IMPROVING PETROLEUM GOVERNANCE: CONTEMPORARY DISCUSSIONS ON GHANA’S PETROLEUM ENVIRONMENTAL LAWS AND REGULATIONS - Part 3

Gaps in the Laws and Regulations and Corresponding Recommendations

3. Air Pollution

The only provisions in the Petroleum (Exploration and Production) Act, 2016 (Act 919) and the Petroleum (Health, Safety and Environmental) Regulations 2017, (L.I. 2258) that address air pollutant emissions from oil and gas activities are sections 46 and 149 respectively.  Neither of these provisions imposes limits on air pollutant emissions from oil and gas wells other than minimal safeguards, such as the use of a flare shield in certain topographic conditions and the reporting of the amount of petroleum flared under emergency conditions. 

Recommendation

Government should consider adopting emission standards equivalent to those that apply to onshore petroleum exploration and development operations in the U.S.: 40 C.F.R. (Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution).   The rule is designed to limit emissions of greenhouse gases (e.g., methane), SO2 (sulfur dioxide) and Volatile Organic Compounds (VOCs), which are significant pollutants that adversely impact climate change, air quality and human health.

Compliance with these standards would require operators of onshore oil and natural gas wells with hydraulic fracturing [commonly used in onshore oil and gas extraction to stimulate well production] to capture and recover methane and other VOCs as soon as practicable, but no later than after the initial flow back stage.

The International Finance Corporation (IFC) outlines air pollution control recommendations in its Environmental, Health and Safety guidelines for offshore oil and gas development. The guidelines identify five main sources of air pollution: combustion sources (e.g., boilers, turbines); compressors, pumps, and engines; emissions from venting and flaring; intermittent emissions (e.g., well testing, engine exhaust); and fugitive emissions.  With regard to fugitive emissions, the IFC recommends:

• “All reasonable attempts should be made to implement appropriate methods for controlling and reducing fugitive emissions in the design, operation, and maintenance of offshore facilities. As an example, the U.S. State of California recently adopted methane emission standards that apply to both onshore and offshore oil and gas facilities, imposing various standards for vapour collection and leak detection for both onshore and offshore unit.

• The IFC recommends use of very low sulfur content fuels and/or natural gas to drive machinery and equipment on offshore oil and gas facilities.

• Emissions standards for small combustion facilities are set forth in the IFC’s General Environmental, Health and Safety Guidelines, at pages 6-7.

• For well testing, the IFC states: “flaring of produced hydrocarbons should be avoided, especially in environmentally sensitive areas.” The IFC guidelines advise regulators to thoroughly evaluate alternatives to flaring of produced hydrocarbons during well testing and to document this process.

My name is Kofi Anokye, a development enthusiast, and by the time I leave this world, it must be better than I found it. Brains, not natural resources, develop a nation!