EPA Finalizes Control Techniques Guidelines (CTG) for Existing Sources in the Oil and Natural Gas Industry

On October 20, 2016, the U.S Environmental Protection Agency (EPA) released its Control Techniques Guidelines (CTG) for the Oil and Natural Gas Industry.  The CTG provide recommendations to reduce volatile organic compound (VOC) emissions from existing sources in the onshore production and processing segments such as storage vessels, pneumatic controllers, pneumatic pumps, centrifugal and reciprocating compressors, equipment leaks, and fugitive emissions.

The CTG is not a regulation itself, but rather provides guidelines for air agencies with areas that are not meeting the ozone National Ambient Air Quality Standards (NAAQS) including nonattainment areas classified as "moderate" or higher as well as states within the ozone transport region.  States with affected areas must employ Reasonable Available Control Technology (RACT) to limit VOC emissions from existing sources covered by a CTG.  State Implementation Plans (SIP) must be updated within two years of October 20, 2016 to include the oil and gas CTG or other equivalent RACT requirements.

EPA's CTGs for each source are summarized below:

  • Storage Vessels with potential to emit ≥ 6 tpy VOC:  Reduce 95% of VOC emissions or demonstrate actual VOC emissions are less than 4 tpy uncontrolled.
  • Pneumatic Controller:  Natural gas bleed rate of 0 scfh (for natural gas processing plant).  Natural gas bleed rate of ≤ 6 scfh (for controllers located from the wellhead to the processing plant or to the point of custody transfer to pipeline) with some exceptions for functional needs.
  • Pneumatic Pumps:  Zero VOC emissions (for natural gas processing plant).  For well sites, route VOC emissions to an existing onsite control device/process to achieve 95% control (maintain records if existing device cannot achieve 95% control) or maintain records if there is no existing control.
  • Reciprocating Compressors:  Replace reciprocating compressor rod packing on or before 26,000 hours of operation or every 36 months.  Alternately, route rod packing emissions to a process through a closed vent system under negative pressure.  Applies to compressors located between the wellhead and point of custody transfer to the natural gas transmission and storage segment.
  • Centrifugal Compressors (wet seals):  Reduce 95% of VOC emissions for each centrifugal compressor wet seal fluid gassing system.  Applies to compressors located between the wellhead and point of custody transfer to the natural gas transmission and storage segment.
  • Equipment Leaks (processing plants):  Implement 40 CFR part 60, Subpart VVa leak detection and repair (LDAR) program.
  • Fugitive Emissions:  For well sites with GOR ≥ 300 that produce > 15 barrel of oil equivalents per day and gathering & boosting stations from wellhead to point of custody transfer.  Incorporate a semiannual (well sites) or quarterly (gathering and boosting stations) OGI monitoring and repair plan.

Note that EPA is expected to designate new ozone nonattainment areas based on the 2015 Ozone NAAQS by October 2017 which could potentially require more states to implement RACT.

EPA's Control Techniques Guidelines can be found here.

To learn more about the potential impact to your facility, call Tom Muscenti (724-935-2611) in our Pittsburgh office, or Wendy Merz (610-648-3858) in our Philadelphia office.