California Air Resources Board

Background

• Adopted by the Board in March 2017.
   
• Reduces fugitive and vented emissions of methane from both new and existing oil and gas facilities, including:
  • Oil and Gas Production, Processing, and Storage Facilities;
  • Natural Gas Gathering and Boosting Stations;
  • Natural Gas Underground Storage Facilities; and
  • Natural Gas Transmission Compressor Stations.
     
• Regulation includes standards for:
  • Separator and tank systems;
  • Circulation tanks;
  • Leak Detection and Repair (LDAR);
  • Underground natural gas storage monitoring;
  • Natural gas compressors;
  • Pneumatic devices and pumps; and
  • Reporting requirements.

Regulation Standards

• Separator and tank systems:
  • Requires flash testing to determine annual methane emissions.
  • Requires systems with annual emissions above 10 MT methane to install vapor collection.
     
• Circulation tanks used in Well Stimulation Treatments:
  • Operators institute a Best Practices Management Plan, followed by a control equipment technical assessment by January 1, 2019.
  • If technical assessment proves out, tanks controlled for emissions by January 1, 2020.
     
• Leak Detection and Repair (LDAR):
  • Requires daily audio/visual inspections and quarterly leak measurements of components.
  • Builds on current requirements by many districts to control VOCs.
  • Regulation extends testing to methane at natural gas facilities.
     
• Underground gas storage monitoring program:
  • Ambient air monitoring.
  • Daily or continuous leak monitoring at injection/withdrawal wellheads.
  • Operators submit monitoring plans to CARB for approval.
     
• Natural gas compressors:
  • Emission standards for reciprocating compressor rod packings and centrifugal compressor wet seals.
  • Requires either (1) replacement of high-emitting rod packing or wet seal, or (2) collection of leaking gas.
  • All compressors subject to LDAR.
     
• Pneumatic devices and pumps:
  • Continuous bleed to be changed to no-bleed.
  • Air or electricity to operate, or controlled with a vapor collection system.
     
• Reporting requirements:
  • Facility and equipment information;
  • Flash test results;
  • Annual LDAR Results;
  • Underground natural gas storage monitoring plan reporting;
  • Annual concentrations or flow rates for compressors and pneumatics; and
  • Additional annual reporting for liquids unloading of natural gas wells, and for well casting vents.

Regulation Impacts

• Overall estimated annualized cost, with natural gas savings, of $27,300,000.
• Estimated continuing reductions of more than 1.4 million MT of CO₂ equivalent per year, using a 20 year Global Warming Potential for methane.
• Estimated overall cost-effectiveness of $19 per MT of CO₂ equivalent reduced.
• Over 3,600 tons per year (TPY) of VOC reductions statewide.
• Over 100 TPY of reductions statewide of Toxic Air Contaminants, such as Benzene, Toluene, Ethyl-Benzene, and Xylenes.
• Neutral statewide Oxides of Nitrogen (NO_x) impact.

Implementation

• Regulation allows both CARB and the districts to implement; district implementation is preferred.
   
• For most districts, CARB is handling the one-time facility and equipment reporting; districts handling “on the ground” enforcement. For district-specific responsibilities, see Memoranda of Agreements.
   
• January 1, 2018
  • Leak Detection and Repair (LDAR) begins;
  • Underground natural gas storage facilities’ monitoring plans due; and
  • Equipment reporting and flash testing data due.
     
• July 1, 2018
  • CARB staff will decide to approve or request modifications of underground natural gas storage facilities’ monitoring plans.
     
• January 1, 2019
  • Vapor collection on separator and tank systems installed;
  • Pneumatic devices and compressor seal change-outs required; and
  • Circulation tank technology assessment complete.
     
• July 1, 2019
  • Annual reporting of LDAR results, compressor and pneumatic concentrations or flow rates, and liquids unloading and well casing vent reporting all due.
  • CARB is working with a contractor to develop a web-based tool for this reporting.
     
• January 1, 2020
  • Circulation tank vapor collection installed, pending technology assessment.