New Regulations Proposed to Reduce Methane Emissions from the Oil and Gas Industry

On November 2, 2021, the U.S. Environmental Protection Agency (U.S. EPA) announced a proposed rule to reduce methane emissions from the oil and gas industry.  This announcement coincided with President Biden’s announcement of the Global Methane Pledge at the COP26 meetings in Glasgow, Scotland, which aims to reduce global methane emissions by 30% by 2030, compared to a 2020 baseline.

The U.S. EPA proposal was published in the Federal Register on November 15, 2021 and while that notice requested comments on the proposed regulatory approach by January 14, 2022, U.S. EPA has already extended the comment period to January 31, 2022.  U.S. EPA intends to issue a supplemental proposal in early 2022, with a final rule to be published by the end of 2022.

The proposed rule will amend the existing New Source Performance Standards (NSPS) for Crude Oil and Natural Gas Facilities (40 CFR Part 60, Subparts OOOO and OOOOa) and establish a new Subpart OOOOb.  The proposal would also establish new Emissions Guidelines (EG) in Subpart OOOOc for existing sources in these source categories.  The proposed EG would require states to regulate hundreds of thousands of existing sources nationwide for the first time, significantly expanding the impact of the emissions reduction requirements.  The key components of the proposal include:

• Finding and repairing methane leaks from well sites and compressor stations;
• Replacing current pneumatic controller technologies with zero-emitting technologies;
• Eliminating venting of natural gas associated with oil well operations;
• Expanding coverage of storage tank requirements to include tank batteries;
• Expanding the types of pneumatic pumps that are covered by the regulations; and
• Establishing nationwide requirements to control methane emissions from liquid loading and unloading operations, increasing leak detection and repair requirements for natural gas processing facilities, and strengthening requirements for reciprocating and centrifugal compressors.

With this proposal, U.S. EPA is also establishing the Protocol for Using Optical Imaging to Detect Volatile Organic Compound and Greenhouse Gas Leaks under Appendix K to 40 CFR Subpart 60.  This new protocol will provide owners/operators with the flexibility to utilize state-of-the-art leak detection and monitoring technology to more efficiently identify and control leaks at well sites and compressor stations.

U.S. EPA estimates that these regulations will reduce methane emissions by approximately 41 million tons through 2035.  The regulations would also increase the recovery and availability of natural gas that would otherwise be lost to the atmosphere.

A copy of the proposal, fact sheets, and additional information are available on the U.S. EPA website.  U.S. EPA has also published a table that compares the sources covered (or proposed to be covered) by the four Part 60 rules.

ALL4 will continue to monitor this regulatory development and will report back periodically regarding the progress of these potentially precedent-setting regulatory changes. If you have any questions in the interim, please reach out to your ALL4 project manager or Daryl Whitt at dwhitt@all4inc.com for more information.