- The California Air Resources Board (CARB) is finalizing methane emissions regulations prior to fully understanding and providing the public with the actual environmental or financial impacts to our local communities.
- CARB staff has worked on the Rule for over two years, expecting industry and affected local air districts to develop and implement programs in only nine months. To facilitate arbitrary internal milestone dates, CARB is willing to compromise the quality and efficiency of regulatory implementation.
WSPA recommends CARB extend the timeline of implementation by at least one year to allow operators and local air districts the ability to properly plan and implement the regulation requirements.
Leak Detection and Repair
- Oil and gas production and natural gas storage are both affected industries under this regulation. However, the business purpose and operational control of oil and gas production as compared to natural gas storage are completely different. Fugitive methane sources in oil and gas production are minimal and have very low potential for prolonged catastrophic events.
- Unlike other industries, the oil and gas production industry has had 20 years of successful LDAR programs. This regulation disregards proven successful LDAR programs that have been in existence for decades.
- Oil and gas operations in the San Joaquin Valley (responsible for greater than 80% of California’s oil and gas production) are already held to strict LDAR requirements under the SJVAPCD. The CARB emissions estimates fail to take this fact into account and therefore, the CARB emission estimates are inaccurate and overstate methane emissions from production activity.
- Adding separate LDAR requirements from CARB to existing local air district LDAR requirements will create unnecessary complexity and cost for both the local air districts and industry with no benefit to achieving California’s greenhouse gas goals.
WSPA recommends annual inspections instead of quarterly inspections for oil and gas production facilities.
- Circulation tanks are used to clean the wellbore of sand using water following well stimulation.
- Vapors occurring from the recirculation process are at low pressures and are oxygen-rich with insignificant amounts of methane.
- Routing temporary, low-pressure, variable quality, and oxygen-rich vapors to an existing stabilized vapor recovery systems or fuel lines will cause a safety hazard by creating an environment for fire and explosions, putting the entire facility and associated employees at risk.
- Testing has shown in California that the quantity of methane (volume and concentration) from these tanks is so low that operators would have to use large quantities of supplemental fuel to control the methane. The result of attempting to control these small emissions will be an increase of NOx and other criteria pollutants in areas struggling to meet attainment with Federal ozone standards.
- Because no viable control technology currently exists, operators will have no other option except to stop all Well Stimulation Treatment operations post 2020. This will require California to import more oil to meet in-state demand.
WSPA recommends CARB revise this section of the regulation in order to allow operators to use Best Management Practices (BMP) in the event no control technologies are developed to control low fugitive methane emissions from recirculation tanks beyond January 1, 2020.
- Gauge tanks are used to test the amount of production from a single well.
- Gauge tanks do not operate continuously. Many gauge tanks operate once a week or once every few weeks depending on the wells connected in the process. Each test may last an average of 2-4 hrs.
- Gauge tanks operate by using valves to isolate the fluids in the tank from the separator and tank system. As such, gauge tanks must be evaluated independently of separator and tank systems for inclusion in the regulation.
- CARB did not include gauge tanks in any of their environmental or economic analyses, and the gauge tank requirements were included last minute in the regulation without proper evaluations.
- The cost to install vapor recovery systems on gauge tanks is uneconomical, eliminating the ability to use these tanks would prohibit effective measurement, and therefore would result in less in-state crude oil production.
WSPA recommends the requirements for gauge tanks should be removed; or at the very least be exempted because these tanks are only used for testing purposes and not for storage of oil.
WSPA recommends ARB should exempt gauge tanks based on WSPA’s July 18 comments and recommendations.