On December 13, DEP’s Air Quality Technical Advisory Committee discussed a draft regulation outline to set limits on volatile organic compound emissions-- with the “co-benefit” of reducing methane emissions-- from existing gas well sites, pumps, storage and other equipment at oil and gas facilities.
The approach used in the regulation is based on a federal Control Technique Guideline for oil and gas facilities which will be used to develop a RACT standard. RACT is defined as the lowest emission limitation that a particular source is capable of meeting with economically feasible, reasonably available emissions control technology.
DEP acknowledged at the meeting EPA is now considering changes to its CTG requirement, but said they intend to move ahead with a proposed rule in any event because of regional commitments to meet federal ozone standards.
While the draft regulation technically proposes to regulate VOC emissions, these controls will in turn reduce methane emissions because both volatile organic compounds and methane are found in many oil and gas operations.
Generally, the draft regulation outline calls for a 95 percent reduction in VOC emissions, however, some equipment-specific requirements call for less or more. For example, natural gas processing plants are required to have zero VOC emissions.
At the meeting, DEP said the regulation, as drafted, would exempt the “lion’s share” of conventional oil and gas wells (perhaps 80 percent or more) and roughly 6 percent of unconventional gas wells in Pennsylvania from the leak detection and repair requirements due to the threshold emission limits.
These estimates are rough because DEP staff said they have not yet done firm calculations to estimate how many wells may be exempt.
There are now about 80,000 conventional oil and gas wells and about 10,651 active unconventional gas wells in Pennsylvania.
A report by the Environmental Defense Fund in February of this year on methane emissions from oil and gas wells in Pennsylvania found about 50 percent of those emissions come from conventional oil and gas wells (268,900 tons) and about 50 percent from unconventional gas wells (253,500 tons).
The higher conventional gas well methane emissions cannot be accounted for by natural gas production.
In fact, conventional gas wells account for only about 2 percent of natural gas production in the state, while 98 percent of the production comes from unconventional (shale) gas wells.
Another difference in the way conventional gas wells are treated is in reporting methane emissions. Conventional oil and gas wells are not required to report their methane emissions to DEP, while unconventional wells are, even though they make up about half the methane emissions.
Marcellus Shale Coalition President David Spigelmyer issued a statement about the draft regulation saying, “While we’re still reviewing the proposal, we do have initial concerns about potential costs as well as DEP’s timing given ongoing federal regulatory activity associated with existing source emissions.
“That said, Pennsylvania’s continued success in enhancing air quality, as reflected by DEP’s own data, is occurring alongside and largely due to the Commonwealth’s leading natural gas production position. Again, rather than creating more regulatory uncertainty, it would be prudent for DEP to delay any regulatory proposals until federal rules are finalized.”
DEP said after it reviewed the initial comments on the draft regulation by Committee members and the public at the meeting, it would provide a more final version of the regulation to the Committee for review. There was no firm timetable for when that might happen.
Click Here for a PowerPoint presentation on the proposal. Click Here for a very draft regulation.
For more information and available handouts, visit DEP’s Air Quality Technical Advisory Committee webpage. Questions should be directed to Kirit Dalal by calling 717-772-3436 or send email to: kdalal@pa.gov.
(Photo: How Reducing Methane Emissions Creates Jobs, Environmental Defense Fund.)
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