American Oil and Gas Reporter - December 2022 - 30

Additional Details Fail To Reassure
EPA Methane Proposal
By Del Torkelson
WASHINGTON-The latest version of
the U.S. Environmental Protection
Agency's methane regulation sends Lee
Fuller back to a theme he has voiced
about the agency's initial proposal.
" The devil is in the details, " reflects
Fuller, officer of environment and general
strategy for the Independent Petroleum
Association of America. " We did not
have many details last year. Now we
have more details, but a lot of questions. "
In November 2021, when EPA unveiled
its proposed rulemaking to revise the Quad
Oa Clean Air Act (CAA) new source performance
standard for air quality regarding
methane and volatile organic compound
emissions at oil and gas sites, the proposal
lacked customary elements of a formal
proposal (AOGR, December 2021, pg. 33).
After collecting feedback in the form of
470,000 public comments, public hearings
and consultations with tribal councils, the
agency has updated its proposal with a
supplemental draft that fills in some blanks
and makes minor changes, but still appears
to ignore considerations important to many
oil and gas industry representatives.
" For existing sources, which predominantly
will be small ones, the rulemaking's
impact hinges on the nature of the relationship
between these guidelines and state
programs, " Fuller assesses. " Will EPA delegate
much of the implementation to states,
or will it become a real battle between the
states and EPA over how to regulate? States
all have their own ways of writing rules
that are embedded in their state rulemaking
processes. I do not expect they will adopt
whatever EPA tells them to. "
Agency Overview
When EPA unveiled its proposal on
Nov. 11, it noted that oil and gas operations
constituted the country's largest industrial
source of methane, which the agency describes
as a greenhouse gas that traps about
80 times as much heat as carbon dioxide
during its first 20 years in the atmosphere.
EPA estimates that methane is responsible
for a third of the globe's GHG-associated
warming. The agency adds that oil and gas
operations are also significant sources of
smog-forming volatile organic compounds
and toxic air pollutants such as benzene.
" The updates would provide more
comprehensive requirements to reduce
climate and health-harming air pollution,
including from hundreds of thousands of
existing oil and gas sources nationwide, "
30 THE AMERICAN OIL & GAS REPORTER
EPA maintains. " It would promote the
use of innovative methane detection technologies
and other cutting-edge solutions,
many of which are being developed and
deployed by small businesses providing
good-paying jobs across the United States. "
innovative and cost-effective methane detection
technologies, and a streamlined
process for approving new detection methods
as they debut;
· Leverage data from remote sensing
technology to quickly identify and fix
" For existing sources, which predominantly will be small ones,
the rulemaking's impact hinges on the nature of the relationship
between these guidelines and state programs. Will EPA delegate
much of the implementation to states, or will it become a real
battle between the states and EPA over how to regulate? "
EPA also touts the proposal's " SuperEmitter
Response Program, " which seeks
to require operators to respond to credible
third-party reports of high-volume methane
leaks. Ultimately, the agency predicts
that in 2030 the proposal will cut methane
emissions from covered sources by 87%
below 2005 levels.
EPA says the supplemental proposal's
CAA standards complement HR 5376,
" The Inflation Reduction Act " reconciliation
package President Biden signed in
the summer. The agency explains that
the law allocates resources to provide financial
and technical assistance to reduce
emissions, and creates waste emissions
charge for applicable oil and gas facilities
that exceed statutorily specified waste
emissions thresholds. The law includes
incentives for early implementation of
methane reduction technologies and supports
methane mitigation and monitoring
activities, EPA continues.
" Taking into account both the supplemental
proposal and other measures in
the November 2021 proposal, EPA projects
that the proposed standards would reduce
an estimated 36 million tons of methane
emissions from 2023 to 2035, the equivalent
of 810 million metric tons of CO2.
That's nearly the same as all GHGs
emitted from coal-fired electricity generation
in the United States in 2020, " the
agency calculates. " EPA's estimates also
show the updated proposal would reduce
VOC emissions by 9.7 million tons from
2023 to 2035, and air toxics emissions,
including chemicals such as benzene and
toluene, by 390,000 tons. "
According to EPA, key features of the
supplemental proposal will:
· Ensure all well sites are routinely
monitored for leaks until they are properly
plugged;
· Provide industry flexibility to use
large methane leaks;
· Require that flares are properly operated
to reduce emissions and tighten
the criteria that must be met to flare associated
gas;
· Establish emission standards for
dry seal compressors;
· Set a zero-emissions standard for
pneumatic controllers and pneumatic
pumps at affected facilities throughout
all industry segments; and
· Increase recovery of natural gas
that otherwise would go to waste in volumes
that, from 2023 to 2035, are sufficient
to heat an estimated 3.5 million homes
during the winter.
According to S&P Global Market Intelligence
Senior Reporter Tom DiChristopher,
a production site's equipment type
and extent will determine leak monitoring
requirements instead of the original proposal's
use of estimated emissions. " The
requirements will differ for small well
sites, wellhead-only sites, sites with major
production and processing equipment,
and sites on Alaska's North Slope, " he
comments. " The new proposal also
dropped exemptions for well sites with
lower emissions, meaning sites of all
sizes would be subject to the rule. "
Fugitive Emissions
Fuller says many elements of the
proposal seem poorly matched and suggests
that small producers may be particularly
vexed by the fugitive emissions
program, which has troubled IPAA since
the 2021 proposal. " That remains the
principal issue, because the mechanics
of that program relate to operating cost, "
he evaluates.
Fuller acknowledges that EPA's latest
proposal exhibits some strides in accepting
IPAA's comments in favor of using an auditory/visual/olfactory
(AVO) approach as
American Oil and Gas Reporter - December 2022

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