By Mary Ellen Ternes
On July 28, 2011, the EPA proposed new regulations governing the oil and natural gas production industry sector (to be codified at 40 CFR Parts 60 and 63). With this action, the EPA proposes the following four air regulations for the oil and natural gas industry:
- A new source performance standard (NSPS) for volatile organic compounds (VOCs)
- A NSPS for sulfur dioxide
- An air toxics NESHAP (National Emission Standard for Hazardous Air Pollutants) for oil and natural gas production
- A NESHAP for natural gas transmission and storage
The EPA is also proposing to add to the source category list any oil and gas operation not covered by the current listing and not previously subject to federal regulation.
The new NSPS source
category listing includes well completions at new hydraulically fractured natural gas wells and at existing wells that are fractured or “re-fractured.” The EPA is proposing to minimize VOC emissions from well completions by requiring “green completions,” also called “reduced emissions completions, ” where special equipment separates gas and liquid hydrocarbons from the flowback that comes from the well as it is being prepared for production, currently utilized through the EPA’s Natural Gas STAR program (not including exploratory or delineation wells). Also, the EPA proposes to require dry seal systems for centrifugal compressors and VOC emission limits for pneumatic controllers. The EPA proposes VOC emission reductions for condensate and crude oil storage tanks with a throughput of at least one barrel per day of condensate or 20 barrels per day of crude oil (equivalent to about 6 tons of VOC emissions per year) must reduce VOC emissions by 95 percent and new NSPS leak detection and repair requirements for natural gas processing plants.
Regarding air toxics, for oil and natural gas production, the EPA is proposing to remove the one ton per year benzene compliance option for large glycol dehydrators and require these units to reduce air toxics their emissions by 95 percent. In addition, the EPA is proposing to:
- Establish emission limits for small glycol dehydrators at major sources;
- Require all crude oil and condensate tanks at major sources to control their air toxics by at least 95 percent; and
- Tighten the definition of a leak for valves at natural gas processing plants.
For natural gas transmission and storage, the EPA proposes to remove the one ton per year benzene compliance alternative for large glycol dehydrators and establish emission limits for small glycol dehydrators at major sources.