WILL ALLISON AIR POLLUTION CONTROL DIVISION APRIL 16, 2012 Oil and Natural Gas Air Pollution Standards

EPA’s Proposed NSPS for oil and gas Scheduled to be finalized April 17 th Four regulations applying to oil and gas industry: 1) NSPS for VOCs; 2) NSPS for SO2; 3) air toxics standard for oil and gas production; and 4) air toxics standard for transmission and storage of oil and gas

Rules Affected NSPS KKK  Standards of Performance for Equipment Leaks of VOC from Onshore Natural Gas Processing Plants for which Construction, Reconstruction, or Modification Commenced After January 20, 1984, and On or Before August 23, 2011, 40 C.F.R. Part 60, Subpart KKK NSPS LLL  Standards of Performance for SO2 Emissions from Onshore Natural Gas Processing Plants for which Construction, Reconstruction, or Modification Commenced After January 20, 1984, and On or Before August 23, 2011, 40 C.F.R. Part 60, Subpart LLL NSPS OOOO  Standards of Performance for Crude Oil and Natural Gas Production, Transmission, and Distribution, 40 C.F.R. Part 60, Subpart OOOO MACT HH  National Emissions Standards for Hazardous Air Pollutants from Oil and Natural Gas Production Facilities, 40 C.F.R. Part 63, Subpart HH MACT HHH  National Emissions Standards for Hazardous Air Pollutants from Natural Gas Transmission and Storage Facilities, 40 C.F.R. Part 63, Subpart HHH

NSPS Review Current NSPS KKK and LLL only cover natural gas processing plants Proposed NSPS OOOO:  Strengthens requirements for equipment leaks at natural gas processing plants; and  Covers previously unregulated sources such as:  Well completions and recompletions  Compressors  Pneumatic Controllers  Storage Vessels (i.e. condensate and crude oil tanks)

MACT Review Current MACT HH and HHH cover:  Most glycol dehydrators at major and area sources, down to a 1 tpy benzene threshold  Storage tanks with the potential for flash emissions  Equipment leaks Proposed revisions:  Establish limits for all glycol dehydrators at major sources, regardless of benzene emission levels  Include all storage tanks, regardless of potential for flash emissions

Colorado Comments Specific Issues  Delegation and Distribution of Authority to State Agencies  Split Delegation or Other Alternative?  Increase in burden on regulating agencies  Green Completions Criteria  Clarifications on when green completion may not be feasible  Include oil AND gas wells in green completion requirements  Re-fracturing and initial completion should be included in requirements  Storage Vessel Modification  Fracturing or re-fracturing a well should be a considered a modification for the storage tank

Colorado Comments Other Emission Sources  Amine Units  Produced and Flowback Water Storage, Treatment and Evaporation  Pneumatic Pumps  Pigging Activities Tracking and Reporting Burden Technical Reconsiderations Rule Clarifications

WILL ALLISON CDPHE – APCD