On March 2, 2019, the USEPA finalized a voluntary New Owner Clean Air Act Audit (CAA) Program custom-made for the oil and natural gas sector.  The program can be used by new owners of upstream exploration and production sites to voluntarily find, correct and self-disclose Clean Air Act violations. This can result in timely and cost-effective CAA compliance.

On December 12, 2018, the Pennsylvania Department of Environmental Protection (PADEP) proposed air quality rules that would affect VOC emissions from existing oil and gas (O&G) facilities. The proposed rules are used comply with the USEPA’s Control Techniques Guidelines for the Oil and Natural Gas Industry (CTG) published in October 2016. The CTG document guides States in how to comply with VOC Reasonably Available Control Technology (RACT) requirements for ozone nonattainment areas and Ozone Transport Region (OTR). Pennsylvania is located in the northeast States OTR. These VOC RACT requirements would apply to existing O&G facilities that are not affected by the NSPS OOOO and OOOOa. The rules can also apply to NSPS OOOO and OOOOa sources since the States can be more stringent than federal requirements.

The pace of new federal air quality regulations to reduce releases of natural gas from oil and gas (O&G) operations has slowed. Existing Federal and State air quality rules are currently in place and actively being enforced by State environmental agencies. New and existing O&G facilities must be designed and operated to comply with air quality rules that limit fugitive equipment leaks and venting of natural gas.

Oil and gas operators are always in need of handy, desk top tools for quick air emission calculations. In response to this need, HY-BON/EDI offers, this valuable Excel spreadsheet for vent gas for free.

Field operations speak in terms of volume of gas in standard cubic feet (SCF) and environmental reporting wants mass amounts of air emissions. Conversion from volume of vented natural gas to mass is often needed by companies for internal communications and environmental reporting. Also, when sizing a vapor recovery units (VRU) or vapor combustion units (VCU), it is important to know the mass of air pollutants handled by these systems.

EPA Mandatory GHG Reporting Regulations – 40 CFR Part 98

The EPA’s greenhouse gas (GHG) reporting rules in 40 CFR 98 Subpart W – Petroleum and Natural Gas Systems are contained in 40 CFR 98 – Mandatory Greenhouse Gas Reporting. The rule requires a facility that has actual emissions of 25,000 metric tons or more of CO2e per year to submit an annual report of GHGs to the EPA. Below is a summary of the requirements regarding leak detection and repair (LDAR) requirements. Review the rule for specific detailed requirements.

On October 15, 2018, the U.S. Environmental Protection Agency (EPA) published a notice in the Federal Register for a proposal rule to revise 40 CFR 60 Subpart OOOOa (Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification or Reconstruction Commenced After September 18, 2015). The proposed changes are in response to petitions to reconsider several parts of the rule.

In September 2018, the Bureau of Land Management (BLM) announced the revision of the 2016 rule “Waste Prevention, Production Subject to Royalties, and Resource Conservation” (43 CFR Parts 3160 and 3170). A prepublication of the final rule can be found at: Link. The rule becomes effective 60 days after publication.

The USEPA posted proposed revisions to AP-42, Chapter 7, Section 7.1 - Organic Liquid Storage Tanks. The document referred to as “AP-42” is named AP-42, Compilation of Air Pollutant Emissions Factors, Volume 1: Stationary Point and Area Sources. AP-42 contains emission factors and emission estimation methods and equations used to calculate emissions across many emission source types (storage tanks, engines, heaters, loading losses, etc.) and industries. This includes emission sources used in the oil and gas (O&G) industry.