By way of update to last month's client alert, on April 15, 2014, EPA released five white papers that discuss methane and volatile organic compound (VOC) emissions from the oil and gas sector. The release of the white papers is part of the White House's Climate Action Plan Strategy to Reduce Methane Emissions.
The white papers cover emissions from five types of emission sources:
- Well completions and production from hydraulically fractured wells
- Liquids unloading
- Pneumatic devices
Each white paper includes an overview or definition of the source and brief summaries of studies that have been conducted to gather emissions data from that type of source. Rather than just relying on data or studies conducted by the government, the white papers also discuss studies conducted by industry. After summarizing this information, each white paper discusses potential mitigation techniques before posing numerous questions to solicit feedback.
Topics for which EPA is soliciting feedback include the estimated methane emissions from a given source type, insights regarding other methods to reduce methane emissions, additional studies that EPA should consider, and the benefits and drawbacks associated with using specific technologies. Notably, some of the data and techniques discussed in these papers were not covered in EPA's 2012 New Source Performance Standards for VOCs (NSPS OOOO).
EPA's request for feedback on the methane and VOC white papers can be contrasted with the rulemaking process the agency undertook when issuing Subpart W of the Greenhouse Gas Reporting Program (GHGRP). Subpart W is the portion of the GHGRP in which companies in the oil and gas sector annually report GHG emissions from sources with 25,000 metric tons or more of CO2-equivalent emissions per year. Subpart W was finalized in late 2010 and did not involve the release of any pre-rulemaking white papers. Over three years later, EPA is still engaged in efforts to fix problems with Subpart W. In fact, comments on the latest round of amendments to Subpart W are due on April 24. Thus, Subpart W serves as a prime example of why it is so important for EPA to ask questions first and ensure that it has gathered adequate information in advance of taking any regulatory action on methane emissions.
With that in mind, oil and gas companies that own and operate sources in the production, midstream processing, and transmission and storage sectors should capitalize on this opportunity to provide EPA with meaningful comments on these white papers. In particular, it is important for EPA to have a complete picture of all of the recent studies that have been conducted regarding methane emissions, the status of current operations, limitations on using certain technologies such as reduced emissions completions (RECs) on wells, and the bases for differing results from various studies. Comments on the white papers must be submitted by June 16, 2014.