Posted by: tommtn | November 20, 2013

Colorado Announces Proposed Rules to Greatly Reduce Emissions from Oil and Gas Wells

Colorado announced a groundbreaking proposed rule that will greatly reduce methane and smog-forming ozone chemicals in Colorado from the oil and gas production sector.  The Environmental Defense Fund (EDF) collaborated with Noble Energy, EnCana Oil and Gas, Anadarko Petroleum and the state to develop the regulations.  Tom Bloomfield of The Gallagher Law Group represented EDF in connection with the development and negotiation of the draft rules.  The development was widely reported in national and state media.

The Colorado Department of Public Health and the Environment projects that the rules will reduce smog-forming volatile organic compounds (VOCs) by 92,000 tons per year, which the state says is equivalent to removing the pollution from all cars from roads in the state.  The state estimates that the rule will reduce man-made VOC emissions in the state by twenty percent.

The rules will also reduce methane emissions by many tens of thousands of tons each year.  Methane is at least 28 times more powerful than CO2 as a greenhouse gas over the long term and at least 84 times more potent in the near term.  The regulations would be the first in the nation to directly regulate methane from oil and gas production facilities.

Among other things, the regulations would require the use of technology, such as infrared cameras, that is capable of detecting leaks from tanks, pipelines and other equipment that otherwise may not be discovered using other more conventional means.  For the largest sites, the rules will mandate monthly instrument based inspections.  The rules will require operators to systematically look for leaks and quickly repair them once detected.

If adopted, the rule will set the state apart from the rest of the country for regulation of greenhouse gases and smog-forming ozone from oil and gas production facilities.  For example, the rules will make Colorado the first state to:

  1. Directly regulate methane emissions from oil and gas production facilities
  2. Require Leak Detection and Repair (LDAR) to control fugitive emissions from all well sites statewide
  3. Require monthly LDAR on certain well sites (Colorado proposal would require monthly LDAR on largest emitters)
  4. Implement statewide requirements to limit venting from well maintenance activities such as liquids unloading
  5. Require retrofits of high bleed pneumatics statewide, a significant source of methane and VOC emissions and
  6. Require existing glycol dehydrators to control hydrocarbon emissions by 95% .

The collaboration between groups like EDF and leading energy companies provides a model for developing effective, practical regulations, based on sound science and modern technology.  The process and proposed rule can lead to greater accountability transparency and public trust.  These draft regulations provide a national template for rules to monitor, control and reduce methane leaks and VOC emissions from the oil and gas sector.

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