After publication in today’s Federal Register, U.S. EPA’s final air emission rules became effective for oil and gas production and natural gas transmission and storage facilities. The rules implement New Source Performance Standards (“NSPS”) for volatile organic compounds (“VOC”) and sulfur dioxide (“SO2”), and National Emissions Standards for Hazardous Air Pollutants (“NESHAP”). The new NSPS require that fractured and refractured gas wells use reduced emission completions (“RECs”) or completion combustion devices such as flaring until January 1, 2015. After January 1, 2015, owner/operators must use RECs and a completion combustion device together.
The NSPS also require controls that reduce VOC emissions by 95% for storage tanks that emit 6 tons or more per year of VOC. The reduction requirement applies to tanks used in oil and gas production, and natural gas processing, transmission and storage. Additionally, the NSPS require VOC limits for pneumatic controllers as well as 95% VOC reduction for wet seal centrifugal compressors. Finally, the NSPS establish more stringent leak detection and repair (“LDAR”) requirements for VOC leaks of 500 ppm or more and increase the required SO2 reduction from sweetening units at natural gas processing plants from 99.8% to 99.9%. The NSPS requirements are found at 40 C.F.R., Part 60, Subpart OOOO.
The NESHAP requires implementation of LDAR for valves when leaks are detected at 500 ppm for oil and gas production facilities. It also establishes Maximum Achievable Control Technology (“MACT”) standards for small glycol dehydrators in both production facilities and natural gas transmission facilities. The new NESHAP requirements can be found at 40 C.F.R. Part 63, Subpart HH and Subpart HHH.