Oil and gas emiss

reductions strate

EPA Public Meeting on Air Reg

for the Oil and Gas 

Elizabeth Paranhos, 

Attorney and consultant, on behalf of

EDF and Wyoming Outdoor Council

August 3, 2010
Natural gas is a cleaner 

alternative to coal• The smart use of natural gas for electricity gencan be a critical part of an overall strategy to redpollution from our electricity sector, as it is a far cburning resource than coal-fired generation. • As natural gas is increasingly utilized as a cleaburning alternative, it is imperative that we ensurproper techniques are used to reduce emissions stages of natural gas development, from exploraproduction through distribution. 
Activities in the natural gas exploration and 

production (“E&P”), storage, processing, transmission and distribution sectors and in 

E&P sectors emit substantial amounts of 

– ozone precursors (VOCs and Nox)– methane (CH4)– and hazardous air pollutants (HAPs).

Oil and gas emissions
2006 VOC and NOx emissions and projected 20

emissions for key oil and gas producing basin

Intermountain West and Gulf region.
Oil and gas methane 

emissions• Third largest source of U.S. methane 

emissions 

• At least 125.5 million metric tons of CO

equivalent (“MmtCO2e”) in 2008 

– Equal to the emissions of 33 coal-fire

power plants

1

• The number is likely much larger as 

emissions underreporting is well documby EPA.

2
Barnett Shale 2009 HAP 

Emissions

Source Tons per D

HAPs

Compressor engine exhaust 3.6 Condensate and oil tanks .60Production Fugitives .62Well drilling and completions .49Gas Processing .37Transmission Fugitives .67
Health effects and 

environmental impacts• Airborne contaminants emitted from oi

gas activities contribute to pollution associated with serious human health and adverse environmental consequenincluding ground-level ozone or “smogparticulate pollution, toxic air pollution, climate-disrupting pollution, and the haobscures scenic vistas in national parkwilderness areas.
Cost-effective technolo

are available • EPA estimates that as much as 300 billio

feet of natural gas (methane) is lost each 

• This equals over $1 billion in lost profits.

3

• Oil and gas companies have saved over 

million through implementing voluntary mair pollution reduction technologies.

4

• Broad adoption of these technologies cou

reduce emissions by approximately 41 MCO2e.

5
Examples of cost-effective 

pollution reduction measu• low or no bleed pneumatic devices;• green or reduced emissions completions and recompletio• still vent condensers and glycol flash separators or other 

technologies that reduce vented emissions from glycol deby 98% or better;

• vapor recovery units or other equipment that reduced emi

from crude oil, condensate and produced water tanks by 9better; 

• leak detection and repair for production fugitives;• plunger lifts and “smart” well automation systems for well • BASO valves on heater-treaters, gas dehydrators and gas • leak detection and repair at compressor stations; • replacement of compressor rod packing;• dry seals for centrifugal compressors;
State actions

A number of western states, includin

Colorado, have implemented or proto implement cost-effective pollution control measures.
CO and WY regulations 

pneumatic devices• Colorado

– All new, replaced or repaired pneumatic devices at 

facilities must be low or no-bleed.

6

– All pneumatic controllers at E&P sites, upstream na

compressor stations, natural gas drip stations and gprocessing plants located in an ozone nonattainmenattainment/maintenance areas must have VOC emiequal to or less than a low-bleed controller. 

7

• Wyoming

– All new pneumatic controllers and existing pneumat

controllers at a modified facility must be low or no-broute discharge streams to a closed loop system.

8
CO, WY, MT regulations 

well completions• Colorado

– Colorado requires the use of green completions o

and gas production wells unless not technically aeconomically feasible.

9

• Wyoming

– Requires green completions in the Jonah-Pineda

Anticline Development Area (“JPAD”).

– Has recently expanded this requirement to all are

concentrated oil and gas development (“CDA”s).10

• Montana

– VOC vapors greater than 200 Btu per cubic foot f

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 

dehydrators• CO

– Must control by 90% actual, uncontrolled VOC emis

15 tpy or more from vents on glycol dehydrators locoil and gas E&P operations, natural gas compressodrip stations or gas processing plants.12

– Operators within a one-quarter mile of a public plac

Garfield, Mesa and Rio Blanco counties in the Piceamust control emissions of VOCs by 90% from all dewith a potential to emit 5 tpy VOCs.13

• WY

– Control of HAPs and VOCs by at least 98% at all ne

existing dehydration units operating in the JPAD.14

– All new and existing dehydrators in CDAs and state

control HAPs and VOCs by 98% upon FDOP.15
CO, WY and MT regulat

for tanks• Colorado

– Control of VOC emissions by 95% from condensate, crude oil and p

water tanks with PTE 5 tpy of VOCs located within one-quarter mile place in Garfield, Mesa and Rio Blanco counties in the Piceance ba

– Owners or operators of condensate tanks whose cumulative actual 

VOC emissions are > 30 tpy located at exploration and production s

ozone NA/ NA/M areas must meet declining emissions reductions o

– Statewide, new and existing condensate tanks that emit > 20 tpy of 

control emissions by 95%. 19

• Wyoming

– VOC emissions from condensate, oil and produced water tanks loca

modified facilities in the JPAD and CDAs must control flash emissioFDOP.

– Statewide, new and modified facilities must control VOC flash emiss

by 98% upon FDOP.16 

• Montana

– VOC vapors greater than 200 Btu per cubic foot from 

wellhead equipment with the potential to emit 15 tpy or greater must be routed to a capture or control device.20
CA Climate Change 

Scoping Plan• Proposes to address fugitive emis

from on- and off-shore sources.

• Fugitive emissions are primarily fr

well and process equipment ventin

• Proposed controls range from LDA

low or no-bleed pneumatic devicereplacement of compressor rod packing. 
Opportunity

An immense opportunity exists 

implement cost-effective clean a

measures that apply to a broad ra

of sources and pollutants. 
Citations

[1] Calculated using EPA’s GHG Equivalencies Calculator, http://www.epa.gov/RDEE/energyresources/calculator.html#results. [2] EPA Technical Support Document for the proposed GHG Mandatory Reporting Rule, p. 23. 

[3] Nathanial Gronewold, Greenwire, “Industry Spotlighting Efforts to Curb Fugitive Emissions”, May 1

[4] U.S. EPA, Natural Gas STAR Program, available at http://www.epa.gov/gasstar/. [5] U.S. EPA, Natural Gas STAR Program, available at http://www.epa.gov/gasstar/. Based on a thirty 

from 2008 emission levels. 

[6] CO Regulation 7, XVIIIColorado Oil and Gas Conservation Commission rule 805(b)(2)(E). [7] CO Regulation 7, XVIII.C. Upstream means upstream of natural gas processing plants. [8] Wyoming Oil and Gas Production Facilities, Chapter 6, Section 2 Permitting Guidance (March 201

March 2010 Guidance”). 

[9] Final Rule, Colorado Oil and Gas Conservation Commission, 

§ 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 facilities that have the potentia

a regulated air pollutant, including HAPs. Oil and gas facilities include wells and associated e

produce, treat, separate or store oil, natural gas, or other liquids produced by the well. MT An

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 equipped with reboiler still vent condensers and glycol f

, after 30 days, potential VOCs > 8 tpy, units must install combustion control capable of reduc

98%. After one year, combustion units may be removed if total potential VOC emissions < 8 t

[16] Note that the emission threshold for the application of this requirement differs depending on an in

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 Explorat

Regulation No. 7 Requirements, http://www.cdphe.state.co.us/ap/sbap/SBAPoilgastankguidan

[19] CO Regulation 7, XVII.C.1.[20] MT Admin. Rules 

§ 17.8.1711.