The EPA has issued its Control Techniques Guidelines for the Oil and Natural Gas Industry (CTGs). The document describes reasonably available control technologies (RACTs) the EPA believes the oil and gas (O&G) sector can use to reduce emissions of volatile organic compounds (VOCs), which contribute significantly to the formation of ground-level ozone.
Issuance of the CTGs triggers the requirement that states that are in moderate and above-moderate nonattainment with the federal 2008 ozone National Ambient Air Quality Standards (NAAQS), as well as states in the Ozone Transport Area, must amend their state implementation plans (SIPs) with RACT rules addressing O&G VOC emissions. States are not compelled to adopt EPA’s recommended CTGs, but their SIP amendments must be approved by the Agency.
“States are encouraged to take additional steps to reduce VOC emissions beyond those included in the CTGs,” says the EPA.
Covered equipment
The guidelines include EPA’s RACT recommendations for reducing VOC emissions from a range of equipment and processes used in the O&G production industry, including storage tanks, centrifugal and reciprocating compressors, pneumatic controllers, pneumatic pumps, and equipment leaks from natural gas processing plants. The guidelines also include RACT recommendations for reducing VOC leaks (or fugitive emissions) at production gathering and boosting stations and at O&G well sites.
The recommended technologies include replacing high-bleed pneumatic controllers with low-bleed controllers and replacing rod packing on a regular recommended schedule. The EPA says these and other recommended control technologies are widely available at a reasonable cost to reduce the amount of natural gas—and the VOCs that come with it—that is vented to the air. Implementation of the CTGs can help save natural gas that otherwise would go to waste, notes the EPA.
Also included in the CTGs are recommended requirements for a variety of equipment located at low-producing well sites (producing less than 15 barrels of oil equivalent per day), such as storage tanks, pneumatic controllers, and pneumatic pumps. The EPA is not finalizing a RACT recommendation for fugitive emissions at these well sites at this time.
The CTG document includes model rule language for the recommended RACT rules. The intent of this language is to provide regulatory language that states can use as a starting point in the development of their SIPs.
Some areas or states subject to RACT requirements may not have any O&G sources covered by the CTGs, says the EPA. In such cases, a state may meet its obligations under the CTGs by submitting a statement to the EPA certifying that they do not have any covered sources.
Due date, benefits, cost
SIP revisions are due to the EPA within 2 years after the CTGs are published in the Federal Register. In a memo accompanying the release of the CTGs, the EPA notes that state plans must require that emissions controls for the covered sources be implemented as soon as practical, but no later than January 21, 2021.
If all states affected by the CTGs implement the recommendations, the EPA estimates that VOC emissions will be reduced by 80,000 tons per year. Also, across-the-board implementation of the recommendations would lower annual methane emissions from the O&G sector by 200,000 tons and hazardous air pollutants by 3,000 tons.
The EPA estimates the capital cost of full implementation of the CTGs at $390 million and annual costs at $100 million assuming savings from sales of recovered gas.
The Control Techniques Guidelines for the Oil and Natural Gas Industry is here.