White papers are a guide to regulations that EPA may issue.

The Environmental Protection Agency (EPA) has issued five white papers on oil and gas sector emissions for public comment. You have until June 16 to send data or comments on emissions or mitigation technologies.  The EPA will use the public comments along with those from a peer-review panel to draft new regulations to reduce methane and volatile organic compounds (VOC) from oil and natural gas operations.

Each white paper presents emissions data from past studies and information on potential mitigation techniques. The mitigation techniques proposed by the EPA are based on lessons learned in the Natural Gas STAR program and an economic analysis by ICF International, a consultancy. In several cases, there is little data on the emissions volumes of certain equipment or procedures. In other cases, the cost or emissions impacts of certain proposed equipment is unclear. Any additional data that you can provide will be valuable.

The white papers are on:

• Compressors: Possible mitigation techniques that are proposed are replacement of worn rod packing systems, the addition of emissions capture systems to reciprocating compressors, and other alternative components for specific compressor types.
• Completions and ongoing production of hydraulically fractured oil wells: Possible mitigation techniques proposed are reduced emission, or ”green,” completions and completion combustion, which is used to control VOC.
• Leaks from natural gas production, processing, transmission and storage: Proposed mitigation techniques include a variety of leak detection devices and repair of detected leaks. EPA determined that almost all leaks that are detected are economic to repair.
• Liquids unloading: Possible mitigation techniques include installation of plunger lift systems with gas capture, installation of artificial lift systems or other technologies.
• Pneumatic devices: Proposed mitigation techniques include installation of low-bleed or zero-bleed controllers where possible.

The white papers and instructions for submitting comments and data are at http://www.epa.gov/airquality/oilandgas/whitepapers.html

Comments are due by June 16.

Comments and data from AAPG members and their colleagues can be important to the EPA decision process. Data from scientists and operators familiar with industry technology and practices can significantly impact the resulting regulations because industry technology for emissions mitigation is rapidly evolving and there are few published studies of emissions volumes.