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Federal and State Permitting Standards, Rules, and Compliance -
Air quality permits issued by the Division of Air Quality (DAQ) for oil and gas operations contain requirements that reduce emissions that lead to the formation of ozone. Oil and gas production accounts for 97 percent of the manmade volatile organic compound (VOC) emissions in the Uinta Basin, but new federal standards, state rules, and permit requirements for tribal lands will help decrease ozone concentrations caused by emissions from these operations.
Federal Standards and Rules
Recent federal rulemaking for the oil and gas industry updated standards set in 1985, requiring a phased-in capture of natural gas from gas wells and establishing requirements for equipment that could vent or leak VOCs. A new permitting rule for minor source oil and gas operations in Indian Country will ultimately reduce emissions in areas outside the jurisdiction of state regulatory authorities.
Environmental Protection Agency (EPA) Air Rules for the Oil and Natural Gas Industry
On August 16, 2012, the EPA issued regulations to reduce air pollution from the oil and natural gas industry. A key component of these rules is the use of “green completions” to capture natural gas currently released into the air. It is expected that these green completions will yield a nearly 95 percent reduction in VOCs from hydraulically fractured wells. The rules also include VOC emission reductions from storage tanks and other production equipment. Included in the regulations are New Source Performance Standards (NSPS) for VOCs, NSPS for sulfur dioxide (SO2), an air toxics standard for major sources of oil and natural gas production, and an air toxics standard for major sources of natural gas transmission and storage.
Recent standard changes for equipment in the oil and gas sector will also provide substantial emission reductions in the Uinta Basin. National Environmental Standards for Hazardous Air Pollutants (NESHAPS) regulations establishing standards for new and modified reciprocating internal combustion engines (RICE) at oil and gas sources will significantly lower emissions, particularly from VOC sources. In addition, New Source Performance Standards (NSPS) standards for compression ignition engines and spark ignition engines will regulate VOC and nitrogen oxides (NOx) emissions from these engines.
EPA Minor New Source Review for Oil and Gas Production Facilities in Indian Country
On July 1, 2011, the EPA issued the Indian Country Minor New Source Review (NSR) rule requiring pre-construction permits for new and modified stationary sources (minor sources) and minor modifications at existing major stationary sources (major sources). Since a significant portion of oil and gas development in the Basin is located in Indian Country, these rules could potentially have a major role in reducing ozone-producing emissions.
On May 22, 2014, the EPA extended the permitting and registrations deadline in the rule. The agency has proposed rulemaking to streamline the minor source permitting process. Permit options include the following alternatives:
- General Permit
- Federal Implementation Plan (FIP)
High ozone levels in the Basin prompted DAQ to examine the emissions impact of permitted new sources and develop emission reduction strategies at existing sources.
New or modified sources that emit pollutants must obtain an Approval Order (AO) prior to beginning construction. These AOs may include emissions limits on construction and operation activities. The required BACT analysis for new or modified sources ensures that the permitted activity uses state-of-the-art pollution control devices to control the precursor emissions, particularly VOCs, which lead to the formation of ozone. The AO also ensures that the new or modified source will comply with the National Ambient Air Quality Standards (NAAQS).
General Approval Order (GAO)
A General Approval Order (GAO) is an alternative to the normal Approval Order (AO) and establishes general conditions for:
- similar new or modified sources within a source category; and,
- specific types of equipment.
Oil and gas operations operating utilizing a general permit would need to meet all requirements under existing rules, including application of Best Available Control Technology (BACT) and a representative impact analysis. The rule requires review of the GAO at least once every three years to ensure periodic opportunities for public review and comment.
The GAO for crude oil and natural gas well site and tank batteries covers facilities that process up to 50,000 barrels of crude oil and condensate (gaseous vapors) combined over a rolling 12-month period. Conditions in the GAO reflect a modeling analysis for nitrogen dioxide (NO2) emissions and ensure protection of the National Ambient Air Quality Standards (NAAQS). Emission controls and equipment specifications limit criteria pollutant and hazardous air pollutant (HAP) emissions. If a source cannot meet the requirements in this GAO, it must submit a Notice of Intent (NOI) and obtain an Approval Order.
DAQ wants to ensure that existing oil and gas production sources control emissions adequately. Much of the emissions in the Basin come from this older equipment. The Air Quality Board recently finalized four rules that establish the following requirements:
- General provisions to ensure that equipment is operated in a manner that minimizes VOC emissions.
- Requirement to replace existing high-bleed pneumatic controllers with low-bleed controllers.
- Requirement to install self-igniters on flares.
- Requirement to use bottom filling or submerged filling when loading product into tanker trucks.
Additional rules are under development to achieve further emission reductions from older equipment that does not meet current control technology standards:
Existing Source Compliance Action
DAQ ensures that oil and gas operations meet regulatory requirements under their permits through inspections, audits, and enforcement actions. DAQ is currently teaming with the Utah Division of Oil, Gas, and Mining (DOGM) to compare DOGM production data with air quality permits to verify that oil and gas operations in the Uinta Basin have obtained the necessary DAQ permits.