U.S. EPA Proposed Amendments to Subpart OOOO and Proposed a New Subpart OOOOa
Posted: August 27th, 2015Authors: JP K.
The anticipation ended on August 18, 2015 when the U.S. Environmental Protection Agency (EPA) proposed to amend 40 CFR Part 60, Subpart OOOO (Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution) and create a new subpart OOOOa. Subpart OOOO would be amended to apply to facilities constructed, modified or reconstructed after August 23, 2011 (i.e., the original proposal date of subpart OOOO) and before the proposal date of the new subpart OOOOa. Subpart OOOOa would apply to facilities constructed, modified or reconstructed after the date the proposal is published in the Federal Register and would include current Volatile Organic Compound (VOC) requirements already provided in subpart OOOO as well as new provisions for methane and VOC across the oil and natural gas source category.
U.S. EPA will receive comment on the proposals for only 60 days after it is published in the Federal Register. If you haven’t started reviewing the proposals, start now. The publication is nearly 600 pages long! ALL4’s E&P Team is here to help you wade through portions of the proposal. In fact, this blog addresses the low hanging fruit as much of the content comes from U.S. EPA’s Fact Sheet.
Takeaways from the U.S. EPA Fact Sheet
U.S. EPA’s proposal would:
- Require that the oil and natural gas industry also reduce/control methane.
- Require methane and VOC reductions for sources that the 2012 standards did not address (e.g., natural gas capture from hydraulically fractured oil wells). U.S. EPA published a Table that illustrates the differences in regulated sources between the 2012 standards and the 2015 proposed standards.
- Extend emission reduction requirements further “downstream”, covering equipment at natural gas transmission compressor stations and at gas storage facilities, which was not regulated in the 2012 standards.
- Require leak detection and repair program.
- Limit emissions from new and modified pneumatic pumps.
- Provide guidelines for states to reduce VOC emissions from existing oil and gas sources in certain ozone nonattainment areas and in the Ozone Transport Region.
- Clarify Federal air permitting requirements as they apply to the oil and natural gas industry.
Sources already subject to the 2012 standards for VOC reductions are not expected to have to install additional controls, because the best system of emission reduction (BSER) for methane is the same as for VOC.
We intend to dig into the rule and prepare subsequent blogs on more specific topics that we think oil and gas operators will find helpful. We invite you to interact with us by posting questions or provide ideas for future blog topics. In the meantime, we dug a little deeper into the well completion requirements and noted the key observations below:
Key Observations for Source Requirements
U.S. EPA has recognized that lower production well sites would generally result in lower fugitive emissions and such well sites are mostly owned and operated by small businesses. Due to concerns about the burden of fugitive emission requirements on small businesses, U.S. EPA is proposing to exclusions for low production well sites. The sections below provide additional information concerning exclusions.
- Wells with a gas-to-oil ratio (GOR) of less than 300 scf of gas per barrel of oil produced would not be affected facilities subject to well completion provisions.
- U.S. EPA has explicitly solicited comment on whether a GOR of 300 is the appropriate applicability threshold. Be sure to submit your comments to support your views.
Fugitive Emissions from Well Site & Compressor Stations
- The proposal acknowledges that some well sites consist only of one or more wellhead and have no ancillary equipment. Thus, the proposal would exclude fugitive emission requirements for well sites that contain only one or more wellhead.
- The proposal would also exclude low producing well sites. A low producing well site would be defined by the average combined oil and natural gas production less than 15 barrels of oil equivalent (boe) per day averaged over the first 30 days of production.
- Due to insufficient information, the proposal does not include standards for liquids unloading.
- U.S. EPA has explicitly solicited comment on nationally applicable technologies and techniques that can be applied to new gas wells that will reduce methane and VOC emissions from liquids unloading.
We will be discussing the Draft Control Techniques Guidelines for reducing VOC emissions from existing oil and gas sources in certain ozone nonattainment areas and states in the Ozone Transport Region. We will also be discussing the proposed Source Determination Rule that will determine when multiple pieces of equipment and activities in the oil and gas industry must be deemed a single source.
Contact JP Kleinle (610) 933-5246, extension 120 or at firstname.lastname@example.org to discuss the content of this blog or any other oil and gas related topics.