The U.S. Environmental Protection Agency (EPA) on Thursday issued finalized recommendations to smog-afflicted states for controlling volatile organic compound (VOC) emissions from oil/natural gas equipment. The guidelines -- not rules -- would apply to more wells than an earlier draft.
In the finalized Control Technique Guidelines [CTG] for the Oil and Natural Gas Industry, wells that produce less than 15 boe per year are now included. Such "low-producing" wells were not included in the earlier guidance. Environmentalists cheered the move while the oil and natural gas industry was critical.
CTGs are not regulations and do not impose legal requirements directly on pollution sources; rather, they provide recommendations for state and local air agencies to consider as they determine what emissions limits to apply to covered sources in their jurisdictions to meet federal requirements, EPA said.
Clean Air Task Force's Conrad Schneider, advocacy director, said, "...low-producing wells can have substantial emissions… It's critical that EPA move forward swiftly to close this loophole and ensure the guidelines provide comprehensive protection for communities across the country."
However, the American Petroleum Institute (API) said EPA and the states "should not pile on additional guidelines and regulations" until the agency completes its Oil and Gas Information Collection Request (ICR) and then analyses the data collected [see Daily GPI, Aug. 3].
"Moving forward with these guidelines without robust data could impose unachievable emission-reduction requirements on the industry..." said API's Howard Feldman, director of regulatory and scientific affairs. "Air quality has already improved dramatically over the past two decades and will continue to improve as the industry continues to deploy innovative technologies and the EPA and states implement existing standards, which are the most stringent ever...
"In light of current and proposed state and federal regulations that address existing sources, it is better to allow completion of the ICR to inform whether CTGs are warranted and avoid the risks that acting on insufficient scientific data and conflicting guidelines could impose on the American public. If the EPA fails to follow the science, we call on Congress to avoid potential barriers to American economic and environmental progress."
The CTG covers certain sources of VOC emissions in onshore production and processing (i.e., pneumatic controllers, pneumatic pumps, compressors, equipment leaks, fugitive emissions) and storage vessel VOC emissions in all segments (except distribution) of the oil and natural gas industry, according to the document. "These sources were selected for RACT [reasonably available control technology] because current information indicates that they are significant sources of VOC emissions."
States to which the guidelines apply are in the "Ozone Transport Region" and are Connecticut, Delaware, Maine, Maryland, Massachusetts, New Hampshire, New Jersey, New York, Pennsylvania, Rhode Island, Vermont and the consolidated metropolitan statistical area that includes the District of Columbia.