In December, the Pennsylvania Dept. of Environmental Protection (DEP) released a draft of onerous new regulations that focus on reducing volatile organic compound (VOC) emissions and so-called fugitive methane (see Pa. DEP Jumps the Gun with Proposed New Emissions Regs). The new regs will force drillers and pipeline companies to spend big bucks to produce a teeny tiny improvement in emissions. The DEP is back with yet another revision of their onerous new regs, hoping this time they can ram them through and make them law.
Here’s the thing that really rankles us: Most of PA’s conventional wells (80% or more) will be exempt from these new rules. And PA’s conventional wells reportedly account for more than 50% of supposed methane emissions. There are approximately 80,000 active conventional oil and gas wells in PA, and about 10,600 active shale gas wells in PA. So how are these rules in any sense “fair” to the shale industry?
The DEP has, for some time, considered requiring new regulations to further reduce volatile organic compound (VOC) emissions at existing oil and gas sites. The question is, since the federal EPA is “relaxing” the regulations on which these onerous new PA regulations are based, will PA, by adopting these new regulations, make itself uncompetitive against other shale drilling states? In a word, yes. But that’s not stopping the lefties in the Tom Wolf administration.
DEP’s Air Quality Technical Advisory Committee is holding a meeting on April 11th to “discuss” (i.e. ram through) these new regs.
The draft regulation to control volatile organic compound emissions, with a “co-benefit of reducing methane emissions, from existing oil and gas operations is now available on DEP’s Air Quality Technical Advisory Committee webpage.
They are to be discussed at an April 11 meeting of the Committee.
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 March 21 Air Quality Advisory Committee 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 previous Air Quality 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 2018 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 5 percent of natural gas production in the state, while 95 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.
The meeting will be held in Room 105 of the Rachel Carson Building starting at 9:15. There are no call-in options at this time.
For more information and available handouts, visit the DEP Air Quality Technical Advisory Committee webpage. Questions should be directed to Kirit Dalal, 717-772-3436 or send email to: [email protected]*
*PA Environment Digest Blog (Mar 29, 2019) – Draft Regulation Controlling VOC/Methane Emissions From Oil & Gas Operations Now Available, To Be On April 11 DEP Advisory Committee Agenda
Newest draft regulations, dated April 11:
ONG_PRN_Annex_A_AQTAC_4-11-2019
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Slide deck the DEP will use during the April 11 meeting to discuss the latest proposed regs:
AQTAC_Presentation_on_CTG_April_11th_Meeting
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