EPA’s Reduced Emission Completion Rule. New Regulation on Hydraulic Fracturing.
John O’Malley, P.G.
Approach Resources, Inc.
On August 23, 2011, the Environmental Protection Agency proposed an unprecedented rule aimed at establishing new emission standards to reduce volatile organic compounds (VOCs) and sulfur dioxide emissions from certain newly-constructed equipment. The rule covers a number of sources in oil and gas production. After a lengthy review and more than 150,000 comments, the rule was finalized on April 17, 2012. For petroleum geologists, perhaps the most notable new requirement is for deploying special equipment to reduce emissions from newly hydraulically fractured gas wells by controlling produced gas during flow-back and sending it to a sales line or putting it to other beneficial use. This reduced emission completion (REC) rule will be phased in, finally becoming effective on January 1, 2015. During the phase-in period, a completion combustion device may be used to flare gas rather than completing an REC. In some circumstances, the REC requirement could add operational cost, delay completions and raise concern over potential penalties and administrative costs not previously associated with hydraulic fracturing. Among other topics of particular interest in this rule is the requirement for 95 % reduction of VOCs emitted from certain newly constructed or modified storage vessels. Vapor control would be required on tanks with relatively low potential to emit (6 tons per year), that would not otherwise trigger permitting thresholds. Questions remain about the practical aspects and economics of controlling vapor at low production levels and complying with extensive operational compliance requirements.
AAPG Search and Discovery Article #90152©2012 AAPG Southwest Section Meeting, Fort Worth, Texas, 19-22 May 2012