On March 21, DEP’s Oil and Gas Technical Advisory Board is scheduled to meet to discuss draft proposed RACT regulations covering volatile organic compound emissions with a “co-benefit” of reducing methane emissions from existing oil and gas operations.

In December, DEP discussed its proposed approach to the regulation with the Air Quality Technical Advisory Committee outlining many of the same points it plans to make in the March 21 presentation.

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 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 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.          

Marcellus Shale Coalition President David Spigelmyer issued a statement in December 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.”

No draft of the regulations has yet been posted as a handout for the meeting.  Click Here for November 2018 draft.  [Note: The draft proposed regulation language will be an action item at the April 11 Air Quality Technical Advisory Committee meeting and will be posted about 2 weeks prior to the meeting-- on or about March 28.]

The meeting will be held in Room 105 of the Rachel Carson Building starting at 10:00.  Click Here to register to join the meeting via Skype.

For more information, visit the DEP Oil and Gas Technical Advisory Board webpage.  Questions should be directed to Todd Wallace, 717-783-9438,  twallace@pa.gov.

(Photo: How Reducing Methane Emissions Creates Jobs, Environmental Defense Fund.)

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3/18/2019