will allison air pollution control division april 16, 2012 oil and natural gas air pollution...
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WILL ALLISON AIR POLLUTION CONTROL DIVISION
APRIL 16, 2012
Oil and Natural Gas Air Pollution Standards
EPA’s Proposed NSPS for oil and gas
Scheduled to be finalized April 17th
Four regulations applying to oil and gas industry: 1) NSPS for VOCs; 2) NSPS for SO2; 3) air toxics standard for oil and gas production; and 4) air toxics standard for transmission and storage of oil and gas
Rules Affected
NSPS KKK Standards of Performance for Equipment Leaks of VOC from Onshore Natural Gas
Processing Plants for which Construction, Reconstruction, or Modification Commenced After January 20, 1984, and On or Before August 23, 2011, 40 C.F.R. Part 60, Subpart KKK
NSPS LLL Standards of Performance for SO2 Emissions from Onshore Natural Gas Processing
Plants for which Construction, Reconstruction, or Modification Commenced After January 20, 1984, and On or Before August 23, 2011, 40 C.F.R. Part 60, Subpart LLL
NSPS OOOO Standards of Performance for Crude Oil and Natural Gas Production, Transmission,
and Distribution, 40 C.F.R. Part 60, Subpart OOOO
MACT HH National Emissions Standards for Hazardous Air Pollutants from Oil and Natural Gas
Production Facilities, 40 C.F.R. Part 63, Subpart HH
MACT HHH National Emissions Standards for Hazardous Air Pollutants from Natural Gas
Transmission and Storage Facilities, 40 C.F.R. Part 63, Subpart HHH
NSPS Review
Current NSPS KKK and LLL only cover natural gas processing plants
Proposed NSPS OOOO: Strengthens requirements for equipment leaks at
natural gas processing plants; and Covers previously unregulated sources such as:
Well completions and recompletions Compressors Pneumatic Controllers Storage Vessels (i.e. condensate and crude oil tanks)
MACT Review
Current MACT HH and HHH cover: Most glycol dehydrators at major and area sources,
down to a 1 tpy benzene threshold Storage tanks with the potential for flash emissions Equipment leaks
Proposed revisions: Establish limits for all glycol dehydrators at major
sources, regardless of benzene emission levels Include all storage tanks, regardless of potential for
flash emissions
Colorado Comments
Specific Issues Delegation and Distribution of Authority to State
Agencies Split Delegation or Other Alternative? Increase in burden on regulating agencies
Green Completions Criteria Clarifications on when green completion may not be feasible Include oil AND gas wells in green completion requirements Re-fracturing and initial completion should be included in
requirements Storage Vessel Modification
Fracturing or re-fracturing a well should be a considered a modification for the storage tank
Colorado Comments
Other Emission Sources Amine Units Produced and Flowback Water Storage, Treatment
and Evaporation Pneumatic Pumps Pigging Activities
Tracking and Reporting BurdenTechnical ReconsiderationsRule Clarifications
