OIL AND GAS INDUSTRY AIR REG UPDATE Kelli Calhoon O&G REGULATORY UPDATE OCTOBER 2016
SUMMARY • NSPS Subpart OOOO/OOOOa — VOC and methane • Source determination • Methane ICR for existing sources O&G REGULATORY UPDATE OCTOBER 2016 JUNE 2016
NSPS SUBPART OOOO/OOOOa VOC AND METHANE O&G REGULATORY UPDATE OCTOBER 2016 JUNE 2016
BASICS Final Rule published in Federal Register June 3, 2016 • Why methane? • O&G operations are second largest emitter of GHGs in US • Climate action plan — strategy to reduce methane emissions, goal to reduce • emissions from O&G sector NSPS – Applies to new, reconstructed, and modified processes and • equipment O&G REGULATORY UPDATE OCTOBER 2016 JUNE 2016
BASICS Subpart OOOO • Amendments to existing regulations to improve implementation • Subpart OOOOa: • Establish CH 4 standards for emission sources currently regulated for VOC • Extend current VOC standards and establish CH 4 standards for remaining • unregulated equipment Establish CH 4 and VOC standards for emission sources not currently covered by • NSPS Subpart OOOO Best system of emissions reduction (BSER) • BSER for CH 4 = BSER for VOC • O&G REGULATORY UPDATE OCTOBER 2016 JUNE 2016
APPLICABILITY/COMPLIANCE DATES • Applicability – facilities constructed, modified or reconstructed • Between August 23, 2011 and September 18, 2015 Subpart OOOO • After September 18, 2015 Subpart OOOOa • Subpart OOOOa compliance date: • August 2, 2016 or start-up, whichever is later O&G REGULATORY UPDATE OCTOBER 2016 JUNE 2016
Sources covered by the 2012 New Source Performance Standards (NSPS) for VOCs and the 2016 NSPS for Methane and VOCs, by site Location and Required to Reduce Rules that Apply Equipment/ Emissions Under 2012 NSPS 2016 NSPS 2016 NSPS Process Covered USEPA Rules for VOCs* for methane for VOCs Natural Gas Well Sites Completions of hydraulically • • ✔ fractured wells Compressors ✔ • • Equipment leaks ✔ • • Pneumatic controllers ✔ • • Pneumatic pumps ✔ • Storage tanks Oil Well Sites Completions of hydraulically • • ✔ fractured wells Compressors • • ✔ Equipment leaks • • ✔ Pneumatic controllers • • ✔ Pneumatic pumps • ✔ Storage tanks Note: Types of sources already subject to the 2012 NSPS requirements for VOC reductions that also are covered by the 2016 methane requirements will not have to install additional controls, because the controls to reduce VOCs reduce both pollutants. https://www3.epa.gov/airquality/oilandgas/may2016/nsps-table.pdf O&G REGULATORY UPDATE OCTOBER 2016 JUNE 2016
Location and Required to Reduce Rules that Apply Equipment/ Emissions Under 2012 NSPS 2016 NSPS 2016 NSPS Process Covered USEPA Rules for VOCs* for methane for VOCs Production Gathering and Boosting Solutions ✔ • • Compressors ✔ • • Equipment leaks ✔ • • Pneumatic controllers Pneumatic pumps ✔ • Storage tanks Natural Gas Processing Plants* • • ✔ Compressors • • ✔ Equipment leaks • • ✔ Pneumatic controllers • • ✔ Pneumatic pumps • ✔ Storage tanks Natural Gas Compressor Stations (Transmission and Storage) • • ✔ Compressors • • ✔ Equipment leaks • • ✔ Pneumatic controllers Pneumatic pumps • ✔ Storage tanks Note: Types of sources already subject to the 2012 NSPS requirements for VOC reductions that also are covered by the 2016 methane requirements will O&G REGULATORY UPDATE not have to install additional controls, because the controls to reduce VOCs reduce both pollutants. OCTOBER 2016 JUNE 2016 https://www3.epa.gov/airquality/oilandgas/may2016/nsps-table.pdf
SUBPART OOOOa COMPRESSORS • Wet seal centrifugal compressors: Rules that Apply Compressor 2012 NSPS 2016 NSPS 2016 NSPS 95 percent reduction of CH 4 and Location for VOCs for methane for VOCs VOC NG Well Sites Accomplished by flaring or routing • Oil Well Sites back to a process Gathering & Dry seal systems not covered • • • Boosting Stns • Reciprocating compressors: • • NG Processing Replace rod packing every 26,000 • NG Compressor • • hours of operation Stations (T&S) (monitor/document operating hours) or Replace rod packing every 36 months • or Route emissions from rod packing to • process through closed vent system under negative pressure to be reused or recycled O&G REGULATORY UPDATE OCTOBER 2016 JUNE 2016
SUBPART OOOOa PNEUMATIC CONTROLLERS • All except natural gas Pneumatic Rules that Apply Controller 2012 NSPS 2016 NSPS 2016 NSPS processing: natural gas bleed Location for VOCs for methane for VOCs rate limit of six scfh (same as • • NG Well Sites 2012 NSPS, new for compressor Oil Well Sites • • stations) Gathering & • • Low-bleed controllers (gas bleed • Boosting Stns rate<six scfh) at compressor NG Processing • • stations are not subject NG Compressor • • Stations (T&S) • Natural gas processing plants: zero natural gas bleed rate (current NSPS) O&G REGULATORY UPDATE OCTOBER 2016 JUNE 2016
SUBPART OOOOa PNEUMATIC PUMPS Pneumatic Rules that Apply Pump 2012 NSPS 2016 NSPS 2016 NSPS Location for VOCs for methane for VOCs • • NG Well Sites • Well sites (oil and NG): 95 percent • • Oil Well Sites control of CH 4 /VOC if control device already onsite Gathering & Boosting Stns Final rule exempts: limited use • • • NG Processing (operate<90 days/yr), lean glycol circulation pumps, all non-natural gas NG Compressor Stations (T&S) driven pumps (solar, electric, air-driven) Have 180 days from publication in FR to meet requirement • • Natural gas processing plants: zero emissions of CH 4 /VOC For natural gas-driven diaphragm pumps • Because electricity is widely available at NG processing plants • Does not include non-natural gas driven pumps (solar, electric, air-driven) • • USEPA is not finalizing requirements for natural gas-driven piston pumps because they are low-emitting • Final rule removed pumps at gathering and boosting stations and compressor stations — USEPA did not have enough information about prevalence of use at these sites O&G REGULATORY UPDATE OCTOBER 2016 JUNE 2016
SUBPART OOOOa HYDRAULICALLY FRACTURED WELL COMPLETIONS Rules that Apply Well 2012 NSPS 2016 NSPS 2016 NSPS Location for VOCs for methane for VOCs • • NG Well Sites • Now includes oil well sites Subcategory 1 wells (non-wildcat, non- • • • Oil Well Sites delineation) Reduced emissions completions (RECs), must have separator onsite during flowback period (some • exceptions) Not required for wells with gas-to-oil ratio<300 scf/bbl (maintain records) • Not required if not technically feasible — use combustion controls • Phase in: can use combustion controls until November 30, 2016 • After November 30, 2016 utilize RECs, as applicable • Subcategory 2 wells (exploratory, delineation, low-pressure) • Use combustion device or completion vessel and separator (unless technically infeasible for • separator to function) • Modification defined as new well site or fracking/refracking at existing site Refracture- recompletion not considered “modification” if use green completions and • meet notification and reporting requirements for new wells O&G REGULATORY UPDATE OCTOBER 2016 JUNE 2016
SUBPART OOOOa FUGITIVE EMISSIONS Rules that Apply Fugitive Emissions 2012 NSPS 2016 NSPS 2016 NSPS Equip Location for VOCs for methane for VOCs • • NG Well Sites • NG Processing – same as 2012 NSPS • • Oil Well Sites • Final rule removed incentive for Gathering & reductions in leak survey frequency • • Boosting Stns • Monitoring Plan required • • NG Processing Outlines measures for locating • NG Compressor • • Stations (T&S) sources and detection technology to be used, number and ID of components, site map, observation path, equipment verification procedures • Final rule allows use of optical gas imaging (OGI), Method 21, or other emerging technology with approval • Fugitive emissions OGI – Any visible emission • Method 21 – 500 ppm • • Does not include equipment that vents natural gas as part of normal operation O&G REGULATORY UPDATE OCTOBER 2016 JUNE 2016
SUBPART OOOOa Fugitive Emissions Monitoring Schedule Type of Facility Initial Leak Repeat Leak Repair Leaks Notable Monitoring Survey Survey Frequency Within Exemptions Well sites Within 60 days of start- Semi-annual, at least 30 days, unless Sites with only (oil and natural gas) up of production or by four months apart shutdown required then wellheads June 3, 2017; whichever at next shutdown within is later two years Compressor Stations - Within 60 days of start- Quarterly, at least 60 30 days, unless Can waive quarterly Gathering & Boosting, up or by June 3, 2017; days apart shutdown required then inspection if 2/3 of Transmission whichever is later at next shutdown within quarter has 0 o F or two years below average temperature O&G REGULATORY UPDATE OCTOBER 2016 JUNE 2016
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