American Oil and Gas Reporter - June 2012 - 24

Natural Gas NSPS

EPA ‘Fracturing’ Rule Casts Wide Net
By Georgette Reeves ALBUQUERQUE, N.M.–On April 17, the U.S. Environmental Protection Agency finalized a host of air quality regulations relating to the oil and gas industry. While many in the press have heralded the rules as “fracking regulations,” their scope reaches far beyond that of hydraulic fracturing at natural gas wellheads. While it is true that these regulations cover emissions resulting from hydraulic fracturing at gas wells, they also include any new, modified, or reconstructed sources as follows: • Centrifugal compressors using wet seals; • Each reciprocating compressor; • Each continuous-bleed, natural gas-driven pneumatic controller; • Each storage vessel; • Groups of equipment (pumps, pressure relief devices, open-ended valves or lines, valves, and flanges or other connectors in volatile organic compound or wet gas service), within a process unit located at onshore natural gas processing plants; and • Sweetening units located at onshore natural gas processing plants. These new regulations will impact the upstream oil and gas production, midstream, processing and transmission industries substantially. They also will set standards for some activities that traditionally have not been regulated as emission sources. Background The final action has been four years in the making, and comes as a result of EPA’s initial review of four rules and subsequent legal action by environmental advocacy groups. After a 2008 review of two new source performance standards and two air toxics rules that affected the oil and gas industry, EPA did not modify any of the existing standards. The original air quality rules (implemented in 1985) provided standards only for emissions from natural gas processing facilities. The Clean Air Act requires EPA to evaluate the need for additional performance standards for new, modified or reconstructed sources every eight years. EPA performed the review required for the oil and gas industry in 2008, but did not modify any standards. In 2009, Earthjustice, along with en24 THE AMERICAN OIL & GAS REPORTER

vironmental advocacy groups Wildearth Guardians and the San Juan Citizens Alliance, sued the EPA for failing to update national air quality regulations relating to the oil and gas sector. The lawsuit found its way through the courts, and the environmental groups ultimately won their claim. This resulted in a judicial consent decree that mandated EPA finalize new standards for segments of the oil and gas industry by April 17, 2012. After EPA’s further review, new source performance standards (NSPS) at Subpart OOOO, and updates to several other maximum achievable control technology and national emission standards for hazardous air pollutants regulations, were proposed. Despite receiving more than 156,000 written comments on the proposed rules, EPA met the deadline (admittedly, after several short extensions), and finalized standards for the oil and gas industry. Key Definitions EPA has been forthcoming in admitting that it is regulating an industry about which it has limited understanding. As such, operators must look closely at definitions in this and related regulations. EPA’s definition of a commonly understood industry practice may not be in line with what operators expect. Among definitions likely to be hotly debated is what constitutes “modified” and “reconstructed” facilities. All newly constructed facilities will be affected by these rules. Existing facilities will be affected only if they are subsequently modified or reconstructed. Similar to previous standards, this rule applies only to sources that are constructed, modified, or reconstructed after a certain date. While the concept of what constitutes a “constructed” facility is relatively straightforward for most activities, this rule will bring in activities and equipment that have not previously been subject to regulation, and for which the definition of modification or reconstruction may be questionable. Interpreting these definitions (found in 40 CFR 60.2, 60.14 and 60.15) will play an important role in deciding what activities performed at affected sources will trigger additional requirements. While the definition of a modification may be straightforward and well defined in traditional regulatory practice (such

as what constitutes a modified or reconstructed compressor), how it applies to some sources covered in this regulation may be more difficult to determine (particularly activities or maintenance related to storage vessels or pneumatic controllers). One thing that remains clear is that an increase in production by itself should not be considered a modification. During any facility expansion, each piece of equipment that is not modified physically should be looked at independently of other associated equipment to determine the applicability of the new rules. What constitutes a gas well has been a burning question for some time, and the EPA has kept industry on its toes by leaving this area open for interpretation. In the preamble of the NSPS rule, the agency specifically clarifies that “the final rule will not affect drilling of oil wells.” However, the definition of a gas well is vague and does not clearly track with the definition of a gas well under other regulatory programs. For example, in EPA’s greenhouse gas reporting rule, Subpart W, the definition of a gas well is quite different. In fact, by most accounts it seems operators may be reporting hydraulic fracturing at more wells under the greenhouse gas program than could be required under the new NSPS OOOO. Unlike the proposed regulation, which would have required compliance as of the date the proposed rule was released (Aug. 21, 2011), the finalized version provides operators with a series of compliance dates that depend on the sector and the source subject to the regulation. For some sources, the new rules could be enforced as early as this summer. Others may not be required to comply until Jan. 1, 2015. Wells And Controllers Starting 60 days following the rule’s publication in the Federal Register (expected to be sometime in late May), this rule will require operators to flare flowback emissions during hydraulic fracturing at gas wellheads, unless more stringent state requirements already are in place (for example, Colorado and Wyoming already require the use of green completion technologies). Operators performing hydraulic fracturing at gas wellheads commencing after Jan. 1, 2015, must employ “green completions



Table of Contents for the Digital Edition of American Oil and Gas Reporter - June 2012

American Oil and Gas Reporter - June 2012
Contents
Reports
Calendar
Oil & Gas Counts
State Legislative
Industry Digest
Natural Gas NSPS Affects a Variety of Equipment
Federal Legislation
SPCC
EPA
Keystone XL
Tech Connections
Washington Watch
Anadarko Finds World-Class Reservoirs in Deepwater Mozambique
Variety of Projects Have Permian Basin Hopping
Infrastructure Bottlenecks Easing in Permian Region
Completion Design Optimizes Yeso-San Andres Oil Wells
Cover Story
Beaver Creek CO2 Flood Boosts Madison Production
Study Evaluates Low-Salinity Waterfloods
Variable Speed Drives Coming of Age
Activity Spurring Artificial Lift Innovations
Project Shows STMZ’s Viability for Lower Tertiary Completions
ICDs, Modeling Improve Horizontal Shelf Well Completion
Intelligent Gas Lift Maximizes Production, Recovery
KOGA
CIPA
TOGA
TAEP
Frac Rules
Marcellus Regs
Conventions
The American Well Servicing Directory, Summer 2012
Industry Focus
Classified Advertising
Advertisers Index
American Oil and Gas Reporter - June 2012 - American Oil and Gas Reporter - June 2012
American Oil and Gas Reporter - June 2012 - Cover2
American Oil and Gas Reporter - June 2012 - Contents
American Oil and Gas Reporter - June 2012 - Reports
American Oil and Gas Reporter - June 2012 - 5
American Oil and Gas Reporter - June 2012 - 6
American Oil and Gas Reporter - June 2012 - 7
American Oil and Gas Reporter - June 2012 - Calendar
American Oil and Gas Reporter - June 2012 - 9
American Oil and Gas Reporter - June 2012 - 10
American Oil and Gas Reporter - June 2012 - 11
American Oil and Gas Reporter - June 2012 - 12
American Oil and Gas Reporter - June 2012 - 13
American Oil and Gas Reporter - June 2012 - Oil & Gas Counts
American Oil and Gas Reporter - June 2012 - 15
American Oil and Gas Reporter - June 2012 - Industry Digest
American Oil and Gas Reporter - June 2012 - 17
American Oil and Gas Reporter - June 2012 - 18
American Oil and Gas Reporter - June 2012 - 19
American Oil and Gas Reporter - June 2012 - 20
American Oil and Gas Reporter - June 2012 - 21
American Oil and Gas Reporter - June 2012 - 22
American Oil and Gas Reporter - June 2012 - 23
American Oil and Gas Reporter - June 2012 - Natural Gas NSPS Affects a Variety of Equipment
American Oil and Gas Reporter - June 2012 - 25
American Oil and Gas Reporter - June 2012 - 26
American Oil and Gas Reporter - June 2012 - 27
American Oil and Gas Reporter - June 2012 - Federal Legislation
American Oil and Gas Reporter - June 2012 - 29
American Oil and Gas Reporter - June 2012 - 30
American Oil and Gas Reporter - June 2012 - 31
American Oil and Gas Reporter - June 2012 - SPCC
American Oil and Gas Reporter - June 2012 - 33
American Oil and Gas Reporter - June 2012 - Keystone XL
American Oil and Gas Reporter - June 2012 - 35
American Oil and Gas Reporter - June 2012 - 36
American Oil and Gas Reporter - June 2012 - Tech Connections
American Oil and Gas Reporter - June 2012 - 38
American Oil and Gas Reporter - June 2012 - Washington Watch
American Oil and Gas Reporter - June 2012 - Anadarko Finds World-Class Reservoirs in Deepwater Mozambique
American Oil and Gas Reporter - June 2012 - 41
American Oil and Gas Reporter - June 2012 - 42
American Oil and Gas Reporter - June 2012 - 43
American Oil and Gas Reporter - June 2012 - 44
American Oil and Gas Reporter - June 2012 - 45
American Oil and Gas Reporter - June 2012 - 46
American Oil and Gas Reporter - June 2012 - 47
American Oil and Gas Reporter - June 2012 - 48
American Oil and Gas Reporter - June 2012 - 49
American Oil and Gas Reporter - June 2012 - Variety of Projects Have Permian Basin Hopping
American Oil and Gas Reporter - June 2012 - 51
American Oil and Gas Reporter - June 2012 - 52
American Oil and Gas Reporter - June 2012 - 53
American Oil and Gas Reporter - June 2012 - 54
American Oil and Gas Reporter - June 2012 - 55
American Oil and Gas Reporter - June 2012 - 56
American Oil and Gas Reporter - June 2012 - 57
American Oil and Gas Reporter - June 2012 - 58
American Oil and Gas Reporter - June 2012 - 59
American Oil and Gas Reporter - June 2012 - 60
American Oil and Gas Reporter - June 2012 - 61
American Oil and Gas Reporter - June 2012 - 62
American Oil and Gas Reporter - June 2012 - 63
American Oil and Gas Reporter - June 2012 - Infrastructure Bottlenecks Easing in Permian Region
American Oil and Gas Reporter - June 2012 - 65
American Oil and Gas Reporter - June 2012 - 66
American Oil and Gas Reporter - June 2012 - 67
American Oil and Gas Reporter - June 2012 - 68
American Oil and Gas Reporter - June 2012 - 69
American Oil and Gas Reporter - June 2012 - 70
American Oil and Gas Reporter - June 2012 - 71
American Oil and Gas Reporter - June 2012 - Completion Design Optimizes Yeso-San Andres Oil Wells
American Oil and Gas Reporter - June 2012 - 73
American Oil and Gas Reporter - June 2012 - 74
American Oil and Gas Reporter - June 2012 - 75
American Oil and Gas Reporter - June 2012 - 76
American Oil and Gas Reporter - June 2012 - 77
American Oil and Gas Reporter - June 2012 - 78
American Oil and Gas Reporter - June 2012 - 79
American Oil and Gas Reporter - June 2012 - 80
American Oil and Gas Reporter - June 2012 - 81
American Oil and Gas Reporter - June 2012 - Cover Story
American Oil and Gas Reporter - June 2012 - 83
American Oil and Gas Reporter - June 2012 - 84
American Oil and Gas Reporter - June 2012 - 85
American Oil and Gas Reporter - June 2012 - 86
American Oil and Gas Reporter - June 2012 - 87
American Oil and Gas Reporter - June 2012 - 88
American Oil and Gas Reporter - June 2012 - 89
American Oil and Gas Reporter - June 2012 - 90
American Oil and Gas Reporter - June 2012 - 91
American Oil and Gas Reporter - June 2012 - Beaver Creek CO2 Flood Boosts Madison Production
American Oil and Gas Reporter - June 2012 - 93
American Oil and Gas Reporter - June 2012 - 94
American Oil and Gas Reporter - June 2012 - 95
American Oil and Gas Reporter - June 2012 - 96
American Oil and Gas Reporter - June 2012 - 97
American Oil and Gas Reporter - June 2012 - 98
American Oil and Gas Reporter - June 2012 - 99
American Oil and Gas Reporter - June 2012 - Study Evaluates Low-Salinity Waterfloods
American Oil and Gas Reporter - June 2012 - 101
American Oil and Gas Reporter - June 2012 - 102
American Oil and Gas Reporter - June 2012 - 103
American Oil and Gas Reporter - June 2012 - Variable Speed Drives Coming of Age
American Oil and Gas Reporter - June 2012 - 105
American Oil and Gas Reporter - June 2012 - 106
American Oil and Gas Reporter - June 2012 - 107
American Oil and Gas Reporter - June 2012 - Activity Spurring Artificial Lift Innovations
American Oil and Gas Reporter - June 2012 - 109
American Oil and Gas Reporter - June 2012 - 110
American Oil and Gas Reporter - June 2012 - 111
American Oil and Gas Reporter - June 2012 - 112
American Oil and Gas Reporter - June 2012 - 113
American Oil and Gas Reporter - June 2012 - 114
American Oil and Gas Reporter - June 2012 - 115
American Oil and Gas Reporter - June 2012 - 116
American Oil and Gas Reporter - June 2012 - 117
American Oil and Gas Reporter - June 2012 - Project Shows STMZ’s Viability for Lower Tertiary Completions
American Oil and Gas Reporter - June 2012 - 119
American Oil and Gas Reporter - June 2012 - 120
American Oil and Gas Reporter - June 2012 - 121
American Oil and Gas Reporter - June 2012 - 122
American Oil and Gas Reporter - June 2012 - 123
American Oil and Gas Reporter - June 2012 - 124
American Oil and Gas Reporter - June 2012 - 125
American Oil and Gas Reporter - June 2012 - 126
American Oil and Gas Reporter - June 2012 - 127
American Oil and Gas Reporter - June 2012 - 128
American Oil and Gas Reporter - June 2012 - 129
American Oil and Gas Reporter - June 2012 - 130
American Oil and Gas Reporter - June 2012 - ICDs, Modeling Improve Horizontal Shelf Well Completion
American Oil and Gas Reporter - June 2012 - 132
American Oil and Gas Reporter - June 2012 - 133
American Oil and Gas Reporter - June 2012 - 134
American Oil and Gas Reporter - June 2012 - 135
American Oil and Gas Reporter - June 2012 - 136
American Oil and Gas Reporter - June 2012 - 137
American Oil and Gas Reporter - June 2012 - 138
American Oil and Gas Reporter - June 2012 - 139
American Oil and Gas Reporter - June 2012 - 140
American Oil and Gas Reporter - June 2012 - Intelligent Gas Lift Maximizes Production, Recovery
American Oil and Gas Reporter - June 2012 - 142
American Oil and Gas Reporter - June 2012 - 143
American Oil and Gas Reporter - June 2012 - 144
American Oil and Gas Reporter - June 2012 - 145
American Oil and Gas Reporter - June 2012 - 146
American Oil and Gas Reporter - June 2012 - 147
American Oil and Gas Reporter - June 2012 - 148
American Oil and Gas Reporter - June 2012 - KOGA
American Oil and Gas Reporter - June 2012 - 150
American Oil and Gas Reporter - June 2012 - 151
American Oil and Gas Reporter - June 2012 - CIPA
American Oil and Gas Reporter - June 2012 - 153
American Oil and Gas Reporter - June 2012 - 154
American Oil and Gas Reporter - June 2012 - 155
American Oil and Gas Reporter - June 2012 - TOGA
American Oil and Gas Reporter - June 2012 - 157
American Oil and Gas Reporter - June 2012 - 158
American Oil and Gas Reporter - June 2012 - 159
American Oil and Gas Reporter - June 2012 - 160
American Oil and Gas Reporter - June 2012 - 161
American Oil and Gas Reporter - June 2012 - 162
American Oil and Gas Reporter - June 2012 - 163
American Oil and Gas Reporter - June 2012 - TAEP
American Oil and Gas Reporter - June 2012 - 165
American Oil and Gas Reporter - June 2012 - 166
American Oil and Gas Reporter - June 2012 - 167
American Oil and Gas Reporter - June 2012 - 168
American Oil and Gas Reporter - June 2012 - 169
American Oil and Gas Reporter - June 2012 - 170
American Oil and Gas Reporter - June 2012 - Frac Rules
American Oil and Gas Reporter - June 2012 - Marcellus Regs
American Oil and Gas Reporter - June 2012 - 173
American Oil and Gas Reporter - June 2012 - Conventions
American Oil and Gas Reporter - June 2012 - The American Well Servicing Directory, Summer 2012
American Oil and Gas Reporter - June 2012 - 176
American Oil and Gas Reporter - June 2012 - 177
American Oil and Gas Reporter - June 2012 - 178
American Oil and Gas Reporter - June 2012 - 179
American Oil and Gas Reporter - June 2012 - 180
American Oil and Gas Reporter - June 2012 - 181
American Oil and Gas Reporter - June 2012 - 182
American Oil and Gas Reporter - June 2012 - 183
American Oil and Gas Reporter - June 2012 - 184
American Oil and Gas Reporter - June 2012 - 185
American Oil and Gas Reporter - June 2012 - 186
American Oil and Gas Reporter - June 2012 - 187
American Oil and Gas Reporter - June 2012 - 188
American Oil and Gas Reporter - June 2012 - 189
American Oil and Gas Reporter - June 2012 - 190
American Oil and Gas Reporter - June 2012 - 191
American Oil and Gas Reporter - June 2012 - 192
American Oil and Gas Reporter - June 2012 - 193
American Oil and Gas Reporter - June 2012 - 194
American Oil and Gas Reporter - June 2012 - 195
American Oil and Gas Reporter - June 2012 - 196
American Oil and Gas Reporter - June 2012 - 197
American Oil and Gas Reporter - June 2012 - 198
American Oil and Gas Reporter - June 2012 - 199
American Oil and Gas Reporter - June 2012 - 200
American Oil and Gas Reporter - June 2012 - 201
American Oil and Gas Reporter - June 2012 - 202
American Oil and Gas Reporter - June 2012 - Industry Focus
American Oil and Gas Reporter - June 2012 - 204
American Oil and Gas Reporter - June 2012 - 205
American Oil and Gas Reporter - June 2012 - 206
American Oil and Gas Reporter - June 2012 - 207
American Oil and Gas Reporter - June 2012 - 208
American Oil and Gas Reporter - June 2012 - Classified Advertising
American Oil and Gas Reporter - June 2012 - Advertisers Index
American Oil and Gas Reporter - June 2012 - Cover3
American Oil and Gas Reporter - June 2012 - Cover4
http://www.nxtbook.com/nxtbooks/aogr/201912
http://www.nxtbook.com/nxtbooks/aogr/201911
http://www.nxtbook.com/nxtbooks/aogr/201910
http://www.nxtbook.com/nxtbooks/aogr/201909
http://www.nxtbook.com/nxtbooks/aogr/201908
http://www.nxtbook.com/nxtbooks/aogr/201907
http://www.nxtbook.com/nxtbooks/aogr/201906
http://www.nxtbook.com/nxtbooks/aogr/201905
http://www.nxtbook.com/nxtbooks/aogr/201904
http://www.nxtbook.com/nxtbooks/aogr/201903
http://www.nxtbook.com/nxtbooks/aogr/201902
http://www.nxtbook.com/nxtbooks/aogr/201901
http://www.nxtbook.com/nxtbooks/aogr/201812
http://www.nxtbook.com/nxtbooks/aogr/201811
http://www.nxtbook.com/nxtbooks/aogr/201810
http://www.nxtbook.com/nxtbooks/aogr/pbios_201810
http://www.nxtbook.com/nxtbooks/aogr/201809
http://www.nxtbook.com/nxtbooks/aogr/201808
http://www.nxtbook.com/nxtbooks/aogr/201807
http://www.nxtbook.com/nxtbooks/aogr/201806
http://www.nxtbook.com/nxtbooks/aogr/201805
http://www.nxtbook.com/nxtbooks/aogr/201804
http://www.nxtbook.com/nxtbooks/aogr/201803
http://www.nxtbook.com/nxtbooks/aogr/201802
http://www.nxtbook.com/nxtbooks/aogr/201801
http://www.nxtbook.com/nxtbooks/aogr/201712
http://www.nxtbook.com/nxtbooks/aogr/201711
http://www.nxtbook.com/nxtbooks/aogr/201710
http://www.nxtbook.com/nxtbooks/aogr/201709
http://www.nxtbook.com/nxtbooks/aogr/201708
http://www.nxtbook.com/nxtbooks/aogr/201707
http://www.nxtbook.com/nxtbooks/aogr/201706
http://www.nxtbook.com/nxtbooks/aogr/201705
http://www.nxtbook.com/nxtbooks/aogr/201704
http://www.nxtbook.com/nxtbooks/aogr/201703
http://www.nxtbook.com/nxtbooks/aogr/201702
http://www.nxtbook.com/nxtbooks/aogr/201701
http://www.nxtbook.com/nxtbooks/aogr/201612
http://www.nxtbook.com/nxtbooks/aogr/201611
http://www.nxtbook.com/nxtbooks/aogr/201610
http://www.nxtbook.com/nxtbooks/aogr/pbios2016_programguide
http://www.nxtbook.com/nxtbooks/aogr/201609
http://www.nxtbook.com/nxtbooks/aogr/201608
http://www.nxtbook.com/nxtbooks/aogr/201607
http://www.nxtbook.com/nxtbooks/aogr/201606
http://www.nxtbook.com/nxtbooks/aogr/201605
http://www.nxtbook.com/nxtbooks/aogr/201604
http://www.nxtbook.com/nxtbooks/aogr/201603
http://www.nxtbook.com/nxtbooks/aogr/201602
http://www.nxtbook.com/nxtbooks/aogr/201601
http://www.nxtbook.com/nxtbooks/aogr/201512
http://www.nxtbook.com/nxtbooks/aogr/201511
http://www.nxtbook.com/nxtbooks/aogr/201510
http://www.nxtbook.com/nxtbooks/aogr/201509
http://www.nxtbook.com/nxtbooks/aogr/201508
http://www.nxtbook.com/nxtbooks/aogr/201507
http://www.nxtbook.com/nxtbooks/aogr/201506
http://www.nxtbook.com/nxtbooks/aogr/201505
http://www.nxtbook.com/nxtbooks/aogr/201504
http://www.nxtbook.com/nxtbooks/aogr/201503
http://www.nxtbook.com/nxtbooks/aogr/201502
http://www.nxtbook.com/nxtbooks/aogr/201501
http://www.nxtbook.com/nxtbooks/aogr/201412
http://www.nxtbook.com/nxtbooks/aogr/201411
http://www.nxtbook.com/nxtbooks/aogr/201410
http://www.nxtbook.com/nxtbooks/aogr/201409
http://www.nxtbook.com/nxtbooks/aogr/pbios2014_programguide
http://www.nxtbook.com/nxtbooks/aogr/201408
http://www.nxtbook.com/nxtbooks/aogr/201407
http://www.nxtbook.com/nxtbooks/aogr/201406
http://www.nxtbook.com/nxtbooks/aogr/201405
http://www.nxtbook.com/nxtbooks/aogr/201404
http://www.nxtbook.com/nxtbooks/aogr/201403
http://www.nxtbook.com/nxtbooks/aogr/201402
http://www.nxtbook.com/nxtbooks/aogr/201401
http://www.nxtbook.com/nxtbooks/aogr/201312
http://www.nxtbook.com/nxtbooks/aogr/201311
http://www.nxtbook.com/nxtbooks/aogr/201310
http://www.nxtbook.com/nxtbooks/aogr/201309
http://www.nxtbook.com/nxtbooks/aogr/201308
http://www.nxtbook.com/nxtbooks/aogr/201307
http://www.nxtbook.com/nxtbooks/aogr/201306
http://www.nxtbook.com/nxtbooks/aogr/201305
http://www.nxtbook.com/nxtbooks/aogr/201304
http://www.nxtbook.com/nxtbooks/aogr/201303
http://www.nxtbook.com/nxtbooks/aogr/201302
http://www.nxtbook.com/nxtbooks/aogr/201301
http://www.nxtbook.com/nxtbooks/aogr/201212
http://www.nxtbook.com/nxtbooks/aogr/201211
http://www.nxtbook.com/nxtbooks/aogr/201210
http://www.nxtbook.com/nxtbooks/aogr/201209
http://www.nxtbook.com/nxtbooks/aogr/2012_pbios
http://www.nxtbook.com/nxtbooks/aogr/201208
http://www.nxtbook.com/nxtbooks/aogr/201207
http://www.nxtbook.com/nxtbooks/aogr/201206
http://www.nxtbook.com/nxtbooks/aogr/201205
http://www.nxtbook.com/nxtbooks/aogr/201204
http://www.nxtbook.com/nxtbooks/aogr/201203
http://www.nxtbook.com/nxtbooks/aogr/201202
http://www.nxtbook.com/nxtbooks/aogr/201201
http://www.nxtbook.com/nxtbooks/demo/aogr_clone
http://www.nxtbook.com/nxtbooks/aogr/201112
http://www.nxtbookMEDIA.com