Frequently Asked Questions: Associated Gas
View frequently asked questions about EPA's 2024 final rule for oil and natural gas operations - associated gas. On this page:
The distinction between wells with associated gas above and below 40 tpy only exists in EG OOOOc at § 60.5391c for existing sources. No such distinction exists for NSPS OOOOb. NSPS OOOOb at § 60.5377b applies to all new, modified, and reconstructed wells irrespective of how much associated gas the well produces.
How should owners/operators demonstrate that alternatives to flaring are technically infeasible?
An infeasibility demonstration must address the technical infeasibility for all options identified in the rule at § 60.5377b, specifically:
- Route into a gas gathering flow line or collection system to a sales line,
- recover from the separator and use as an onsite fuel source,
- recover from the separator and use for another useful purpose that a purchased fuel, chemical feedstock, or raw material would serve, or
- recover from the separator and reinject into the well or injected into another well.
For routing into a gas gathering flow line or collection system to a sales line, the demonstration could rely on information such as inability to secure necessary easements and/or rights-of-way, inability to obtain necessary specialized equipment, inadequate capacity of gathering system to accept the gas, or production sharing contract restrictions. For recovery and use as an onsite fuel source, a demonstration could explain how or why recovery from the separator and use as an onsite fuel source is infeasible for reasons specific to the site. A demonstration that it is infeasible to reinject the associated gas into the well or another well could include a lack of availability of a well to reinject the gas or the infeasibility of reinjection based on the unsuitability of the geology of the site. However, the third option—use the associated gas for another useful purpose that a purchased fuel, chemical feedstock, or raw material would serve—is more open-ended.
The final rule does not specify the ‘‘other useful purpose’’ solutions that must be evaluated, but it is the responsibility of the owner and operator, along with the qualified professional engineer or other qualified personnel performing the evaluation, to ensure that the list of options evaluated is comprehensive to address technically viable solutions.
Technologies that are in the evaluation, pilot-plant, or testing stages are not considered to be technically viable.
In summary, to demonstrate technical infeasibility in order to route to a flare or control device, where allowed by the regulations, you must establish that it is not technically feasible to:
- route the associated gas into a gas gathering flow line or collection system to a sales line, or
- use the associated gas as an onsite fuel source such as a generator, fuel cell, or other power-producing use, or
- reinject into the well or another well, or
- utilize the associated gas for ‘‘other useful purposes.”
A technically viable ‘‘other useful purpose’’ is likely to require the routing of the associated gas to on-site or nearby equipment that compresses, liquifies, or transforms the gas into a physical state that can be transported by pipeline or other transportation mode to an eventual user. A determination of technical infeasibility requires a showing of site-specific conditions that make these operations infeasible for even the most basic of such uses. One such basic use is capture and truck transportation offsite.