March 27, 2019
On December 13, 2018 Pennsylvania’s Department of Environmental Protection (DEP) posted proposed rules for cutting smog-forming compounds based on Obama-era Environmental Protection Agency (EPA) Control Technique Guidelines (CTGs) for the oil and natural gas industry that the Trump administration EPA has proposed to withdraw.
As reported in the January 2019 MIRATECH Emissions Monitor, Pennsylvania’s proposal is designed to curb direct emissions and leaks of volatile organic compounds from older well sites, storage tanks and other oil and gas facilities that aren’t covered by air pollution rules that DEP adopted earlier this year.
Pennsylvania’s proposed rules are part of Governor Tom Wolfe’s Methane Reduction Strategy which sets an implementation date for January 1, 2021. It appears Pennsylvania has no plans to abandon these efforts, or any element of the Governor’s Methane Reduction Strategy, even if the U.S. EPA withdraws its CTGs. DEP has indicated it intends to move ahead with a proposed rule in any event because of regional commitments to meet federal ozone standards.
At its March 21, 2019 scheduled meeting with its Oil and Gas Technical Advisory Board (TAB) DEP further discussed and reviewed its draft proposal of Reasonably Available Control Technology (RACT) regulations covering volatile organic compound (VOC) emissions with a “co-benefit” of reducing methane emissions from existing oil and gas operations.
In DEP’s March 21st presentation to its Advisory Board, DEP covered the following items:
- Reviewed the background of EPA Control Technique Guidelines as well as Reasonably Available Control Technologies (RACT).
- Reviewed the history of Obama era EPA’s CTG Guidelines for the Oil & Gas Industry and the Trump EPA’s request to withdraw the Obama CTG Guidelines.
- Advised its board that, “Despite EPA’s proposed withdrawal of the CTG, DEP intends to develop the regulations for existing sources at natural gas and oil facilities with due consideration to the proposed changes.”
- Stated DEP’s regulation will affect the following sources of VOC emissions in the oil and natural gas industry that were in existence on or before the effective date of adoption of the regulation: Storage vessels, Natural gas-driven pneumatic controllers, Natural gas-driven diaphragm pumps, Compressors (Centrifugal and Reciprocating), and Fugitive emissions components.
What this means to you
At its March 21st meeting with its Oil & Gas Technical Advisory Board, Pennsylvania DEP said, despite EPA’s proposed withdrawal of the CTG, it intends to develop regulations for existing sources at natural gas and oil facilities.
MIRATECH can help
Contact MIRATECH for stationary engine emissions solutions in Pennsylvania’s oil and gas industry.