On April 15, 2014, the U.S. Environmental Protection Agency (EPA) released for public comment and external peer review five white papers on potentially significant sources of methane and volatile organic compound (VOC) emissions in the oil and gas sector. As instructed in the White House’s Strategy to Reduce Methane Emissions issued in March 2014 and with the input from the peer reviewers and the public, the EPA will determine how to best pursue additional emission reductions from these sources. The comment period ends on June 16, 2014.
The technical white papers analyzing methane and VOC emissions cover five sectors: compressors, emissions from completions and ongoing production of hydraulically fractured oil wells, leaks, liquids unloading, and pneumatic devices. Each white paper defines the source of the emissions, provides data on the emissions, and discusses available mitigation techniques. At the end of each white paper, there is a section requesting reviewers to consider listed questions, some specific to the methodology addressed in the paper and others addressing more general knowledge gaps on methane emissions and VOCs.
After the review period, the EPA will evaluate whether the current emission requirements need to be changed. In April 2012, the EPA completed rules to reduce emissions from oil and gas operations, including hydraulic fracturing. These rules targeted compressors, oil storage tanks and other oilfield equipment. For all wells being completed on or after January 1, 2015, operators must install “green completions” which are technologies that capture harmful emissions.
In August 2012, the EPA issued standards for oil and gas production facilities under the New Source Performance Standards (NSPS). These standards establish control requirements for hydraulic fracturing, including combustion controls during frack flowback which took effect in October 2012.
One year later, the EPA updated its 2012 performance standards addressing VOC emissions from storage tanks. The updated rule clarifies the type of storage tanks that are subject to the NSPS and delays the compliance deadlines for some tanks until April 15, 2014 and for others until April 15, 2015.
This post was written by Barclay Nicholson (barclay.nicholson@nortonrosefulbright.com or 713.651.3662) from Norton Rose Fulbright's Energy Practice Group.
