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8/3/2019 EPA Review of Federal Air Regulations for the Oil and Natural Gas Sector public meetings August 2010
http://slidepdf.com/reader/full/epa-review-of-federal-air-regulations-for-the-oil-and-natural-gas-sector-public 1/19
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Review of Federal Air Regulationsfor the
Oil and Natural Gas Sector
Public Stakeholder Meetings
Arlington, TX, August 2, 2010Denver, CO, August 3, 2010
US Environmental Protection AgencyOffice of Air and Radiation
Office of Air Quality Planning and Standards
8/3/2019 EPA Review of Federal Air Regulations for the Oil and Natural Gas Sector public meetings August 2010
http://slidepdf.com/reader/full/epa-review-of-federal-air-regulations-for-the-oil-and-natural-gas-sector-public 2/19
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Overview
Background on the Oil and Natural Gas sector
Our regulatory tools
Applying our tools to this sector
Schedule for future activities
8/3/2019 EPA Review of Federal Air Regulations for the Oil and Natural Gas Sector public meetings August 2010
http://slidepdf.com/reader/full/epa-review-of-federal-air-regulations-for-the-oil-and-natural-gas-sector-public 3/19
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The Oil and Natural Gas sector hasbecome the focus of increasingpublic attention
Horizontal drilling and hydraulic fracturing enable extraction of shale gas
Gas reserves have gone from under 50 years to over 100 years
Recent gas boom has heightened public concern (water and air impacts)
Winter ozone exceedances in western states linked to oil and gas activity
Oil and natural gas sector accounts for 23% of U.S. methane emissions
Certain emissions are not addressed by existing federal air rules
8/3/2019 EPA Review of Federal Air Regulations for the Oil and Natural Gas Sector public meetings August 2010
http://slidepdf.com/reader/full/epa-review-of-federal-air-regulations-for-the-oil-and-natural-gas-sector-public 4/19
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8/3/2019 EPA Review of Federal Air Regulations for the Oil and Natural Gas Sector public meetings August 2010
http://slidepdf.com/reader/full/epa-review-of-federal-air-regulations-for-the-oil-and-natural-gas-sector-public 5/19
5Source: American Gas Association and EPA Natural Gas STAR Program
Producing Wells(Onshore and Offshore)
Gathering Lines
Compressor Stations
Processing Plant
Oil and Natural Gas Operations
UndergroundStorage
Transmission Lines
City GateRegulatorsMeters
Regulators/Meters
Large Volume Customer
Residential Customers
Commercial Customer
Distribution Mains
Oil Refineries(not in this sector)
LNG or Propane Plant
8/3/2019 EPA Review of Federal Air Regulations for the Oil and Natural Gas Sector public meetings August 2010
http://slidepdf.com/reader/full/epa-review-of-federal-air-regulations-for-the-oil-and-natural-gas-sector-public 6/19
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What are our regulatory tools?
New Source Performance Standards
National Emission Standards forHazardous Air Pollutants
Control Techniques Guidelines
8/3/2019 EPA Review of Federal Air Regulations for the Oil and Natural Gas Sector public meetings August 2010
http://slidepdf.com/reader/full/epa-review-of-federal-air-regulations-for-the-oil-and-natural-gas-sector-public 7/19
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New Source Performance Standards (NSPS)
Authority provided by Congress under Section 111(b) of Clean Air Act(CAA)
Primarily regulate criteria pollutants and precursors from new,reconstructed, and modified sources Ozone (via precursors VOC* and NOx*)
Sulfur dioxide (SO2) Nitrogen dioxide (NO2)
Particulate matter Carbon monoxide (CO) Lead
Concept -- make new facilities perform as well as the best existingfacilities (commonly known as “best demonstrated technology”)
Must be reviewed every 8 years to determine whether technology
advances warrant updating the requirements*Volatile organic compounds (VOC) and oxides of nitrogen (NOx)
8/3/2019 EPA Review of Federal Air Regulations for the Oil and Natural Gas Sector public meetings August 2010
http://slidepdf.com/reader/full/epa-review-of-federal-air-regulations-for-the-oil-and-natural-gas-sector-public 8/19
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National Emission Standards for Hazardous AirPollutants (NESHAP)
In 1990, Congress amended the CAA (section 112) to requireEPA to control a specific list of air toxics from new and existing
sources
Pollutants of concern to oil and natural gas sector: benzene, toluene, ethylbenzene, mixed xylenes (BTEX)
n-hexane
Concept -- technology-based standards that require what thebest facilities are doing
Requires risk and technology review (RTR) One-time residual risk assessment 8 years after promulgation to
determine if existing rule provides an ample margin of safety Technology review every 8 years to determine if technology
advances warrant updating the requirements
8/3/2019 EPA Review of Federal Air Regulations for the Oil and Natural Gas Sector public meetings August 2010
http://slidepdf.com/reader/full/epa-review-of-federal-air-regulations-for-the-oil-and-natural-gas-sector-public 9/19
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Control Techniques Guidelines (CTG)
Authority provided under Section 182 of CAA to
provide guidance to states for incorporation ofcontrol measures into state implementationplans (SIPs)
Affect new and existing sources in ozonenonattainment areas
Target VOC emissions (precursor to ozoneformation)
Establish recommendations for reasonablyavailable control technology (RACT)
8/3/2019 EPA Review of Federal Air Regulations for the Oil and Natural Gas Sector public meetings August 2010
http://slidepdf.com/reader/full/epa-review-of-federal-air-regulations-for-the-oil-and-natural-gas-sector-public 10/19
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What have we done so far? -- NSPS
Subpart KKK (1985) requires VOC leak detection and repair
(LDAR) for gas processing plants (facilities that removenatural gas liquids from field gas)
Subpart LLL (1985) requires control of SO2 emissions fromgas processing plants
Sweetening units (remove H2S and CO2 from sour gas)
Sulfur recovery units (recover elemental sulfur)
8/3/2019 EPA Review of Federal Air Regulations for the Oil and Natural Gas Sector public meetings August 2010
http://slidepdf.com/reader/full/epa-review-of-federal-air-regulations-for-the-oil-and-natural-gas-sector-public 11/19
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What have we done so far? -- NESHAP
Subpart HH controls air toxics from oil and natural gas
production operations (major source rule 1999, areasource rule 2007)
Tanks with flash emissions (major sources only)
Equipment leaks (major sources only)
Glycol dehydrators (major and area sources)
Subpart HHH controls air toxics from natural gas
transmission and storage operations (1999) Glycol dehydrators (major sources only)
8/3/2019 EPA Review of Federal Air Regulations for the Oil and Natural Gas Sector public meetings August 2010
http://slidepdf.com/reader/full/epa-review-of-federal-air-regulations-for-the-oil-and-natural-gas-sector-public 12/19
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Deadline Litigation CAA requires periodic reviews of NSPS and NESHAP
In 2009 WildEarth Guardians and San Juan CitizensAlliance filed deadline suit for failure to conduct requiredreviews of the two NSPS (1985) and failure to conduct
risk and technology reviews of the NESHAP rules (1999) Consent Decree entered 02/04/10
Deadline for proposed action 01/31/11
Deadline for final action 11/30/11
In addressing these obligations, we are evaluating theentire range of operations
8/3/2019 EPA Review of Federal Air Regulations for the Oil and Natural Gas Sector public meetings August 2010
http://slidepdf.com/reader/full/epa-review-of-federal-air-regulations-for-the-oil-and-natural-gas-sector-public 13/19
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What are we doing in our review?
We are looking at operations across the
entire sector Identifying emission sources
Quantifying emissions
Considering mitigation opportunities Analyzing environmental and economic impacts
The next few slides show the sources ofemissions in each segment
8/3/2019 EPA Review of Federal Air Regulations for the Oil and Natural Gas Sector public meetings August 2010
http://slidepdf.com/reader/full/epa-review-of-federal-air-regulations-for-the-oil-and-natural-gas-sector-public 14/19
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venting of
casinghead gas
flash emissionsfrom storage tanks
Where are the emissions?
NOTE: Shaded boxes denote emission sourcesat least partially covered by existing rules
vapor fromtruck loading produced
waterponds
landfarming
Crude Oil
Production
8/3/2019 EPA Review of Federal Air Regulations for the Oil and Natural Gas Sector public meetings August 2010
http://slidepdf.com/reader/full/epa-review-of-federal-air-regulations-for-the-oil-and-natural-gas-sector-public 15/19
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well completionsand workovers
Where are the emissions?
NOTE: Shaded boxes denote emission sourcesat least partially covered by existing rules
reciprocatingcompressor rod
packing
gas-drivenpneumatic
devices
Natural GasProduction and
Processing
processing plant leaks
glycol dehydrators
sweetening andsulfur recovery units
flash emissionsfrom storage tanks
8/3/2019 EPA Review of Federal Air Regulations for the Oil and Natural Gas Sector public meetings August 2010
http://slidepdf.com/reader/full/epa-review-of-federal-air-regulations-for-the-oil-and-natural-gas-sector-public 16/19
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leaks frompipelines and
compressorstations
Where are the emissions?
NOTE: Shaded boxes denote emission sourcesat least partially covered by existing rules
centrifugalcompressor seal
oil de-gassing
gas-drivenpneumatic
devices
Natural GasTransmission
and Storage
glycol dehydrators
reciprocatingcompressor rod
packing
storage tanks
venting of gas for
maintenance or repair ofpipelines and compressors
8/3/2019 EPA Review of Federal Air Regulations for the Oil and Natural Gas Sector public meetings August 2010
http://slidepdf.com/reader/full/epa-review-of-federal-air-regulations-for-the-oil-and-natural-gas-sector-public 17/19
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leaks from
unprotectedsteel mains and
service lines
Where are the emissions?
NOTE: Shaded boxes denote emission sourcesat least partially covered by existing rules
leaks at meteringand regulating
stations
gas-drivenpneumaticdevices
Natural Gas
Distribution
pipeline blowdowns
leaks frompipelines and
compressorstations
8/3/2019 EPA Review of Federal Air Regulations for the Oil and Natural Gas Sector public meetings August 2010
http://slidepdf.com/reader/full/epa-review-of-federal-air-regulations-for-the-oil-and-natural-gas-sector-public 18/19
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Where do we go from here?
Propose action (1/2011)
Public comment period following proposal
Complete reviews and take final action (11/2011)
8/3/2019 EPA Review of Federal Air Regulations for the Oil and Natural Gas Sector public meetings August 2010
http://slidepdf.com/reader/full/epa-review-of-federal-air-regulations-for-the-oil-and-natural-gas-sector-public 19/19
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How can you help?
Continue what you’re doing right now – beinvolved in the process
In the near term -- provide information on recentstudies that provide emissions data
During the public comment period followingproposal – give us constructive feedback