EPA Proposes Oil and Gas Industry Emissions Limits

Posted Friday, November 13th, 2015

On August 18, 2015, the U.S. Environmental Protection Agency (EPA) released a suite of proposed regulations and guidance addressing methane and volatile organic compounds (VOCs) from the oil and gas sector. The proposals includes revisions to new source performance standards (NSPS), control technique guidelines for reducing VOCs in certain smog areas, guidance on aggregating emissions sources for permitting requirements, and a federal implementation plan (FIP) for minor new source review of oil and gas emissions sources on Indian land.

The NSPS revisions propose methane and VOCs standards for new, modified, and reconstructed emissions sources across the oil and gas sector. The revisions also propose methane standards for emissions sources currently regulated for VOCs. EPA notes that oil and gas sources subject to the 2012 NSPS for VOCs generally would not have to install additional controls, because the VOCs controls reduce both pollutants. In particular, the revisions would require finding and repairing leaks, capturing natural gas from hydraulically fractured and refractured oil wells, limiting emissions from new and modified pneumatic pumps, and limiting emissions from certain equipment at natural gas transmission compressor stations and at gas storage facilities not covered by the 2012 rules. Revisions are also intended to improve implementation and update certain procedures.

The proposed guidelines on reducing VOCs from existing oil and gas sources are intended to assist air agencies in determining “reasonably available control technology” (RACT) in certain ozone nonattainment areas and the Ozone Transport Region of the mid-Atlantic and northeast. It does not impose requirements. State implementation plan (SIP) revisions in response to the final control technology guidelines (CTG) must be submitted within two years from issuance of the final CTG.

The proposed aggregation rule would clarify source determinations in permitting for the oil and gas sector. “Adjacency,” for determining whether equipment and activities are a single source, would be defined either in terms of proximity (preferred by EPA) or in terms of proximity or related function.

As noted above, with the extension, comments on all rules are due by December 4, 2015.

For additional information contact Jon Harris Maurer.

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