Beyond the Headlines
Emissions are in the air and in the headlines every day. Whether the discussion is on human health impacts of pollution, greenhouse gas (GHG) emissions and their impact on climate change, or the misleading performance of a diesel engine, the bottom line is there is a global focus on emissions.
Emission discussions are also in the forefront of the oil and gas industry. In 2012, the US Environmental Protection Agency (EPA) mandated new emission rules for our industry dealing with volatile organic hydrocarbons (VOCs), hazardous air pollutants (HAPs), and, most recently, methane. On 18 August, the agency proposed additional measures (EPA 2015) that supplement the earlier regulations and that “together will help combat climate change, reduce air pollution that harms public health, and provide greater certainty about Clean Air Act permitting requirements for the oil and natural gas industry.”
The rules have set limits on emissions. If they cannot be captured, the emissions must be combusted at a 95% destruction efficiency at a minimum. Destruction efficiency is not as extensive a measure of performance as combustion efficiency; however, the move to performance-based legislation is a positive one and will most certainly lead to improved air quality and a healthier relationship with communities in close proximity to oil and gas development. Within the US, various states have or are in the process of enacting legislation specific to their local situation, on the proviso that their requirements are not weaker than the federal rules.
In Colorado, for example, much of the industry activity occurs in the vicinity of communities. The state regulator is moving toward mandating de vices that not only combust efficiently, but also fully enclose the combustion to eliminate the visibility of the flare. It is also spot inspecting facilities with special cameras that detect uncombusted hydrocarbons, which are a clear indicator of poor performance. Companies that are emitting uncombusted hydrocarbons will be subject to considerable fines.
North Dakota has put a rule in place that the industry must find an acceptable method of using a significant, measurable portion of a well’s associated gas, or oil production from that well will be capped.
There are other situations in which the new EPA requirements, combined with state rules, will result in improved operations.
The existing 2012 EPA legislation covered natural gas wellsites, production gathering and boosting stations, natural gas processing plants, and natural gas compressor stations. The proposed EPA legislation requires the reductions of methane and VOC emissions from hydraulically fractured oil wells and extends the emission reduction targets downstream covering equipment in the natural gas transmission segment.
In view of this regulation, two questions are central to the emissions issue.
1. Is there a technology that can deliver results cost-effectively and address the community concerns about emissions?
2. Is it possible to comply with the new rules in the current low oil and natural gas price environment?
