The American Petroleum Institute (API) is submitting this supplemental comment letter on the proposed rulemaking to create a new Subpart OOOO as a result of EPA’s sector-based rulemaking for the oil and natural gas (O&G) industry. API represents more than 490 oil and natural gas companies and most of our members will be directly impacted by these proposed regulations.
The attachment to this letter is intended to:
1. Address EPA’s concerns regarding industry’s ability to reliably anticipate the volatile organic compound (VOC) content of a gas well prior to drilling in order to comply with a VOC percent by weight applicability cutoff for the reduced emissions completion (REC) requirements in the well. Suggested rule text has been provided that would implement this process.
2. Expand our cost-effectiveness arguments further supporting inclusion of an appropriate percent by weight VOC cutoff for RECs in the final rule.
3. Correct the record regarding API’s November 30, 2011 comments that underestimated the VOC content of common shale plays by only showing the average for an entire shale play.
We believe this additional information further supports an appropriate VOC percent by weight threshold for REC requirements in the final rule. As this data indicates, an operator will have sufficient knowledge of the VOC content of given gas well, because of its location and gas characteristics, and can determine in advance whether a well is likely to be above the 10% VOC by weight threshold. We are aware, however of the importance to EPA of an easily implemented and enforceable mechanism to ensure that all gas wells above the VOC threshold are subject to the requirements of NSPS OOOO. Whether a gas wellhead facility is subject to NSPS OOOO can be readily determined by direct measurement of the VOC content of any gas well that did not conduct a REC within 30 days of the date that production commences and report any wells that were, indeed, above the threshold as deviations. This will provide strong incentive for operators to get it right in the first instance and will provide information that will assist EPA in improving implementation of the rule.
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