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EPA’s New Methane Emissions Rules for Oil and Gas

Posted on 8/26/2015 by Roger Marks

On August 18, 2015, US EPA proposed new standards under the Clean Air Act that aim to reduce methane and VOC emissions from the oil and gas industry. The long-term goal of the proposal is to cut methane emissions from the oil and gas industry sector by 40 to 45 percent (from 2012 levels) by 2025.

The newly proposed methane rules will amend the New Source Performance Standards (NSPS) for the oil and gas industry. The NSPS apply to new, modified, and reconstructed “facilities,” meaning any piece of equipment that can emit Clean Air Act-regulated chemicals.

New Clean Air Act methane rules for oil and gas industry

Three Major Elements of EPA’s New Methane Rule

EPA proposal includes three major elements.

1. Expanding the range of emission sources covered under NSPS to include hydraulically fractured oil well completions, fugitive emission from well sites and compressor stations, pneumatic pumps, and other sources not covered by existing requirements.

2. Updating EPA’s 2012 NSPS to address methane and VOC emissions from sources covered by that rule.

3. Expanding the existing NSPS to equipment not previously regulated. In short, new methane rules will be developed for equipment across the oil and gas source category. Existing VOC standards will be extended to remaining unregulated equipment.

Under the proposed rule, EPA requires the following steps from owners and operators of oil and gas facilities:
  • Finding and repairing leaks at well sites;
  • Capturing natural gas from the completion of hydraulically fractured oil wells;
  • Limiting emissions from new and modified pneumatic pumps; and
  • Limiting emissions from several types of equipment used at natural gas transmission compressor stations, including compressors and pneumatic controllers.
EPA is also proposing that owners or operators of well site-affected facilities conduct an initial survey of “fugitive emissions components,” i.e., parts of equipment from which methane/VOCs can leak. The proposed definition of these components includes valves, connectors, open-ended lines, pressure relief devices, closed vent system, and thief hatches on tanks.

Clarification of Air Permitting Rules for Oil and Gas Industry

EPA also released a Fact Sheet describing clarifications to the air permitting rules for the oil and gas industry.

Under the Clean Air Act’s New Source Review (NSR) permitting rules, owners and operators are required to secure a permit in order to build a new source of emissions or significantly modify an existing source. EPA uses three main factors to determine whether a new source will require a permit. A permit is typically NOT required if the new source:
  1. Shares an industrial grouping (SIC code) with the existing facilities;
  2. Is under control of the same person/people; or
  3. Is located on contiguous or “adjacent” properties.
What Does “Adjacent” Really Mean?

As happens often with the EPA environmental regulations, the standard “dictionary definition” of the word “adjacent” is not necessarily sufficient to capture the EPA’s true meaning here.

EPA has put forward two options for defining “adjacent” in the regulations. The first and more straightforward option is to define “adjacent” as equipment or activities located on the same site or on sites that are within a short distance (1/4 mile) of each other. The second option is to define “adjacent” to include both physical proximity and whether the new source is related-by-function to an existing permitted source (like being connected by a pipeline).

New Clean Air Act Regulations Now Available
A new online course is now available to help environmental engineers, EHS managers, and compliance officers keep their facilities in compliance with the US EPA’s Clean Air Act programs. The Clean Air Act Regulations guides professionals through compliance with Title V permit requirements, emissions and pollution controls, annual greenhouse gas (GHG) reporting, Risk Management Planning (RMP) responsibilities, and more. 

Build the expertise needed to make informed on-the-job decisions that help your site control pollution and maintain compliance. Interactive, easy to use, and available 24/7, the new online course will help you get up to speed with new and changing EPA clean air rules and protect your facility from costly EPA enforcement. 

Tags: Act, Air, Clean, EPA, new rules

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