Breaking News - July 29, 2011
proposed amendments to Air regulations for the oil and natural gas industry
In response to a legal deadline, EPA announced on July 28, 2011 the proposal of several new air regulations impacting the oil & natural gas industry. EPA’s deadline to publish the final rules is 2/28/2012. Note that EPA believes that these standards will result in a net cost savings to industry based on captured gas value.
The proposed rules include both New Source Performance Standards (NSPS) and Air Toxics standards (NESHAPs), and include controls on gas emissions associated with hydraulic fracturing. The rules, once finalized, will affect production and processing operations (drilling and well completion, producing wells, gathering lines, gathering and boosting compressors, and gas processing plants) and transmission and storage (transmission compressor satiations, pipelines, and underground storage). Public hearings on the rule will be scheduled in Dallas, Denver, and Pittsburgh.
The following summary is based on EPA’s Fact Sheet for the rules. The actual regulatory language will need to be reviewed to determine exact requirements.
Proposed NSPS regulations (two NSPS standards, one for VOCs and one for SO2):
- Natural Gas Processing Plants
- Stricter LDAR requirements
- Tighter SO2 controls for gas plants handling > 50% H2S gas
- Well completions and re-completions = VOC controls
- Hydraulically fractured wells (new and existing wells that are fracked or re-fracked) – “green completions” (gas separation equipment to capture hydrocarbons during “flowback” period; and flaring of vented gases (when hydrocarbons cannot be collected)
- Green completions not required for exploratory and reservoir delineation wells, these wells must use flaring
- Compressors
- Centrifugal – dry seals
- Reciprocating – replace rod packing every 26,000 hours of operation
- Pneumatic controllers
- Gas plants – new or replaced controllers not gas driven
- Compressor stations – emission limit of 6 cubic feet of gas per hour
- Exceptions for applications requiring high-bleed controllers
- Storage vessels (condensate and crude oil) – at wells and other production facilities – VOC controls
- 95% VOC controls on tanks greater than 1 bbl condensate/day or 20 bbls crude oil/day
Proposed Air Toxics regulations (two NESHAP standards)
Oil and Natural Gas Production (not applicable to Area Sources)
- Storage tanks
- Tanks at major sources require 95% toxics control
- (eliminates throughput, API gravity, and gas/oil ratio criteria)
- Equipment Leaks
- Tighter equipment leak standard
- Glycol dehydrators
- Eliminate current 1 ton/year benzene compliance option at major sources, 95% control requirement
- Small glycol dehydrator requirements at major sources (< 3 MMscfd or annual benzene emissions < 1 ton per year)
Natural gas transmission and storage
- Glycol dehydrators
- Eliminate current 1 ton/year benzene compliance option at major sources, 95% control requirement
- Small glycol dehydrator requirements at major sources (< 10 MMscfd or annual benzene emissions < 1 ton per year)
Title V Operating Permit
- Facilities that are non-major and not otherwise subject to Title V operating permit requirements would not be subject to Title V if they trigger the NSPS rules in this proposal.
Links to key documents released at this time:
Fact Sheet – http://www.epa.gov/airquality/oilandgas/pdfs/20110728factsheet.pdf
PowerPoint slide deck: - http://www.epa.gov/airquality/oilandgas/pdfs/20110728presentation.pdf
Proposed Rule: http://www.epa.gov/airquality/oilandgas/pdfs/20110728proposal.pdf
Regulatory Impact Analysis: http://www.epa.gov/ttn/ecas/regdata/RIAs/oilnaturalgasfinalria.pdf
For more information regarding the proposed regulations, contact Cal Niss or Jay Christopher at 800-359-0251.
