Understanding a New Regulatory Environment

摘要

On April 17, 2012, following an eight year review process of the Clean Air Act, the U.S. EPAfinalized and issued the first federally enforceable air quality regulations and standards for theOil and Natural Gas Industry. These regulations and standards were designed to reduceemissions of smog-forming volatile organic compounds (VOCs), along with other Hazardous AirPollutants (HAPs). After final comments of the newly proposed regulations were considered, theEPA released the New Source Performance Standards 40 CFR, Part 60, Subpart OOOO (NSPSOOOO or NSPS 4O) and updates to the National Emissions Standards for Hazardous AirPollutants (NESHAP) 40 CFR, Part 63, Subparts HH, and HHH (HH/HHH) for the oil and gasproduction, transmission, distribution, and processing industries. These regulations originallypublished on August 16, 2012 in the Federal Register. The most recent revisions to the NSPSOOOO regulations were published in the Federal Register on September 23, 2013 (FR 58416).These revisions addressed the first round of petitions filed by the American Petroleum Institute(API) and others for reconsideration; however, this revision mostly addressed the questionssurrounding storage tanks and the control device provisions of the rule.The EPA is expecting that all affected facilities comply with these regulations by installing acombustion control device that meets a 95% reduction. This applies to both HAPs and VOCemissions from hydraulically fractured gas wells, storage tanks, transmission, transportation,and processing equipment in the U.S. Oil and Natural Gas Industry. Flare systems, vaporrecovery units, and enclosed combustors are the most common types of control devices thatcan be installed to meet the requirements of these new regulations. Ms. Blake Leary of Zeeco,Inc., in conjunction with Mr. Ron M. Clark, P.E. of Sage Environmental Consulting, L.P., willaddress the specifics of these new regulations, and provide guidance for upstream andmidstream owners and operators in selecting the most cost-efficient and effective controlsystems available to meet these requirements.