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.

Air permits for oil and gas (O&G) production facilities include Federal EPA and State requirements for storage tanks for crude oil, condensate and produced water. The main EPA rules applying to O&G storage tanks are the New Source Performance Standards (NSPS) OOOO and OOOOa. Individual state environmental regulatory agencies may have their own storage tank regulations that might also apply.

The Ohio Environmental Protection Agency (Ohio EPA) is the environmental agency that administers air quality regulations and permitting programs in Ohio. Oil and gas (O&G) production facilities are required to obtain, from the Ohio EPA, an air permit prior to construction and operation. The exception to this is that for some counties, the Local Air Pollution Control Agency (LAPCA) is the air permitting agency in lieu of Ohio EPA. Contact the Ohio EPA to determine the correct air permitting agency for the county. The LAPCAs work with the Ohio EPA on air permitting for O&G operations. The following link has a listing of: OH Regional Offices and LAPCs.