By Marc Karell, P.E., CEM, Principal, Climate Change & Environmental Services, LLC
While the focus of the environmental controversy concerning hydraulic fracturing ("fracking") has been the alleged contamination of aquifers and other drinking water supplies, a recent U. of Colorado study (http://www.ucdenver.edu/about/newsroom/newsreleases/Pages/health-impacts-of-fracking-emissions.aspx) indicates that a much bigger health risk to the public may emanate from air emissions from fracking operations, such as exhaust high in natural gas and its major component methane leaving the mine and entering the atmosphere. The study asserts that this exhaust gas contains high levels of different air toxics, VOCs, and methane. With this in mind, the USEPA promulgated new final rules regulating air emissions from fracking and other production methods of natural gas on April 17, 2012. This is actually 4 rules, 2 New Source Performance Standards and 2 NESHAP (air toxic) Residual Risk rules for the oil & gas sector. See: http://www.epa.gov/airquality/oilandgas/pdfs/20120417finalrule.pdf. Summary: http://www.epa.gov/airquality/oilandgas/.
On the effective day of the rule (60 days after it will be published in the Federal Register), VOC emissions from all fracked wells will need to be flared during the well completion period. By Jan. 1, 2015, all natural gas fracking operators will be required to capture the exhaust from gas wells, centrifugal compressors, reciprocating compressors, pneumatic controllers, glycol dehydrators, sweetening units, and storage vessels using reduced emission completion ("REC") equipment (also known as "green completion" equipment). REC equipment allows operators to capture natural gas normally escaping from wells or other equipment which is of sufficient quality to be sellable, improving the economics of implementing these regulations. The USEPA estimates that these requirements will enable the industry to net an additional $11 to $19 million per year. The USEPA estimates that by capturing these gases, emissions of VOCs, NOx, and air toxics, including known carcinogens, such as benzene and hexane, from a fracking operation would be drastically lowered, by as much as 95%. The USEPA is allowing the delay of mandating REC usage until 2015 because public comment by the oil & gas industry indicated that there is believed to be an insufficient quantity of such equipment available for all fracking operations nationally. Low pressure and research wells are exempted from these provisions.
The new rules also contain monitoring, recordkeeping, and reporting requirements. For example, operators must notify the USEPA and/or state/local air agencies at least 2 days before well completion work begins. Well operators must also submit annual reports detailing all well completions for the prior year. The reports must be certified by a company Responsible Official.
CCES can help you assess your compliance status vis-à-vis new or existing federal and state air quality rules. We can devise multiple, cost-effective options for compliance. We can devise compliance systems to integrate with your current systems to reliably monitor your compliance status in the future.
CCES can help your facility in any state assess the NOx emissions of your boilers and strategize cost-effective options to lower them to comply with future regulations.
Reprinted with permission by CCES.
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