# Emission Standards for New and 

# Modified Sources in the Oil and Natural Gas Sector
Interagency Review Introductory Briefing

June 26, 2015Deliberative - Do Not Cite or Quote 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

2Deliberative - Do Not Cite or Quote Source: Adapted from American Gas Association and EPA Natural Gas STAR Program Crude Oil to Refineries (not included in this source category)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Natural gas distribution is currently out of the scope of the white papers and 2015 NSPS Proposed RuleDeliberative - Do Not Cite or Quote 

# Scope of Coverage – 2012 NSPS vs. 2015 Proposal

4 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2 We are not proposing any additional requirements for emission sources addressed under the 2012 NSPS.Deliberative - Do Not Cite or Quote 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

5Deliberative - Do Not Cite or Quote 

### ► 

## 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

6Deliberative - Do Not Cite or Quote 

### ► 

## 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

7Deliberative - Do Not Cite or Quote 

### ► 

## 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

8Deliberative - Do Not Cite or Quote ► 

### 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

9Deliberative - Do Not Cite or Quote 

# 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