Final U.S. EPA and California Regulations to Reduce Methane Emissions from Oil & Natural Gas Sector Expected in 2016 - January 14, 2016
Paul Hastings LLP
Description
21
See id. § 7411(h) (permitting EPA to promulgate a work practice standard or other requirements, which reflects BSER,
when it is not feasible to enforce an emission standard).
22
Id. § 7411(b)(1)(B).
23
A wildcat well, also referred to as an exploratory well, is a well drilled outside known fields or are the first well drilled in
an oil or gas field where no other oil and gas production exists. 80 Fed.
Reg. at 56,611. 24 A delineation well is a well drilled to determine the boundary of a field or producing reservoir. Id. 25 Id.
at 56,630. 26 Id. at 56,632. 27 Id. at 56,637. 28 Id.
at 56,624. 29 Id. at 56,610; 56,624. 30 Id. at 56,627.
This option results in a 95 percent reduction of emissions for both methane and VOC. Id. 31 Id. 32 Id. at 56,622.
This BSER does not include use of reciprocating compressors located at well sites. Id. 33 Id. at 56,620. 34 Id.
at 56,644. 35 CARB, Proposed Regulation Order, Article 3: Greenhouse Gas Emission Standards for Crude Oil and Natural Gas Facilities (April 22, 2015 Draft), http://www.arb.ca.gov/cc/oil-gas/meetings/Draft_Regulatory_Language_4-22-15.pdf. 36 Tit. 17 Cal. Code Regs., § 95213(a) (April 22, 2015 Draft). 37 Id.
§ 95213(c). 38 Id. § 95213(b). 39 Id. § 95213(d), (e). 40 Id.
§ 95213(f). 41 Id. § 95213(g). 42 Id. § 95213(i)(2). 43 See 80 Fed.
Reg. at 56,644 (explaining EPA’s conclusion that it does not have sufficient information to propose a standard for liquids unloading). 44 Tit. 17 Cal.
Code Regs., § 95213(h) (April 22, 2015 Draft). In alternative, the volume of natural gas vented to remove the accumulated liquids can be measured by direct measurement or calculated and reported to CARB. Id. 45 Draft Short-Lived Climate Pollutant Reduction Strategy (September 2015), at 52.
As required by SB 1371 (2014), GHG emissions from oil and gas pipelines are being addressed in a proceeding before the California Public Utilities Commission. See CPUC R.15-01-008. 46 80 Fed. Reg.
at 56,598. 47 Proclamation of a State of Emergency, Edmund G. Brown, Jr., Governor of the State of California (January 6, 2016), https://www.gov.ca.gov/news.php?id=19264. 6 .
Reg. at 56,611. 24 A delineation well is a well drilled to determine the boundary of a field or producing reservoir. Id. 25 Id.
at 56,630. 26 Id. at 56,632. 27 Id. at 56,637. 28 Id.
at 56,624. 29 Id. at 56,610; 56,624. 30 Id. at 56,627.
This option results in a 95 percent reduction of emissions for both methane and VOC. Id. 31 Id. 32 Id. at 56,622.
This BSER does not include use of reciprocating compressors located at well sites. Id. 33 Id. at 56,620. 34 Id.
at 56,644. 35 CARB, Proposed Regulation Order, Article 3: Greenhouse Gas Emission Standards for Crude Oil and Natural Gas Facilities (April 22, 2015 Draft), http://www.arb.ca.gov/cc/oil-gas/meetings/Draft_Regulatory_Language_4-22-15.pdf. 36 Tit. 17 Cal. Code Regs., § 95213(a) (April 22, 2015 Draft). 37 Id.
§ 95213(c). 38 Id. § 95213(b). 39 Id. § 95213(d), (e). 40 Id.
§ 95213(f). 41 Id. § 95213(g). 42 Id. § 95213(i)(2). 43 See 80 Fed.
Reg. at 56,644 (explaining EPA’s conclusion that it does not have sufficient information to propose a standard for liquids unloading). 44 Tit. 17 Cal.
Code Regs., § 95213(h) (April 22, 2015 Draft). In alternative, the volume of natural gas vented to remove the accumulated liquids can be measured by direct measurement or calculated and reported to CARB. Id. 45 Draft Short-Lived Climate Pollutant Reduction Strategy (September 2015), at 52.
As required by SB 1371 (2014), GHG emissions from oil and gas pipelines are being addressed in a proceeding before the California Public Utilities Commission. See CPUC R.15-01-008. 46 80 Fed. Reg.
at 56,598. 47 Proclamation of a State of Emergency, Edmund G. Brown, Jr., Governor of the State of California (January 6, 2016), https://www.gov.ca.gov/news.php?id=19264. 6 .
