Federal laws, including in 40 CFR Part 60, Subpart OOOO (Quad O), are in place to regulate flaring in the United States. Additionally, in August 2016, Quad O was amended and finalized to include additional regulations, called 40 CFR Part 60, Subpart OOOOa. Subpart OOOOa regulates sources of VOC and greenhouse gases (GHGs) that were formerly unregulated under Subpart OOOO, including hydraulically fractured oil well completions, pneumatic pumps and fugitive emissions from well sites and compressor stations. It also addresses several unresolved Quad O issues such as:
- Storage vessel control device monitoring and testing
- Clarification of the due date for the initial annual report
- Clarification of flare design and operational standards (i.e., they are subject to the 40 CFR Part 60 Subpart A general provisions)
- The definition of capital expenditure (i.e., used when evaluating if a “reconstruction” will occur)
- Continuous control device monitoring requirements for storage vessels and centrifugal compressor affected facilities
However, individual states also have their own standards for controlling air quality as it relates to oil and gas production. ASHCOR flares are designed to be efficient and cost effective solutions for organizations who fall into a need for compliance with these environmental laws.
Below is a simplified breakdown of flaring regulations in states that play a major role in oil and gas production:
In early 2014, Colorado fully adopted the EPA’s standards found in 40 CFR Part 60, Subpart OOOO (Quad O). The state also adopted revisions to its emissions reporting and permitting framework, as well as oil and gas control measures (Regulation Number 7). The state’s regulations focus on identifying and repairing leaks, and Regulation Number 7 regulates methane emissions in the oil and gas industry.
Colorado was the first state to regulate methane emissions from oil and gas drilling, and the state’s regulations are considered the “gold standard” for other states to emulate. Producers are required to regularly check for leaks from pipelines, storage tanks and other equipment; since the rules went into effect, leakage rates have dropped by 75 percent.
Though not as strict in their regulations as Colorado, Montana stipulates that owners or operators of oil and gas well facilities must route volatile organic compound (VOC) vapors greater than 500 BTU/scf from oil and gas equipment to a gas pipeline. Or, if a gas pipeline is not within a half mile of the facility, the VOCs should be routed to a smokeless combustion device with electronic ignition or continuous burning pilot.
Operators are required to follow air pollution control standards at all times. If the average daily gas production exceeds 100 MCFG and the operator intends to flare the gas, the well may not produce more than an average of 100 MCFG per day each month after a required 60-day test. If an operator wishes to flare more than the 100 MCFG per day each month, a justified statement of flaring needs must be submitted to the governing body.
New Mexico requires companies to report the amount of gases vented or flared into the atmosphere from their operating sites, but operators have been delaying compliance. A 2016 gas-capture plan implemented by the Energy, Minerals and Natural Resources Department’s Oil Conservation Division was developed to address flaring, but recent numbers from March 2017 show only an 8 percent compliance rate.
Flares in New Mexico must be equipped with a system to ensure a flame is present at all times, and is operated without any visible emissions. Flares are subject to 20 percent opacity standards.*
*See Ringelmann Opacity Scale at the bottom of this post
North Dakota has implemented significant policies to decrease the amount of natural gas burned as waste. Producers are required to submit plans for capturing gas, and are limited on the percentage of gas they’re allowed to burn. A minimum of a pit flare with 90 percent Destruction and Removal Efficiency (DRE) is required for facility emission control on all new wells.
Flares must be equipped and operated with automatic ignition or continuous burning pilot. Additionally, visible emissions must not exceed 20 percent opacity. A maximum of 60 percent opacity is allowable for just one six-minute period each hour.*
Because of these regulations, what was once 36 percent of natural gas produced in oil fields being burned as waste has been reduced to 10 percent.
*See Ringelmann Opacity Scale at the bottom of this post
Specific regulations exist in Oklahoma to regulate venting and flaring. The Conservation Division may grant a permit to vent or flare daily gas volumes more than 50 mcf/day. Permit requirements are for a period up to 14 days, which begins with the first day gas flow is more than 50 mcf/day. A variety of exceptions exist for this permitting process.
Additionally, well operators must keep a daily log of gas volumes flared from the well during a 30-day period. These records are meant to be preserved for up to three years.
Texas has implemented detailed regulations controlled by the Texas Railroad Commission (TRRC) and Texas Commission on Environmental Quality (TCEQ). Flare permits in Texas are available for 45 days at a time, for a maximum of 180 days.
The TCEQ offers permits for routine air emissions from oil and gas production facilities. These air permits are designed to limit venting and flaring of gas – the TCEQ implements Quad O venting regulations. The air permits have facility- and emission source-specific emission control requirements for VOCs.
Oil and gas production in Wyoming is well regulated. Flaring must incorporate Best Available Control Technology (BACT), including enclosed, smokeless combustion devices or flares. These flares must reduce the mass content of VOC and total HAP emissions by at least 98 percent.
VOC and HAP emissions from flaring should be based upon the guaranteed DRE of the flare. Reported flared gases should include pilot gas with heat content and flared gas with average estimated heat content. Gases normally burned by flares in Wyoming have more than 900 BTU/scf.
To comply with Wyoming Department of Environmental Quality Air Quality Rules, flaring or venting must be reported monthly and include duration and total estimated volume of gas, circumstances that resulted in flared gas, identification of whether gas was vented or flared, identification of whether gas volume is based on metered flow or other measurement and a compositional analysis of the gas.
Venting or flaring is authorized in the cases of emergencies or upset conditions, and for safety purposes during necessary maintenance or upgrades. Additionally, production tests and well purging and evaluation tests are permissible for flaring.
Although individual states claim their own regulations surrounding flaring in the oil and gas industry, the overarching goal is to safely and effectively eliminate the risk of harmful VOCs entering the atmosphere.
ASHCOR flares are built to a high standard, and can be customized to meet certain state and site requirements. To learn more about our series of flares, click here. For more information about how ASHCOR can partner with your organization, contact us here.
*Ringelmann Opacity Scale