EPA Review of Federal Air Regulations for the Oil and Natural Gas Sector public meetings August 2010

8/3/2019 EPA Review of Federal Air Regulations for the Oil and Natural Gas Sector public meetings August 2010

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Review of Federal Air Regulationsfor the

Oil and Natural Gas Sector

Public Stakeholder Meetings

Arlington, TX, August 2, 2010Denver, CO, August 3, 2010

US Environmental Protection AgencyOffice of Air and Radiation

Office of Air Quality Planning and Standards



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Overview

Background on the Oil and Natural Gas sector

Our regulatory tools

Applying our tools to this sector

Schedule for future activities



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The Oil and Natural Gas sector hasbecome the focus of increasingpublic attention

Horizontal drilling and hydraulic fracturing enable extraction of shale gas

Gas reserves have gone from under 50 years to over 100 years

Recent gas boom has heightened public concern (water and air impacts)

Winter ozone exceedances in western states linked to oil and gas activity

Oil and natural gas sector accounts for 23% of U.S. methane emissions

Certain emissions are not addressed by existing federal air rules



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5Source: American Gas Association and EPA Natural Gas STAR Program

Producing Wells(Onshore and Offshore)

Gathering Lines

Compressor Stations

Processing Plant

Oil and Natural Gas Operations

UndergroundStorage

Transmission Lines

City GateRegulatorsMeters

Regulators/Meters

Large Volume Customer

Residential Customers

Commercial Customer

Distribution Mains

Oil Refineries(not in this sector)

LNG or Propane Plant



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What are our regulatory tools?

New Source Performance Standards

National Emission Standards forHazardous Air Pollutants

Control Techniques Guidelines



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New Source Performance Standards (NSPS)

Authority provided by Congress under Section 111(b) of Clean Air Act(CAA)

Primarily regulate criteria pollutants and precursors from new,reconstructed, and modified sources Ozone (via precursors VOC* and NOx*)

Sulfur dioxide (SO2) Nitrogen dioxide (NO2)

Particulate matter Carbon monoxide (CO) Lead

Concept -- make new facilities perform as well as the best existingfacilities (commonly known as “best demonstrated technology”)

Must be reviewed every 8 years to determine whether technology

advances warrant updating the requirements*Volatile organic compounds (VOC) and oxides of nitrogen (NOx)



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National Emission Standards for Hazardous AirPollutants (NESHAP)

In 1990, Congress amended the CAA (section 112) to requireEPA to control a specific list of air toxics from new and existing

sources

Pollutants of concern to oil and natural gas sector: benzene, toluene, ethylbenzene, mixed xylenes (BTEX)

n-hexane

Concept -- technology-based standards that require what thebest facilities are doing

Requires risk and technology review (RTR) One-time residual risk assessment 8 years after promulgation to

determine if existing rule provides an ample margin of safety Technology review every 8 years to determine if technology

advances warrant updating the requirements



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Control Techniques Guidelines (CTG)

Authority provided under Section 182 of CAA to

provide guidance to states for incorporation ofcontrol measures into state implementationplans (SIPs)

Affect new and existing sources in ozonenonattainment areas

Target VOC emissions (precursor to ozoneformation)

Establish recommendations for reasonablyavailable control technology (RACT)



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What have we done so far? -- NSPS

Subpart KKK (1985) requires VOC leak detection and repair

(LDAR) for gas processing plants (facilities that removenatural gas liquids from field gas)

Subpart LLL (1985) requires control of SO2 emissions fromgas processing plants

Sweetening units (remove H2S and CO2 from sour gas)

Sulfur recovery units (recover elemental sulfur)



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What have we done so far? -- NESHAP

Subpart HH controls air toxics from oil and natural gas

production operations (major source rule 1999, areasource rule 2007)

Tanks with flash emissions (major sources only)

Equipment leaks (major sources only)

Glycol dehydrators (major and area sources)

Subpart HHH controls air toxics from natural gas

transmission and storage operations (1999) Glycol dehydrators (major sources only)



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Deadline Litigation CAA requires periodic reviews of NSPS and NESHAP

In 2009 WildEarth Guardians and San Juan CitizensAlliance filed deadline suit for failure to conduct requiredreviews of the two NSPS (1985) and failure to conduct

risk and technology reviews of the NESHAP rules (1999) Consent Decree entered 02/04/10

Deadline for proposed action 01/31/11

Deadline for final action 11/30/11

In addressing these obligations, we are evaluating theentire range of operations



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What are we doing in our review?

We are looking at operations across the

entire sector Identifying emission sources

Quantifying emissions

Considering mitigation opportunities Analyzing environmental and economic impacts

The next few slides show the sources ofemissions in each segment



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venting of

casinghead gas

flash emissionsfrom storage tanks

Where are the emissions?

NOTE: Shaded boxes denote emission sourcesat least partially covered by existing rules

vapor fromtruck loading produced

waterponds

landfarming

Crude Oil

Production



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well completionsand workovers



reciprocatingcompressor rod

packing

gas-drivenpneumatic

devices

Natural GasProduction and

Processing

processing plant leaks

glycol dehydrators

sweetening andsulfur recovery units

flash emissionsfrom storage tanks



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leaks frompipelines and

compressorstations



centrifugalcompressor seal

oil de-gassing

gas-drivenpneumatic

devices

Natural GasTransmission

and Storage

glycol dehydrators

reciprocatingcompressor rod

packing

storage tanks

venting of gas for

maintenance or repair ofpipelines and compressors



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leaks from

unprotectedsteel mains and

service lines



leaks at meteringand regulating

stations

gas-drivenpneumaticdevices

Natural Gas

Distribution

pipeline blowdowns

leaks frompipelines and

compressorstations



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Where do we go from here?

Propose action (1/2011)

Public comment period following proposal

Complete reviews and take final action (11/2011)



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How can you help?

Continue what you’re doing right now – beinvolved in the process

In the near term -- provide information on recentstudies that provide emissions data

During the public comment period followingproposal – give us constructive feedback

EPA Review of Federal Air Regulations for the Oil and Natural Gas Sector public meetings August 2010

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