Oil and gas emissionsreductions strategies**EPA Public Meeting on Air Regulations for the Oil and Gas Industry** **Elizabeth Paranhos, Attorney and consultant, on behalf of** **EDF and Wyoming Outdoor Council August 3, 2010** Natural gas is a cleaneralternative to coal**• The smart use of natural gas for electricity gener ation** **can be a critical part of an overall strategy to re duce air** **pollution from our electricity sector, as it is a f ar cleaner** burning**resource than coal-fired generation. • As natural gas is increasingly utilized as a clean** **er burning alternative, it is imperative that we ensur** **e that proper techniques are used to reduce emissions at a** **ll stages of natural gas development, from exploration** **and production through distribution.** **Activities in the natural gas exploration and production (“E&P”), storage, processing,** **transmission and distribution sectors and in the oi l** **E&P sectors emit substantial amounts of – ozone precursors (VOCs and Nox)** **– methane (CH4) – and hazardous air pollutants (HAPs).** Oil and gas emissions2006 VOC and NOx emissions and projected 2010/2012emissions for key oil and gas producing basins in theIntermountain West and Gulf region.Oil and gas methaneemissions**• Third largest source of U.S. methane emissions** **• At least 125.5 million metric tons of CO2 equivalent (“MmtCO2e”) in 2008** **– Equal to the emissions of 33 coal-fired power plants** **1 • The number is likely much larger as** **emissions underreporting is well documented by EPA.** **2**Barnett Shale 2009 HAPEmissions**Source Tons per Day** **HAPs Compressor engine exhaust 3.6** **Condensate and oil tanks .60 Production Fugitives .62** **Well drilling and completions .49 Gas Processing .37** **Transmission Fugitives .67**Health effects andenvironmental impacts**• Airborne contaminants emitted from oil and gas activities contribute to pollution** **associated with serious human health effects and adverse environmental consequences** **including ground-level ozone or “smog”, particulate pollution, toxic air pollution,** **climate-disrupting pollution, and the haze that obscures scenic vistas in national parks and** **wilderness areas.**Cost-effective technologiesare available**• EPA estimates that as much as 300 billion cubic feet of natural gas (methane) is lost each year.** **• This equals over $1 billion in lost profits. 3** **• Oil and gas companies have saved over $800 million through implementing voluntary methane** **air pollution reduction technologies. 4** **• Broad adoption of these technologies could reduce emissions by approximately 41 Mmt** **CO2e. 5** Examples of cost-effectivepollution reduction measures**• low or no bleed pneumatic devices; • green or reduced emissions completions and recomp** **letions; • still vent condensers and glycol flash separators** **or other technologies that reduce vented emissions from glyc** **ol dehydrators by 98% or better;** **• vapor recovery units or other equipment that reduc ed emissions** **from crude oil, condensate and produced water tanks by 98% or** **better; • leak detection and repair for production fugitives** **; • plunger lifts and “smart” well automation systems f** **or well unloading; • BASO valves on heater-treaters, gas dehydrators an** **d gas heaters; • leak detection and repair at compressor stations;** **• replacement of compressor rod packing; • dry seals for centrifugal compressors;** State actions**A number of western states, including Colorado, have implemented or propose** **to implement cost-effective pollution control measures.** CO and WY regulations forpneumatic devices**• Colorado – All new, replaced or repaired pneumatic devices at** **production facilities must be low or no-bleed.** **6 – All pneumatic controllers at E&P sites, upstream n** **atural gas compressor stations, natural gas drip stations and** **gas processing plants located in an ozone nonattainment** **or attainment/maintenance areas must have VOC emission** **s equal to or less than a low-bleed controller.** **7 • Wyoming** **– All new pneumatic controllers and existing pneumat ic** **controllers at a modified facility must be low or n o-bleed or** **route discharge streams to a closed loop system. 8** CO, WY, MT regulations forwell completions**• Colorado – Colorado requires the use of green completions on** **all oil and gas production wells unless not technically and** **economically feasible. 9** **• Wyoming – Requires green completions in the Jonah-Pinedale** **Anticline Development Area (“JPAD”). – Has recently expanded this requirement to all area** **s of** **concentrated oil and gas development (“CDA”s). 10** **• Montana – VOC vapors greater than 200 Btu per cubic foot fro** **m wellhead equipment with the potential to emit 15** **tpy or greater must be routed to a capture or control device.** **11**CO and WY regulations fordehydrators**• CO – Must control by 90% actual, uncontrolled VOC emiss** **ions of 15 tpy or more from vents on glycol dehydrators loca** **ted at all oil and gas E&P operations, natural gas compressor** **stations, drip stations or gas processing plants.** **12 – Operators within a one-quarter mile of a public pl** **ace in Garfield, Mesa and Rio Blanco counties in the Picea** **nce basin must control emissions of VOCs by 90% from all dehyd** **rators with a potential to emit 5 tpy VOCs.** **13 • WY** **– Control of HAPs and VOCs by at least 98% at all new and** **existing dehydration units operating in the JPAD. 14** **– All new and existing dehydrators in CDAs and statew ide must** **control HAPs and VOCs by 98% upon FDOP. 15** CO, WY and MT regulationsfor tanks**• Colorado – Control of VOC emissions by 95% from condensate, cr** **ude oil and produced water tanks with PTE 5 tpy of VOCs located within one** **-quarter mile of a public place in Garfield, Mesa and Rio Blanco counties in t** **he Piceance basin. 17** **– Owners or operators of condensate tanks whose cumul ative actual uncontrolled** **VOC emissions are > 30 tpy located at exploration and production sites w** **ithin ozone NA/ NA/M areas must meet declining emissions red** **uctions over time. 18** **– Statewide, new and existing condensate tanks that emit >** **20 tpy of VOCs must control emissions by 95%.** **19 • Wyoming** **– VOC emissions from condensate, oil and produced wat er tanks located at new or** **modified facilities in the JPAD and CDAs must control flash emissions upon** **FDOP. – Statewide, new and modified facilities must control** **VOC flash emissions**≥**10 tpy by 98% upon FDOP.** **16 • Montana** **– VOC vapors greater than 200 Btu per cubic foot fro m** **wellhead equipment with the potential to emit 15 tpy o r** **greater must be routed to a capture or control devic e.** **20**CA Climate ChangeScoping Plan**• Proposes to address fugitive emissions from on- and off-shore sources.** **• Fugitive emissions are primarily from well and process equipment venting.** **• Proposed controls range from LDAR to low or no-bleed pneumatic devices and** **replacement of compressor rod packing.** Opportunity**An immense opportunity exists to implement cost-effective clean air** **measures that apply to a broad range of sources and pollutants.** Citations**[1] Calculated using EPA’s GHG Equivalencies Calcul ator,** **http://www.epa.gov/RDEE/energy resources/calculator.html#results** **. [2] EPA Technical Support Document for the proposed** **GHG Mandatory Reporting Rule, p. 23. [3] Nathanial Gronewold, Greenwire, “Industry Spotl** **ighting Efforts to Curb Fugitive Emissions”, May 19 , 2009.** **[4] U.S. EPA, Natural Gas STAR Program, available at** **http://www.epa.gov/gasstar/ .** **[5] U.S. EPA, Natural Gas STAR Program, available a t** **http://www.epa.gov/gasstar/ . Based on a thirty percent reduction** **from 2008 emission levels. [6] CO Regulation 7, XVIIIColorado Oil and Gas Conse** **rvation Commission rule 805(b)(2)(E). [7] CO Regulation 7, XVIII.C. Upstream means upstre** **am of natural gas processing plants. [8] Wyoming Oil and Gas Production Facilities, Chap** **ter 6, Section 2 Permitting Guidance (March 2010) ( “WY Revised** **March 2010 Guidance”). [9] Final Rule, Colorado Oil and Gas Conservation C** **ommission,**§**805(b). [10] WY Revised March 2010 Guidance,** supra**note 9, at 15. [11] MT Admin. Rules** §**17.8.1711. This rule applies to all oil and gas fa cilities that have the potential to emit 25 tpy of** **a regulated air pollutant, including HAPs. Oil and gas facilities include wells and associated equipm** **ent used to produce, treat, separate or store oil, natural gas,** **or other liquids produced by the well. MT Ann. Co de (2009)** §**75-2-103. [12] CO Regulation 7, XII.H.** **[13] Final Rule, Colorado Oil and Gas Conservation Commission,** §**805(b). [14] WY Revised March 2010 Guidance,** supra**note 9 at 37. [15] Alternatively, upon FDOP units must be equipp** **ed with reboiler still vent condensers and glycol fl ash separators. If** **, after 30 days, potential VOCs > 8 tpy, units must install combustion control capabl** **e of reducing emissions by 98%. After one year, combustion units may be remov** **ed if total potential VOC emissions < 8 tpy.** **[16] Note that the emission threshold for the appli cation of this requirement differs depending on an** **individual tank’s location in the state** **[17] Final Rule, Colorado Oil and Gas Conservation Commission,** §**805(b). [18] CO Regulation 7, XII.D.1. See also CDPH&E Air** **Pollution Control Division, Oil and Gas Exploration & Production** **Regulation No. 7 Requirements, http://www.cdphe.state.co.us/ap/sbap/SBAPoilgastank** **guidance.pdf .** **[19] CO Regulation 7, XVII.C.1. [20] MT Admin. Rules** §**17.8.1711.**