American Oil and Gas Reporter - December 2022 - 32

prioritizes directing it to sales outlets, or
secondarily, utilizing the gas on site or
injecting it. " Alaska has injected gas for
many years, " he observes. " If you do
that, the gas may be available for sales in
the future. "
Absent all those options, he continues,
operators may flare gas through closed
systems. " There are other parts of the
rule that increase the stringency of managing
flares or combustion devices to
make sure they function continuously
and oxidize the methane to carbon dioxide, "
Fuller notes. " Making sure it combusts
properly always has been a challenge
that depends on the consistency of the
volume and its heating value.
" Technical minds will have to examine
it closely, but the idea is that even sites
that use natural gas as a supplemental
fuel source must keep the flare continuously
operational, " he assesses.
Along with processing and transmission,
other aspects of the rule deal with
the liquids unloading process, Fuller mentions,
with the goal of minimizing the
need to vent gas and stipulating best
management practices when venting must
occur. Another section focuses on storage
vessels and has seen considerable changes
since the 2021 version. The new supplement
seeks to clarify definitions for storage
vessels and what constitutes modifications
to them, Fuller details.
" EPA is trying to move away from
grappling with vapor space connections
as a criteria, " he reports. " Now the agency
is focusing on liquid links. "
State Authority
The new proposal raises compatibility
questions with the process outlined in
CAA Section 111(d) through which states
can become the primary authorities for
implementing and enforcing the proposed
requirements, Fuller warns. He says this
section was designed to deal with the
rare instance of a pollutant that was
neither a criteria pollutant, such as VOCs
and sulfur oxides, or a hazardous air pollutant,
such as benzene.
In the structures for both VOCs and
HAPs, he explains, a state's failure to
attain ambient air quality standards is the
regulatory driver that forces states to craft
regulatory plans for areas of nonattainment.
Historically, Fuller says, the CAA regulatory
structure guides states' actions regarding
reasonably available control technologies
for existing sources. Congress
created Section 111(d) for a small universe
of pollutants, allowing for nationwide
control of existing sources with the advent
of a new source standard.
" Section 111(d)'s significance changed
when EPA classified GHGs as pollutants, "
he recounts. " GHGs are pervasive. Under
the prior 111(d), it may have covered 25
operations across the country. Even when
EPA was looking at existing utility electric
generators, that still would apply to maybe
150 coal-fired boilers. This proposal is
looking at a million oil and gas wells.
" It's a totally different framework under
a program that never really envisioned
such a large scope, " he continues. " EPA
has come up with a structure that is somewhat
modeled after a state implementation
plan (SIP) for ozone nonattainment, in
which a state has a certain amount of time
to develop new regulations and a certain
amount of time to implement them. "
In the instance of ozone nonattainment,
Fuller details, EPA evaluates and determines
whether to accept a SIP, including
how it adapts EPA guidelines for reasonably
available technology/controls. " In
this case, EPA puts out its Quad O(c)
Emissions Guidelines for which it basically
has a model regulatory structure, " he relates.
" If the state adopts them as written,
it gets EPA approval. "
However, he notes, states such as Colorado,
Pennsylvania and California already
have methane regulations, while many
others already have VOC rules. " EPA gives
Your first line of defense
for water influx, casing leaks, and
inefficient flood patterns
32 THE AMERICAN OIL & GAS REPORTER
American Oil and Gas Reporter - December 2022

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