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Multiple Regulations, One Emission Source: Well Completions

The attention surrounding the oil gas industry’s impact to air quality has received local, state and federal attention for years. However more recently, the US EPA has finalized new regulations under the Clean Air Act (CAA) to curb the increasing trend of emissions from the industry. Historically allowed to operate outside of the attention the refining industry received under the CAA Amendments in 1990, the upstream industry is now center stage for both state and federal regulations working to limit emissions. Fast forward to 2007 where the Supreme Court granted the US EPA authority to regulate GHG pollutants resulting in a significant compliance obligation for the entire oil and gas industry, including the upstream segment. This regulation was titled the Greenhouse Gas (GHG) Mandatory Reporting Rule (MRR).

Under the MRR, the oil gas industry known as Subpart W included reporting requirements for a variety of emission sources across all segments of the industry. For the upstream segment, well completions were an affected source. Reporting requirements for the completions category evolved over each final rule revisions since 2010, but completions continued to receive further regulation.

On May 12, 2016, the US EPA issued final New Source Performance Standards (NSPS) for oil well sites and completions, also known as OOOOa. The NSPS OOOOa was predated by the original NSPS OOOO in 2012 that covered specific emission sources in the oil gas arena. NSPS OOOO included completions associated with gas wells, but once NSPS OOOOa was promulgated, oil completions were also subject to the regulation.

While well completions requirements subject to reporting under the GHG MRR and NSPS OOOO/OOOOa are different, the rules have considerable overlap that is important to understand and evaluate for your operation.

For both NSPS OOOOa and GHG MRR, the flowback period begins when the flowback is routed to open pits or tanks when the material introduced into the well during the treatment returns to the surface following hydraulic fracturing or refracturing. This time period is logged and is used to calculate emissions under GHG MRR. The subsequent period when gas content is sufficient to route the flowback to the separator or when the gas is sufficient to allow measurement by the certain devices is monitored hourly under NSPS OOOOa for the disposition of gas, while only quantity of gas is monitored under GHG MRR. Under both NSPS OOOOa and GHG MRR, the completion event ends when the well is disconnected from the flowback equipment or at the startup of production.

The biggest difference is that NSPS OOOOa requires all hours of disposition from the initial flowback stage to be tracked along with all hours of the separation flowback stage. The reporting requirements for GHG MRR only require hours of disposition for the initial flowback stage; any hours following this initial flowback stage are only tracked for the quantity of gas.

Final Rule
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