U.S. EPA Proposes Control Techniques Guidelines (CTGs) for the Oil and Natural Gas Industry

On August 18, 2015, the U.S. Environmental Protection Agency (U.S. EPA) posted draft Control Techniques Guidelines (CTGs) for the oil and gas industry in order to reduce volatile organic compound (VOC) emissions from existing oil and gas sources in ozone nonattainment areas, including the Ozone Transport Region (OTR).  

The CTGs were developed to provide support to regulatory agencies that are required to determine reasonably available control technology (RACT) for specific VOC emissions from the oil and gas industry.  U.S. EPA defines RACT as “the lowest emission limitation that a particular source is capable of meeting by the application of control technology that is reasonably available considering technological and economic feasibility.”  The idea behind these guidelines is that regulatory agencies can rely on U.S. EPA evaluations of VOC sources and corresponding control technologies to make informed decisions with respect to determining RACT under their jurisdiction.  The CTG documents often form the basis for state-specific RACT regulations which then apply to existing affected sources located in non-attainment areas.  The proposal of CTGs for the oil and gas industry by U.S. EPA could have substantial impacts on operators in Pennsylvania because Pennsylvania is in the OTR and the entire state is currently managed as an ozone nonattainment area for air permitting purposes (even though most of Pennsylvania is attaining the 2008 ozone standard). So when the Pennsylvania Department of Environmental Protection (PADEP) adds RACT rules for oil and gas operations (in 3 years or so), the rules could impact all existing sources covered by the CTGs.   

The proposed CTGs generally align with the proposed Subpart OOOOa (except the requirements for completions) covering VOC sources across the oil and gas industry, including the following with their proposed RACT recommendations:

• Storage Vessels – Recommended 95% reduction of VOC emissions from vessels with a potential to emit (PTE) greater than or equal to 6 tons per year (tpy);
• Pneumatic Controllers – Proposed natural gas bleed rate restrictions based on the type of continuous bleed, natural gas-driven pneumatic controller;
• Pneumatic Pumps – Proposed zero natural gas emissions from pumps located at natural gas processing plants and 95% reduction of VOC emissions from other pumps that have a control device;
• Compressors (Centrifugal and Reciprocating) – Recommended that RACT, for individual reciprocating compressors located before transmission of natural gas to transmission and storage, VOC emissions would be reduced by periodically replacing the compressor rod packing or through the use of a closed vent system.  Recommended that RACT, for individual centrifugal compressors using wet seals located before transmission of natural gas to transmission and storage, VOC emissions from each compressor wet seal fluid gassing system be reduced by 95% or greater.
• Equipment Leaks – Proposed that a leak detection and repair (LDAR) program be implemented on equipment components.
• Fugitive Emissions – Recommended that a periodic optical gas imaging (OGI) monitoring and repair program be implemented. 

How is this going to affect your facility?  Within two (2) years of the final issuance of the CTGs, U.S. EPA will require revisions to the appropriate State Implementation Plans (SIPs) (i.e., the States that include ozone nonattainment areas, including the OTR) to incorporate the changes in RACT regulations for the oil and gas industry, which will most likely be based on the information presented in these CTGs.   There will be a 60-day public comment period beginning on the date that the proposed rule is published in the Federal Register.    Existing oil and gas operators that will be impacted when Pennsylvania adopts RACT requirements for existing sources are encouraged to review the CTG proposal and provide comments for the public record.