Supplemental Proposal to Reduce Emissions

The Environmental Protection Agency (EPA) published a supplemental proposal on December 6^th to update, strengthen, and expand the November 15, 2021, standards to reduce emissions of greenhouse gases and air pollutants/volatile organic compounds (VOCs) from new and existing oil and natural gas facilities.

Proposed revisions include:

• Standards for emissions sources not addressed in November 2021 proposal.
• Stronger standards for sources of leaks, flexible use of high-tech detection methods, and creation of a super-emitter response program.
• Modifications of some proposed November 2021 standards.
• Specific state methane reduction timelines and implementation requirements.

The proposed rule affects existing and new methane emissions sources and sites, which are categorized by wellhead numbers and on-site equipment. Monitoring and leakage repair requirements are imposed until the well site is declared closed per specified requirements.

Proposed Timelines

States must submit plans to the EPA within 18 months after final guidelines are published in the Federal Register and impose a compliance deadline on designated facilities no later than 36 months after the state plan submittal deadline.

The deadline for comments is February 13, 2023, the EPA will hold virtual public hearings on January 10 and 11, 2023, and rule finalization is expected in early 2023.

Key Components: Fugitive Emissions Monitoring

• Mandatory Inspections of All Wellheads
  • Single wellhead only – quarterly audio, visual, and olfactory (AVO) inspection and surface casing valve closure.
    • Small well site (subcategory) – Quarterly AVO and closed/sealed thief hatches.
  • Multi-wellhead only – quarterly AVO and semi-annual optical gas imaging (OGI) or EPA method 21.
  • Sites with multiple wellheads and major production and processing equipment – bimonthly AVO inspection, quarterly OGI monitoring, and closed/sealed thief hatches.
• Leak Remediation
  • Following AVO inspections, repairs must be made within 15 days of inspection.
  • Following OGI/method 21 inspections, initial repair attempt within 30 days of inspection and final repair within 30 days of first attempt.
• Advanced Monitoring Options
  • Matrix of allowable methane detection technologies for fugitive emissions monitoring.
  • Development of streamlined pathway for EPA approval of advanced monitoring/measurement technologies
• Ownership Changes
  • Owners/operators ownership changes at individual well sites annually report.
• Well Closure Process
  • Monitoring required for all sites until wells are plugged.
  • Well closure plans to be submitted within 30 days from production cessation and notification 60 days prior to closure activities.
  • Plan must include steps for closing all wells at site including plugging operations, financial steps to complete closure, and timeline of closure steps completion.
  • Before monitoring can be terminated, the well owner/operator must conduct an OGI survey to confirm zero emissions.
• Flaring
  • Restricted unless there is no sales route line or other beneficial use and must function as designed with pilot light continuously lit.
• Super-Emitter Response Program
  • Owners/operators must investigate and take rapid corrective actions when methane emissions of 100 kg/hr or larger are detected.
• Equipment Restrictions (pneumatic controllers and pumps, centrifugal compressors)
  • New and existing facilities must use zero-emissions pneumatic controllers and pumps.
  • Revised standards for compressors and pumps.
  • Disallows natural gas-powered pneumatic pumps at some facilities.

Emission Source Components

Emission source components in the November 2021 proposal subject to updated requirements are specified as:

• Well completions
• Gas well liquids unloading operations
• Associated gas from oil wells
• Wet seal centrifugal compressors
• Reciprocating compressors
• Pneumatic controllers
• Pneumatic pumps
• Storage vessels
• Groups of fugitive emissions components at well sites, centralized production facilities, and compressor stations
• Equipment leaks at natural gas processing plants
• Sweetening units

The new proposal adds dry seal centrifugal compressors to the list.

Projected Impacts (2023-2035)

• Air Quality
  • Estimated reduction of 36 million short tons of methane emissions (810 million tons CO2 equivalent), 9.7 million short tons of VOC emissions, and 390,000 short tons of hazardous emissions.
• Compliance Cost/Benefit Estimates
  • Annualized regulatory compliance cost is $1.8 billion, annualized recovery value of saleable natural gas is $440 million, net cost of regulatory compliance is $1.4 billion per year.
• Climate Benefits
  • EPA estimated present value of $48 billion.
• Information Collection: Annual Burden Estimates
  • Industry – 2.2 million hours, annual labor cost $166 million.
  • States – 55,467 to 69,333 hours, annual labor cost $7.0 to $8.8 million.
  • Federal – 22,520 hours, total annual labor cost $1.4 million.

Methane Mitigation

For operators seeking to reduce methane emissions at the wellhead, BioSqueeze® provides the most effective solution for eliminating leaks, permanently sequestering methane and VOCs to enable clean production and efficient abandonment.