As 2015 quickly approaches, there is still momentum in the development of domestic unconventional oil and gas resources. Therefore, exploration and production companies utilizing hydraulic fracturing are reminded that the final compliance provisions for reduced emission completions (RECs) pursuant to 40 CFR Part 60, Subpart OOOO (Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution) will become effective with the New Year. In this article ALL4 discusses the REC compliance requirements that become effective January 1, 2015, as well as the proposed amendments and their implications to RECs.
The Story of Subpart OOOO
Subpart OOOO regulates emissions of volatile organic compounds (VOC) and sulfur dioxide (SO2) from seven (7) categories of “affected facilities” for which construction, modification, or reconstruction began after August 23, 2011. Subpart OOOO was originally promulgated in July 2012, and was revised in September 2013. In July 2014, additional amendments were proposed that: provide regulatory clarification regarding the handling of liquids and gases during well completion operations; update requirements for storage vessels and reciprocating compressors; provide an opportunity for public comment on the definition of low-pressure wells within the rule; and clarify requirements for leak detection at natural gas processing plants. Key aspects associated with RECs are also clarified in the 2014 proposed amendments. These amendments are expected to be finalized in December 2014.