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Methane Emissions: The Rules are Changing in the US

01.16.2015

Global climate change is one of the most highly debated topics in the environmental world today. There is overwhelming evidence that air pollutant emissions, specifically Greenhouse Gases (GHGs), are a contributing factor to the global climate shift that is currently being observed. GHGs are associated with the changing global climate due to their ability to absorb and retain thermal radiation from the sun. This absorbed thermal energy is held in the atmosphere creating a warming effect – also known as the "Greenhouse Effect". When the term GHG was first introduced, it was a common misconception that carbon dioxide (CO2) was the main pollutant of concern. However, it has now been proven that methane (CH4) and nitrous oxide (N2O) are far more effective at trapping thermal radiation from the sun when compared to carbon dioxide. According to the EPA's defined global warming potentials contained in Table A-1 of the 40 CFR Part 98, Subpart A; methane exhibits an absorption rate that is 25 times higher than carbon dioxide at absorbing and retaining thermal radiation from the sun. More dramatically, the EPA reports nitrous oxide properties as being 298 times higher than carbon dioxide at absorbing and retaining thermal radiation.

Methane's ability to retain such a vast amount of thermal energy compared to carbon dioxide makes it necessary to control its release into the atmosphere to curtail the global climate shift. In a press release issued by the Office of the Press Secretary for the White House; the Obama administration is going to be taking action in an effort to reduce methane emissions in the oil and gas sector. The goal of these efforts is to reduce methane emissions by 40-45% from the recorded 2012 levels by 2025. At this point, no official proposed rules or standards have been drafted. However, the plan outlined in the White House Press Release indicates that the new rules and standards will be released in the summer of 2015 with the final rules being adopted sometime in 2016.

"Reducing methane emissions is an important part of the picture as we work collaboratively with federal, state, local and industry partners to harness America's domestic energy potential while also tackling climate change." – Sally Jewell, Secretary of the Interior

It is anticipated that the new rules and standards will apply to new and modified upstream oil and gas activities. The Press Release emphasized that the goal of these new regulations will be to utilize technologies currently in use by the industry, industry practices, and efficient and accommodating regulatory methodologies to achieve the methane reduction goals while imposing minimal impact on the growing oil and gas industry.

The EPA, in addition to imposing new rules and standards, may work to modify the existing GHG reporting program (40 CFR Part 98, Subpart W) to include more sources within the oil and gas industry sector. There are motions to move forward with an increase in remote sensing technology requirements for the purposes of monitoring and quantifying GHG emissions.

The Obama administration has proposed $15,000,000 be allocated to the Department of Energy (DOE) to develop cost effective technologies for methane and natural gas leak detection in the nation's natural gas distribution systems. Furthermore, the DOE is to work on the development of new compressors that have significantly lower methane emission/leak rates, and modernize the natural gas infrastructure nationwide.

Without the proposed rules and standards, it is difficult to forecast what kinds of implications that these new rules and regulations will have on the upstream oil and gas sector. However, it can be reasonably anticipated that there will be an increase in the reporting requirements of methane, Volatile Organic Compounds (VOCs), and/or GHGs. In addition, these new regulations may require detailed emissions inventories to estimate methane, VOC, and/or GHG emissions for the purpose of determining the applicability of; control technology requirements, state or federal permits, and leak detection and repair (LDAR) programs.

"This [methane/VOC detecting infrared camera] technology has moved the ball farther and faster than any other technology that I am aware of with regards to air-quality improvement," - Kevin Cauble, TCEQ Air Quality Division

As the state and federal regulations continue to limit air pollution from the oil and gas industry, there is the possibility that there will be an increase in the enforcement and monitoring of the oil and gas sector by the state environmental agencies. This increase in enforcement can already be observed in the state of Texas, where the Texas Commission on Environmental Quality (TCEQ) has acquired infrared cameras designed to detect methane and VOCs. The TCEQ is currently utilizing helicopters outfitted with the new methane/VOC detecting infrared cameras to survey vast areas of land containing many production sites with the purpose of enforcing the new and stricter air quality control regulations.

The ever changing regulations surrounding air quality, pollution, and climate change will continue to affect the oil and gas industry as a whole. These new rules and standards will continue to build on the framework of existing air quality control regulations in an effort to minimize the environmental impacts associated with industry specific activities. The possible results of these new rules and standards may dictate that operators install control technologies, monitor/report emissions, acquire new state/federal permits, and/or implement leak detection and repair programs.

Article Cited From: http://goo.gl/iE73ZL

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