Emission Standards for New and 

Modified Sources in the Oil and 

Natural Gas Sector

Interagency Review Introductory Briefing

June 26, 2015
Deliberative - Do Not Cite or Quote 

Overview

► Purpose of this Briefing

► Oil and Gas Sector Description

► Scope of Coverage – 2012 NSPS vs. 2015 Proposal

► Compressors

► Pneumatic Controllers

► Pneumatic Pumps

► Well Completions

► Fugitive Emissions

► Schedule

2
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Source: Adapted from American Gas Association and EPA Natural Gas STAR Program

Crude Oil to Refineries 

(not included in this source 

category)

Production & Processing

1. Drilling and Well Completion

2. Producing Wells

3. Gathering Lines

4. Gathering and Boosting Stations

5. Gas Processing Plant

3

1

2

4

5

6

7

8

10a

10b

10c

10d

9

Natural Gas 

Transmission & Storage

6. Transmission Compressor Stations

7. Transmission Pipeline

8. Underground Storage

Distribution

9. Distribution Mains

10. Regulators and Meters for:

a. City Gate

b. Large Volume Customers

c. Residential Customers

d. Commercial Customer

Natural gas systems encompass wells, gas gathering and 

processing facilities, storage, and transmission and distribution 

pipelines. 

Oil and Gas Sector Description

Natural gas distribution is currently out of the scope of the white 

papers and 2015 NSPS Proposed Rule
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Scope of Coverage – 2012 NSPS vs. 2015 Proposal

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Emission Source 2012 NSPS

(VOC)

2015 NSPS Proposal

(GHG/Methane and VOC)

Compressors through gas processing, 

excluding well site compressors

across the source category, excluding 

well site compressors

Pneumatic Controllers well sites through gas 

processing across the source category

Pneumatic Pumps not covered across the source category

Well Completions hydraulically fractured gas wells hydraulically fractured gas wells and 

hydraulically fractured oil wells

Equipment Leaks natural gas processing plants natural gas processing plants, well sites, 

and compressor stations

Liquids Unloading not covered not covered

Notes:

1

”Across the category” means the production, processing and transmission/storage segments.

2 We are not proposing any additional requirements for emission sources addressed under the 2012 NSPS. 
Deliberative - Do Not Cite or Quote 

► 2012 NSPS (VOC) covers compressors in gas production & 

processing segments; excludes well site compressors

► 2015 Proposal (methane and VOC): 

► Proposed requirements are the same as 2012 except for scope

► Centrifugal Compressors

• Wet seal – would require 95% control across source category

• Dry seal – would not be affected facilities (same as 2012)

► Reciprocating Compressors

• Would require rod packing replacement after 26,000 hours of operation or 

36 calendar months, or 

• Would allow alternative of routing emissions from the rod packing to a 

process through a closed vent system under negative pressure 

► Well site compressors would not be affected facilities (same as 2012)

Proposed Standards - Compressors

5
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► 2012 NSPS (VOC) covers pneumatic controllers in the 

production and processing segments

► 2015 Proposal (methane and VOC): 

► Proposed requirements are the same as 2012 except for scope

► At natural gas processing plants: 

• Requires a zero natural gas bleed rate

• Non-natural gas-driven controllers are not affected facilities (same as 

2012)

► Everywhere else in the category: 

• Requires continuous bleed, natural gas-driven pneumatic controllers 

to have a natural gas bleed rate limit of 6 standard cubic feet per hour 

(i.e., low-bleed)

• Low-bleed controllers are not affected facilities (same as 2012)

Proposed Standards - Pneumatic Controllers

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► Not covered in 2012 NSPS

► 2015 Proposal (methane and VOC): 

► At natural gas processing plants: 

• Would require emissions from natural gas-driven 

chemical/methanol pumps and diaphragm pumps to be zero

► Everywhere else in the category: 

• Would require emissions from natural gas-driven 

chemical/methanol pumps and diaphragm pumps be controlled 

by 95% if a control device is already available on site

► Non-natural gas-driven pumps (e.g., air, electric, solar) would 

not be affected facilities

Proposed Standards - Pneumatic Pumps

7
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► 2012 NSPS regulated VOC emissions from completion of 

hydraulically fractured or refractured gas wells

► 2015 proposed requirements for oil well completions are the 

same as for gas well completions in the 2012 NSPS 

► 2015 Proposal (methane and VOC): 

► Would exclude wells with a gas to oil ratio (GOR) less than 300 scf 

of gas per barrel of oil

► Would require reduced emissions completion (REC) in combination 

with a completion combustion device; or

► Would require only combustion in situations not meeting criteria for 

REC (and where flaring is not a hazard)

• Exploratory and delineation wells

• Low pressure wells

Proposed Standards - Well Completions

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► 2012 NSPS requires leak detection and repair at natural gas processing plants to 

control VOC emissions

► 2015 Proposal (methane and VOC): 

► Would cover new and modified well sites and compressor stations across the 

category

► “Fugitive emissions components” would include valves, connectors, open-ended 

lines, pressure relief devices, closed vent systems and thief hatches on tanks

► Would require fugitive emissions surveys be conducted with optical gas imaging 

(OGI) technology

► Would require repair of sources of fugitive emissions (i.e., leaks) found during those 

surveys

► Survey frequency: 

• Initial survey would be required within 30 days after startup of new facility

• Would require semiannual surveys initially

• Frequency would decrease to annual for sites that find fugitive emissions from fewer 

than 1% of their fugitive emission components during two consecutive surveys

• Frequency would increase to quarterly for sites that find fugitive emissions from 1% or 

more of their fugitive emission components during two consecutive surveys

• The 1% trigger also would be used to revert back to the previous frequency

► We are soliciting comment on exemptions for owners or operators already 

implementing a corporate-wide fugitive emissions monitoring plan

Proposed Standards - Fugitive Emissions

9
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Schedule

10

Milestones Dates

Small Business Advocacy Review In progress – complete July 2015

Interagency Review July 2015

Proposal Signature Summer 2015

Final Signature Spring 2016