Obtaining Proper Authorization to Discharge Air Pollutants from Oil and Gas Production Facilities

摘要

Based on current rules, most oil and gas facilities required to secure authorization for air pollutant emissions are minor sources under EPA NSR rules, although a somewhat greater number may be subject to EPA Title V Operating Permit rules. Therefore, most sites must demonstrate that they qualify for an exemption, permit-by-rule, standard permit, or must obtain authorization to construct and operate under state minor source permitting rules. Such facilities located on Indian lands where the tribal government does not have delegated permitting authority must obtain a minor source permit under EPA rules. The major challenge when preparing documentation for these purposes is collecting the data required to calculate the facility emission rates and identify the best approach for securing authorization. In addition, while oil and gas production facilities have been operating in the US for over a century, the emissions from most sites were at levels that didn't draw much attention from regulators. Therefore, mission calculation methods have not been rigorously developed, and emission factors for sources unique to oil and gas production operations are often based on very limited studies or data from other industries. Finally, in most states, oil and gas operators secure drilling permits and, often, permits for managing water and wastes from a state agency other than the one responsible for authorizing air emissions, which has led to a lack of both compliance and enforcement across the industry.