Following the U.S. Senate’s decision last week to not repeal the Bureau of Land Management (BLM) Venting and Flaring regulation, you may be thinking about what happens next.
First Things First…Could the Rule Requirements Still Change?
Yes, there are several issues still in play that could result in changes to the regulation. For example:
These actions take time and possible changes to the rule will not happen immediately. So for now at least, the rule is final. Although timing requirements vary, the requirements do apply to new and existing oil and gas production operations. Here’s a quick summary of the requirements we put together when the rule was finalized last fall.
What to Put at the Top of Your To-Do List
Since compliance requirements actively apply, we recommend starting with the most time-sensitive pieces first:
- Identify affected facilities that began production after January 17, 2017, including any that will be coming on line over the next few months. Leak detection inspections must be completed within 60 days of beginning production at these facilities. If you are meeting NSPS OOOOa requirements, you are compliant.
- Submit your Waste Minimization Plans documenting how flared gas will be managed with Applications for Permit to Drill (APDs) submitted after January 17, 2017.
- Develop tank emissions information, if not already available. The deadline for existing tanks was March 18, 2017, and within 30 days of new production going to a new or existing tank. Tanks with greater than six tons/year of VOC emissions must be routed to sales lines or to a control device (flares/combustors/vapor recovery units) by January 17, 2018 (or 2020 if you need to replace the tanks).
Note that some exceptions to these requirements are allowed if and when compliance costs will cause you to shut-in the well(s), but you must document the basis of the exception(s) to BLM.
OK, That’s Figured Out, Now What?
- Put together a list of affected facilities that were producing on or before January 17, 2017. These facilities will require leak detection inspections by January 17, 2018. Depending on your operations, this could be a large list of sites, so plan the timing of these inspections accordingly.
- Develop an overall gas minimization strategy. The BLM rule imposes a phased-in requirement to reduce flared gas volumes over time (85% captured by January 2018 growing to 98% by January 2026, as well as decreasing allowed flaring volumes from 5,400 Mcf/well by January 2018 to 750 Mcf/well by January 2025). Your strategy can be developed by lease, county, or state, depending on what makes the most sense for your business.
- Upgrade high-bleed (greater than six scf/hr) continuous natural gas bleed pneumatic controllers to low- or zero-bleed pneumatics by January 17, 2018. Documented exceptions for safety and other requirements are allowed.
- Route gas-driven pneumatic pumps to a flare/combustor or replace with zero emission/solar-powered pumps by January 17, 2018.
There are also detailed requirements about liquids unloading that will affect plunger lift systems as well as gas capture during well completions. If you think these requirements may affect you, the details can be found in 43 CFR 3179.204 for liquids unloading, and 43 CFR 3179.102 for well completions.
What’s the Best Way to Manage all this Data?
We realize that this new regulation adds more work and cost to your organization, which is why Trihydro developed LeakTracker Pro. LeakTracker Pro software is designed to reduce the recordkeeping burden and help you save money complying with the new regulation. It combines field data collection with easy access to data, updates, recordkeeping, repair and remonitor timeframes, as well as annual report submission for your NSPS OOOOa and BLM leak data needs. The software is currently being adapted to meet the new BLM leak data tracking methods.
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For More Information
Ask our compliance team your other questions about the rule:
Calvin Niss, Senior Vice President
Air Quality & Process Management
Lynn Olson, Lead Project Engineer