August 16, 2012
New and Revised Federal Air Compliance Regulations for the Oil and Gas Sector
The EPA has existing air quality regulations that affect the oil and gas industry including New Source Performance Standards (NSPS) under 40 CFR Subpart KKK and Subpart LLL and National Emission Standards for Hazardous Air Pollutants (NESHAP) Subpart HH and Subpart HHH. The EPA has expanded the regulatory reach on oil and natural gas sites with the issuance of the Oil and Gas Sector regulatory package on August 16, 2012 where they revised NESHAP Subparts HH and HHH and signed the new NSPS Subpart OOOO – Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution. In particular, the EPA has established Federal limitations on air emissions associated with hydraulic fracturing completions for natural gas (NG) wells. The applicability dates of NSPS Subparts KKK and LLL have also been revised to coincide with the NSPS Subpart OOOO applicability date of August 23, 2011.
The regulatory package, which was originally signed by the EPA on April 18, 2012, becomes effective on October 15, 2012.
The guide focuses on the new standards under NSPS Subpart OOOO. A brief summary is provided below.
Topic: New Oil and Gas Federal Air Quality Regulations and Requirements
NSPS Subpart OOO: Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution
Purpose: Control of volatile organic compounds (VOC) and Sulfur Dioxide (SO2) Emissions
Applicability: Affected Sources that Commence Construction, Modification or Reconstruction after August 23, 2011
• Natural Gas Wells (Completion with Hydraulic Fracturing)
• Centrifugal Compressor (with wet seals, located between wellhead and point of custody transfer)
• Reciprocating Compressor (located between the wellhead and point of custody transfer)
• Pneumatic Controller (located between wellhead and point of custody transfer)
• Pneumatic Controller (continuous bleed natural gas driven, located at a Natural Gas Plant)
• Storage Tank (in oil and NG production, NG processing or NG transmission and storage)
• Equipment Leaks / Fugitives (within an onshore Natural Gas processing unit)
• Sweetning Units (within Onshore Natural Gas Processing Plants)
Compliance Requirements: Affected Sources will have to do some or all of the following:
• Control Emissions (install control device)
T. Baker Smith, LLC has enjoyed a healthy working relationship with your company and can assist in this minor source air permitting process, or in other areas of air quality compliance (eg, Title V Permit Applications, Act 547 Exemption documentation, compliance reviews, etc.). Should you need further information, please do not hesitate to contact Chris Howard at 225.744.2101 or Kenny King at 985.223.9208.