Proposed Updates to 2012 NSPS for the Oil and Gas Industry to Reduce Emissions of Greenhouse Gases
Summary
On August 18, 2015, the U.S. Environmental Protection Agency (EPA) proposed to amend the new source performance standards (NSPS) for the oil and natural gas source category by setting standards for both methane and volatile organic compounds (VOC). This rule builds on the 2012 NSPS for VOC emissions for the oil and natural gas industry. The EPA is including requirements for methane emissions in this proposed rule because methane is a potent greenhouse gas, and the oil and natural gas category is currently one of the country's largest emitters of methane. This proposed amendment includes the following:
- Proposing emission standards for methane and VOC from emission sources not currently covered by the NSPS; hydraulically fractured oil well completions, fugitive emissions from well sites and compressor stations, and pneumatic pumps
- Proposing methane standards for the following emission sources; hydraulically fractured gas well completions, equipment leaks at natural gas processing plants that are currently regulated for VOC
Who is affected?
The following source categories are affected by this proposed rule.
| NAICS Code | Examples of Regulated Entities |
|---|---|
| 211111 | Crude Petroleum and Natural Gas Extraction |
| 211112 | Natural Gas Liquid Extraction |
| 221210 | Natural Gas Distribution |
| 486110 | Pipeline Distribution of Crude Oil |
| 486210 | Pipeline Transportation of Natural Gas |
What are the proposed standards?
The following table summarizes the proposed standards for the affected sources.
| Source | Proposed Standard |
|---|---|
| Compressors (except for those located at well sites) | Centrifugal Compressors - 95% reduction of methane and VOC from wet seal. Reciprocating Compressors - replace the rod packing after 26,000 hours of operation or 36 months of route emissions through a closed vent system under negative pressure. |
| Pneumatic Controllers | Natural gas bleed rate - 6 standard cubic feet per hour to reduce methane and VOC emissions from individual, continuous bleed, natural gas-driven pneumatic controllers at all locations except natural gas processing plants. For natural gas processing plants, the proposed rule regulates methane and VOC emissions by requiring natural gas operated pneumatic controllers to have a zero natural gas bleed rate. |
| Pneumatic Pumps | Chemical/methanol pumps and diaphragm pumps at all locations except natural gas processing plants - 95% reduction of methane and VOC. Chemical/methanol pumps and diaphragm pumps at natural gas processing plant - zero (0) emissions. |
| Hydraulically Fractured Oil Well Completions | For subcategory 1 wells (non-wildcat, non-delineation wells) - reduced emissions completions (RECs) or "green completions," to reduce methane and VOC emissions. For subcategory 2 wells (wildcat, delineation wells) - use a completion combustion device to reduce methane and VOC emissions. |
| Fugitive Equipment Leaks from Well Sites, Compressor Stations (includes transmission and storage segment and gathering and boosting segment) | Requires leak detection and repair (LDAR) program Conduct fugitive emissions surveys semiannually with optical gas imaging (OGI) technology and repair the sources of fugitive emissions within 15 days. The required survey frequency would decrease from semiannually to annually for sites that find fugitive emissions from < 1% of their fugitive emission components during a survey. The frequency would increase from semiannually to quarterly for sites that find fugitive emissions from 3% or more of their fugitive emission components during a survey. |
How can GHD help?
GHD's air professionals can assist your facilities prepare and comply with the upcoming changes to the NSPS regulation.
Our services include the following:
- Conducting site visits to identify potential emission sources
- Estimating methane and VOC emissions
- Developing compliance programs
- Recordkeeping programs
- Reporting assistance
This rule is a proposed rule signed by EPA Administrator Gina McCarthy on August 18, 2015. The proposed rule has been sent to the federal register for publication. There is a comment period of 60 days after date of publication in the federal register. The EPA will also hold public hearings on the proposal. Details will be announced in a separate notice. For assistance with getting ahead on applicability of this rule, please contact GHD for further details.
For more information:
E: GHD | T:+1 800 265 6102