Final EPA Oil and Gas Air Emissions Rule Adopts Phased Approach for “Green Completion” of Gas Wells


Pursuant to a consent decree deadline, the U.S. EPA issued today its longawaited amended rules for the Oil and Natural Gas Industry. Proposed in August 2011, the amendments substantively revise new source performance standards (NSPS) and air toxics standards (NESHAPs) for the oil and gas sector that have been in place for more than ten years. For many sources in the industry, these rules represent the first federal standards for air emissions.

Focus on Fracking

Comment and controversy over the past months has concerned the proposed requirement to use “reduced emissions completion” (REC) or “green completion” techniques during hydraulic fracturing activities. An REC uses specialized equipment to capture hydrocarbons from flowback and route them to a pipeline. Many operators and organizations, including API, expressed forcefully the concern that the quantities of REC equipment sets necessary for compliance could not be manufactured by the proposed deadline. Other stakeholders, including some operators, strongly supported the proposed rule and its deadlines.

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