ACTION ALERT: Tell EPA You Support Rule to Limit Greenhouse Gas Emissions from Oil & Gas Operations
Updated: Sep 12, 2022
Anyone who has lived in a community riddled with fracked wells knows Pennsylvania has struggled with properly regulating the oil and gas industry, which has contributed to high-profile pollution events, consent decrees, and even criminal charges against some of the Keystone State’s worst industry bad actors.
Now, the Environmental Protection Agency (EPA) is considering a purported new “Proposed Rule” that would impose emissions standards and limitations on certain new and existing facilities in the oil and natural gas production, storage, and transmission sectors.
“We use the term ‘purported’ because the Proposed Rule did not include any actual proposed regulations despite taking up 154 single-spaced pages in the Federal Register,” GASP Senior Staff Attorney noted.
So, what *did* EPA do? The agency disclosed its intention to regulate, re-regulate, or more strictly regulate emissions of volatile organic compounds ( also known as VOCs) and greenhouse gases (called GHGs – and methane is one) from oil and natural gas industry sources.
Let’s break down some of those proposed changes.
Leak Detection and Repair Requirements
First, the EPA is proposing leak detection and repair (LDAR) requirements for new well sites that are contingent upon sites’ baseline methane emissions instead of their production volumes.
That means well sites with established baseline methane emissions of 3 tons per year or less would be exempt from leak detection and repair requirements, while well sites with baseline methane emissions of more than 3 tons per year would be required to monitor for leaks of VOCs (and repair them if found) every calendar quarter.
EPA is also considering requiring well sites with baseline methane emissions between 3 and 8 TPY to monitor for leaks of VOCs only semi-annually. EPA further proposes to require leak detection and repair monitoring at new and existing compressor stations on a quarterly basis (such monitoring at existing compressor stations currently must be performed only semi-annually).
Vapor Recovery System Requirements
The new proposed EPA oil and gas rule would also reduce emissions from certain liquid storage tanks using either a vapor recovery system or flare. For the uninitiated: Vapor recovery systems capture VOC emissions before they are released into the atmosphere. Flares destroy harmful VOCs before they can be emitted.
Right now, existing tanks having the potential to emit 6 tons per year or more of VOCs are already subject to such a requirement.
But existing batteries of storage tanks having an aggregate potential to emit 20 or more tons per year of methane *would* be subject to this requirement under the proposed rule. That’s not all: New individual storage tanks or batteries of storage tanks having a potential to emit at least 6 TPY of VOCs would also be required to reduce VOC emissions by at least 95 percent using a vapor recovery device or flare.
Gas Sales Lines Availability
The proposed rule would also eliminate the practice of natural gas flaring from new and existing well sites unless a gas sales line is not accessible to the well site. The Proposed Rule does not say (but does request comment regarding) what constitutes an accessible gas sales line.
A Few Last Rules We Want to Tell You About
The proposed rules would also:
Eliminate emissions of VOCs and methane from new and existing pneumatic controllers. Pneumatic controllers are devices that run on natural gas and are used to regulate pressure and temperature at well sites.
Eliminate emissions of VOC emissions from new and existing liquids unloading operations, with a proposed exception for situations in which zero-emissions unloading is unsafe (in which case emissions still must be minimized). VOCs can be emitted through evaporation during liquids loading and unloading operations.
The Potential Air Quality Impact
EPA projects that the proposed rule if implemented, will reduce the oil and natural gas sector’s emissions of greenhouse gases tremendously. Between 2023 and 2035, the agency projects:
methane to be reduced by 41 million tons
VOCs to be reduced by 12 million tons and
hazardous air pollutants to be reduced by 480 thousand tons
Why does it matter? Consider this:
Not only are those air pollutants leading drivers of climate change, but they are also exacerbating the health impacts of climate change. So many studies have shown that people exposed to methane, VOCs, and other hazardous air pollutants can have an increased likelihood of developing cancer or experiencing other serious health impacts, including damage to the immune system, and neurological, reproductive, developmental, respiratory, and other health problems.
How You Can Weigh In & Ensure Your Voice is Heard
Please know that your opinion matters. You have until Jan. 31 to let the EPA know you support its intention to better regulate air pollution from the oil and natural gas industry.
Just so everyone understands the process, EPA is accepting comments submitted in the following ways:
Through the Federal eRulemaking Portal: It can be reached here and is our preferred method. Follow the online instructions for submitting comments.
By Email: email@example.com. Include Docket ID No. EPA–HQ–OAR– 2021–0317 in the subject line of the message.
By U.S. Mail: U.S. Environmental Protection Agency, EPA Docket Center, Docket ID No. EPA–HQ–OAR–2021– 0317, Mail Code 28221T, 1200 Pennsylvania Avenue NW, Washington, DC 20460.
It’s important to note that any comments must reference Docket ID # EPA-HQ-OAR-2021-0317.
Because we know how confusing this stuff can get, we want to make commenting on these new rules as easy as possible. The form below includes some sample verbiage that you can use and/or supplement and will be routed directly to the EPA.
“Please remember that these public comment periods aren’t just for scientists and those who intimately understand air quality data,” Campbell said. “Your human experience is also important. We encourage everyone who has been personally impacted by emissions from the oil and gas industry to submit a comment so the EPA knows that behind all the cold science are real humans with real concerns.”
Feel free to add your personal thoughts and experiences about dealing with emissions from the oil and gas industry:
Editor’s Note: The public comment period is now closed. Thank you to all who weighed in on the proposed rule. Once EPA finalizes the regulatory text for the proposed rule, it should provide an additional opportunity to comment. It is likely that EPA’s finalized regulatory language will be published for comment in 2022. We’ll keep you posted, so stay tuned.
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