Gas flaring could be eliminated in most cases under proposed regulations. Photo courtesy of GreenPacks.
Some very exciting news just came out of the EPA. In Ken Ward Jr.’s blog, Sustained Outrage, there is a July 28 post that informs us that the EPA just released Proposed Amendments to Air Regulations for the Oil and Natural Gas Industry (ONG). An 8-page Fact Sheet on the document is available on the EPA website. Generally, the proposed changes fall into one of four categories: reducing volatile organic compound (VOC) emissions, reducing sulfur dioxide emissions, revising the air toxics standards (to reduce cancer risk and other ill health impacts) from oil and natural gas production and revising air toxic standards to reduce risk of health impacts from natural gas transmission and storage. The EPA will accept public comment for 60 days after publication in the Federal Register. Final action must be taken by the EPA by Feb. 28, 2012.
Here’s the very distilled recap :
REDUCING VOC EMISSIONS During the flowback stage of well completion, fracturing fluids, high-salinity water and gas come to the surface at a high velocity and volume. Flaring is employed to burn off the gas during this gushing phase until the majority of the liquid and solid contaminants have been forced out by the pressures generated by the fracking process, the gas flows more purely, and is then collected and treated.
Much methane is lost during flowback and flaring, and other VOCs and hazardous air pollutants (HAPs) such as benzene, ethylbenzene and n-hexane are also released. Raw natural gas is primarily composed of methane, a VOC and greenhouse gas which is 20 times as potent in greenhouse effect as carbon dioxide. Oil and natural gas production accounts for nearly 40% of all US methane emissions. VOCs contribute to the formation of ground-level ozone (smog).
The green completion process, also known as Reduced Emissions Completions, is a technology which captures gas which would otherwise be lost during well completion and puts it into the production line so that it can be treated and sold.
Interestingly, employing the green emission technology results in sizable savings to the natural gas industry. The EPA estimates the net savings to industry through application of the proposed rule would be nearly $30 million annually. (One seriously wonders why it takes a federal law to force an industry to employ technology that not only raises net revenue, but also reduces public health risks.)
EPA estimates that the use of green completion technology will reduce VOC emissions from hydraulic fracturing by almost 95%, methane being one of the VOCs. VOCs across the ONG industry are expected to fall by nearly 25% if the proposals are implemented. Wyoming and Colorado already require green completions.
Other equipment proposals: 1)Centrifugal compressors would have to be equipped with dry seal systems. Reciprocating compressors would have to replace rod systems every 26,000 hours. 2) The proposed regulations would require that new or replaced pneumatic controllers be driven by a non-gas power source. 3) Condensate tanks which handle a certain volume of condensate or crude oil must reduce VOC emissions by 95%. 4) Natural gas processing plants must strengthen leak detection an repair.
SULPHUR DIOXIDE Stronger source performance standards for sulfur dioxide would be required for plants processing gas with the highest sulfur dioxide content. (Sulphur dioxide standards were issued in 1985.)
REDUCING CANCER RISK/HEALTH IMPACTS (for both ONG production and natural gas transmission and storage) All large dehydrators would have to reduce emissions of air toxics (such as benzene) by 95%. Emissions standards would be established for small dehydrators at major sources. The proposed regulations are expected to reduce emissions of air toxics by 30%.
BACKGROUND The Clean Air Act (CAA) requires a review every 8 years for new source performance standards (NSPS) for industries that contribute to air pollution which endangers public health. The existing NSPD for VOCs were issued in 1985. You do the math. A similar story can be told about air toxics standards. The CAA requires a one-time review after a standard is issued to find out what risks remain and whether or not more protective standards are needed. The CAA also requires technical review every 8 years to identify better emission control technologies. Both the standards for ONG production and those for natural gas transmission and storage were issued in 1999. Environmental groups sued the EPA in Jan. 2009 for failing to review the NSPS. The U.S. Court of Appeals for the D.C. District entered a consent decree in Feb. 2010 that required the EPA to sign proposals related to the review of those standards by July 28, 2011 and issue final standards by Feb. 28, 2012.
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The Achilles heel of the proposed amendments shows up under the paragraph on page 6 titled REDUCING COMPLIANCE BURDENS. “The proposed exemption would apply to sources covered by the NSPS that are not major sources and that do not obtain Title V permits for another reason….. VOC sources are considered “non-major” if they emit less than 100 tons per year…..That emissions threshold is lower in certain nonattainment areas, however.”
The Wetzel County Action Group filed a legal appeal to the WV Air Quality Board (AQB)to consider compressors and gas wells collectively so as to be covered by Clean Air Act rules. From the FrackCheckWV post by Duane Nichols on May 21, “The AQB said that insufficient evidence had been presented to support a claim that the new compressors stations and/or the wells feeding them were in fact “contiguous or adjacent”, as defined by the legal definitions of these terms under the Clean Air Act in spite of existing pipelines interconnecting them.”
Thank God for some monitoring , oversite and regulations. I hope that they are retroactive to the wells that are already producing in QWest Virginia.
I did not see any rules that will require Gas Companies to pay for additional State inspectors. One person wsho spoke at the meeting in Morgantown suggested that every well should have an inspector. I spoke on having training, experience and education sufficient to understand what was going on in the drilling, fracking, etc so that the inspectors could adequately oversee the situation. This is a good start and I’m sure that there will be many more comments. Meg D.