PETITION TO THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Petition for Listing and Rulemaking Under Section 112 of the Clean Air Act to Establish an Area Source Category for Oil and Gas Production Wells and Associated Equipment and to Set National Emission Standards for Hazardous Air Pollutant Emissions

Earthjustice and a coalition of nonprofit organizations petition the EPA to regulate oil and gas wells as area sources, arguing that the rapid expansion of drilling—particularly via hydraulic fracturing—in metropolitan areas poses a non-negligible risk to public health. The document details the emission of toxic air pollutants such as benzene and formaldehyde, highlights the vulnerability of children and overburdened communities, and identifies significant regulatory gaps in existing EPA rules. It concludes that available technologies, such as green completions and vapor recovery units, can substantially reduce these emissions.

• The number of oil and gas wells in the U.S. exceeded 1.04 million as of 2011, with projections suggesting an annual increase of 17,000–35,000 natural gas wells and 9,000–10,000 oil wells through 2035.
• Oil and gas production releases a wide array of hazardous air pollutants (HAPs), including benzene, toluene, ethyl benzene, xylenes, n-hexane, formaldehyde, and naphthalene.
• Existing EPA regulations, specifically the 2012 Rule, are insufficient as they are estimated to reduce HAP emissions by only 12,000-20,000 tons per year, leaving the majority of the industry's estimated 100,000+ tons of HAP emissions uncontrolled.
• Hydraulic fracturing introduces additional toxic chemicals into the air; between 2005 and 2009, companies used at least 595 products containing 24 different HAPs, with methanol appearing in 342 products.
• Research in Colorado's Denver-Julesburg Basin indicates that current emission inventories significantly underestimate benzene emissions, with some findings suggesting an underestimate by a factor of 7.
• Children are more vulnerable to toxic air emissions due to biological differences in development, and the petition argues that EPA must use age-dependent adjustment factors and a 10X default factor for in-utero exposure.
• Environmental justice data shows that racial minorities and people below the poverty level face increased cancer risk from the oil and natural gas production sector at rates higher than their general U.S. population representation.
• State enforcement of oil and gas rules is described as inadequate, with reports that 53% to 91% of wells in studied states operated without inspections to determine compliance.
• The EPA Inspector General found that the agency has limited directly-measured air emissions data for several processes, including well completions and evaporative ponds, leading to an inventory that likely underestimates emissions.
• Available technologies can significantly reduce emissions, including green completions, closed loop systems, vapor recovery units, and the use of centrifugal compressors with tandem dry seal systems.

APA

Earthjustice (2014). PETITION TO THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Petition for Listing and Rulemaking Under Section 112 of the Clean Air Act to Establish an Area Source Category for Oil and Gas Production Wells and Associated Equipment and to Set National Emission Standards for Hazardous Air Pollutant Emissions. https://earthjustice.org/wp-content/uploads/oilgastoxicwellspetition51314.pdf

Chicago

Earthjustice. PETITION TO THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Petition for Listing and Rulemaking Under Section 112 of the Clean Air Act to Establish an Area Source Category for Oil and Gas Production Wells and Associated Equipment and to Set National Emission Standards for Hazardous Air Pollutant Emissions. 2014. https://earthjustice.org/wp-content/uploads/oilgastoxicwellspetition51314.pdf.

Wikipedia

{{cite report |author=Earthjustice |title=PETITION TO THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Petition for Listing and Rulemaking Under Section 112 of the Clean Air Act to Establish an Area Source Category for Oil and Gas Production Wells and Associated Equipment and to Set National Emission Standards for Hazardous Air Pollutant Emissions |date=13 May 2014 |url=https://earthjustice.org/wp-content/uploads/oilgastoxicwellspetition51314.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{earthjustice2014petition, author = {{Earthjustice}}, title = {{PETITION TO THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Petition for Listing and Rulemaking Under Section 112 of the Clean Air Act to Establish an Area Source Category for Oil and Gas Production Wells and Associated Equipment and to Set National Emission Standards for Hazardous Air Pollutant Emissions}}, institution = {Earthjustice}, year = {2014}, month = may, url = {https://earthjustice.org/wp-content/uploads/oilgastoxicwellspetition51314.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }