New EPA White Papers May Lead to Additional Oil & Gas Regulation



On April 15, 2014, the U.S. Environmental Protection Agency (EPA) released five technical white papers covering what it considers to be potentially significant sources of emissions in the oil and gas industry.  The white papers focus on technical issues covering emissions and mitigation techniques for methane and volatile organic compounds (VOCs) in the upstream and midstream oil and gas sectors of the industry.  The white papers were issued for external peer review, with comments, additional technical information, and additional data due by June 16, 2014.  The white papers can be downloaded from EPA’s oil and gas air quality website at:  http://www.epa.gov/airquality/oilandgas/whitepapers.html.

As noted in the Obama Administration’s Strategy to Reduce Methane Emissions, EPA plans to use the information in the white papers, along with input received from the peer reviewers and the public, to determine how to best pursue additional reductions from these sources through new or amended regulations.

The five white papers cover:

  • Completions and ongoing production emissions from hydraulically fractured oil wells
  • Emissions from compressors
  • Fugitive equipment leak emissions
  • Emissions from liquids unloading of gas wells
  • Emissions from pneumatic devices

With regard to emissions from completions and ongoing production of hydraulically fractured oil wells, EPA appears to be concerned about the potential methane and VOC emissions associated with the flow back process of completion fluids after initially fracturing or refracturing the well.  Additionally, EPA appears to be concerned about the venting and/or flaring of associated gas during ongoing oil production when gathering or gas sales lines are not available to move the gas to a gas plant for processing.  EPA points out that these emissions were not addressed in New Source Performance Standards (NSPS) Subpart OOOO, Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution covering certain oil and gas VOC emission sources that are constructed new, modified, or reconstructed after August 23, 2011.

Regarding compressors, EPA appears to be concerned about emissions of methane and VOC from degassing centrifugal compressor wet seals and from the rod packing in reciprocating compressors.  NSPS Subpart OOOO currently only addresses these emissions at gathering compressor stations and natural gas processing plants.  Compressors located at well sites are currently exempted by the NSPS.

Fugitive equipment leaks are leaks that could occur from equipment components such as valves, flanges, screwed fittings, pumps, and pressure relief valves.  EPA appears to be concerned that NSPS Subpart OOOO only addresses these emissions at natural gas processing plants, and does not address them at oil and gas production facilities, gathering facilities, transmission facilities, and storage facilities.

The potential for methane and VOC emissions from the liquids unloading of gas wells also appears to be a concern of EPA.  Liquids unloading is also not covered by NSPS Subpart OOOO.

The last white paper addresses EPA’s apparent concern about methane and VOC emissions from pneumatic devices, both pneumatic controllers and pneumatic pumps.  All continuous bleed pneumatic controllers at natural gas processing plants and continuous bleed pneumatic controllers with a bleed rate of at least 6 scfh at oil and gas production and gathering facilities were addressed by NSPS Subpart OOOO.  However, NSPS Subpart OOOOO did not address intermittent or snap-action controllers at any facilities or continuous bleed pneumatic controllers with a bleed rate of less than 6 scfh at oil and gas production and gathering facilities.

These white papers set the stage for either a new oil and gas regulation or an amendment to NSPS Subpart OOOO that addresses EPA’s apparent concerns.

Should you wish to provide additional technical information, additional data, or comments to EPA, submissions are due no later than June 16, 2014 and should be sent by electronic mail to oilandgas.whitepapers@epa.gov.  EPA has requested that submissions include a notation of which white paper is being addressed and that they include a telephone number in case the reviewer has questions about the information provided. 

EPA has also indicated that it may make the information submitted to the email address available to the public.  Business confidential information (CBI) should be submitted via CD ROM or other removable storage device and marked as CBI.  Any information not specifically marked as CBI may be made available to the public.  CBI should be submitted to Roberto Morales, US Environmental Protection Agency Office of Air Quality Planning and Standards, Mail Code: C404-02; 109 T.W. Alexander Drive, Research Triangle Park, NC 27711.

For further information about the white papers, their potential impact, or for assistance in providing comments to EPA, please contact your local Trinity office at (800) 229-6655 or Georgette Reeves, at (512) 349-5800  or greeves@trinityconsultants.com.