BMP of Oil and Gas Development
 

2012 EPA Amendment of New Source Performance Standards

For the full text of the EPA final rule, as well as EPA summaries of the rule by subject matter, visit the EPA Oil and Gas Air Quality Actions Page.

The EPA recently released a final rules amendment of the New Source Performance Standards for Volatile Organic Compounds released from oil and gas production sites, including the first federal air standards for hydraulically fractured natural gas wells. Although the rule focuses on hydraulically fractured natural gas production wells, the section on pneumatic controllers also applies to oil production wells. The rules were issued and signed by EPA Administrator Lisa P. Jackson on April 17, 2012, and go into effect 60 days after being published in the federal register (which has not yet happened as of 7/3/2012).

The rules apply to all new high-pressure hydraulically fractured wells drilled after Aug. 23, 2011 and establish two phases for reducing Volatile Organic Compound emissions. During Phase 1, which will last from the effective start date of the rule until Jan. 1, 2015, industry is required to reduce VOC emissions, but may accomplish this through flaring using a completion combustion device unless combustion is a safety hazard or is prohibited by state or local regulations. During Phase 2, which begins Jan. 1, 2015, operators must capture the gas and make it available for use or sale, which can be done through green completions. During both phases, VOC emissions must be reduced by 95 percent. New exploratory wells, delineation wells, and hydraulically fractured low-pressure wells where natural gas cannot be routed to the gathering line are not required to have green completions, but emissions must still be reduced using combustion during well completion unless combustion is a safety hazard or is prohibited by state and local regulations.

For wells needing to be refractured, if they are refractured and recompleted using green completion, they will not be considered “modified” wells and therefore will not require new state permitting in many states. This incentivizes operators to use green completion when refracturing even before the Jan. 1, 2015 deadline. The new rule also requires the operator to notify the EPA by email at least 2 days before completion work begins. However, if they must notify the state in advance by state requirements, such notification will also satisfy the EPA notification requirement.

Additionally, within 1 year of the effective date of this rule, new and modified pneumatic controllers used at both oil and natural gas well sites must allow for gas bleed of no more than 6 cubic feet of gas per hour, new storage tanks with VOC emissions of 6 tons a year or more must reduce emissions by at least 95 percent, and both existing and new small glycerol dehydrators must meet a unit-specific limit for emissions of benzene, toluene, ethylbenzene and xylene that is based on the unit’s natural gas throughput and gas composition. The definition of “associated equipment” has also been amended, and now all emissions from all storage vessels are counted toward determining whether a facility is a major source under NESHAP.“

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