Pennsylvania Proposed Oil & Gas VOC Control Rules
May 2, 2019

On December 12, 2018, the Pennsylvania Department of Environmental Protection (PADEP) proposed air quality rules that would affect VOC emissions from existing oil and gas (O&G) facilities. The proposed rules are used comply with the USEPA’s Control Techniques Guidelines for the Oil and Natural Gas Industry (CTG) published in October 2016. The CTG document guides States in how to comply with VOC Reasonably Available Control Technology (RACT) requirements for ozone nonattainment areas and Ozone Transport Region (OTR). Pennsylvania is located in the northeast States OTR. These VOC RACT requirements would apply to existing O&G facilities that are not affected by the NSPS OOOO and OOOOa. The rules can also apply to NSPS OOOO and OOOOa sources since the States can be more stringent than federal requirements.

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In June 2017, the USEPA announced it had granted a reconsideration of parts of the October 2016 CTG for the O&G Industry document. At this time, the CTG document has not been rescinded or modified.

The proposed rules can be found at: PA DEP Proposed O&G VOC Air Rules. This be an amendment of PA Code Title 25, Part I, Subpart C, Chapter 129. Standards for Sources.

The proposed RACT regulations by the PADEP would attain equivalent or greater VOC reductions than the comparable CTG requirement. For storage tanks and fugitive equipment leaks, the proposed VOC RACT requirements are more stringent than the CTG document; for other sources, the proposed VOC RACT requirements are the same.

The PADEP proposed VOC RACT rules have a definition of existing sources that overlap with NSPS OOOO and OOOOa rules. NSPS OOOO applies to new facilities/equipment constructed, modified or reconstructed after August 23, 2011; NSPS OOOOa applies to new facilities constructed, modified or reconstructed after September 18, 2015. Facilities installed before these NSPS applicability dates are considered existing sources by NSPS OOOO/OOOOa are exempt from the NSPS requirements. The proposed VOC RACT rules will apply to facilities and equipment in existence on or before the effective date of the VOC RACT rules.

Below is a summary of the rules that would affect existing O&G facilities – including those currently required to comply with NSPS OOOO and OOOOa.

 

Emission Source Well/Facility Type Install date PADEP Proposed RACT
Oil and produced water storage tanks Conventional well sites No applicable (N/A) install date If PTE greater than or equal to 6 TPY VOC require 95% VOC reduction unless uncontrolled emissions less than 4 TPY for 12 consecutive months.
Oil and produced water storage tanks Unconventional well site at wellsites Prior to 8-10-2013 If PTE greater than or equal to 6 TPY VOC require 95% VOC reduction unless uncontrolled emissions less than 4 TPY for 12 consecutive months.
Oil and produced water storage tanks Unconventional well sites On or after 8-10-2013 If PTE greater than or equal to 2.7 TPY VOC then require 95% VOC reduction unless actual VOC emissions without control are less than 2.7 TPY on a 12-month rolling basis.
Oil and produced water storage tanks Natural gas (NG) gathering and boosting stations or NG plant or NG transmission and NG storage sites N/A install date If PTE greater than or equal to 2.7 TPY VOC then require 95% VOC reduction unless actual VOC emissions without control are less than 2.7 TPY on a 12-month rolling basis.
Fugitive Leaks Well sites with wells with gas-to-oil ratio (GOR) >300 that produce 15 barrels of oil eq. (BOE) per day N/A install date 1. Monthly audio, visual, olfactory (AVO) inspection.
2. Quarterly LDAR
3. Semiannual LDAR if <2% leakers in any 2 consecutive quarterly inspections.
Fugitive Leaks Natural gas (NG) gathering and boosting stations or NG plant or NG transmission and NG storage sites or oil pipeline. N/A install date 1. Monthly audio, visual, olfactory (AVO) inspection.
2. Quarterly LDAR
Pneumatic controllers Well site & NG gathering & boosting stations N/A install date Natural gas bleed rate equal to or less than 6 scfh. Some exemptions apply.
Pneumatic controllers NG processing plants N/A install date Natural gas bleed rate of zero scfh.
Some exemptions apply.
Diaphragm pumps Well site and NG gathering and boosting stations N/A install date 1. Route pump discharge to an existing onsite control device/ process.
2. 95% control unless existing control/process cannot achieve 95%.
3. Maintain records if no existing control at location.
Diaphragm pumps NG processing plants N/A install date Zero VOC emissions.
Recip Compressor Between wellhead and point of lease custody transfer N/A install date Replace rod packing seals every 26,000 hr or 36 months of operation.
Recip Compressor Well site N/A install date Not covered by RACT.
Centrifugal Compressor Between wellhead and point of lease custody transfer N/A install date Reduce VOC emission by 95% from wet seal fluid gassing system.
Centrifugal Compressor Well site N/A install date Not covered by RACT.


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HY-BON/EDI’s Complete Solution

HY-BON/EDI’s engineered enclosed vapor combustion units (VCU) are used by operators to reduce venting emissions as required by NSPS OOOO/OOOOa and State air quality regulations. Also, our IQR and Leak Detection and Repair (LDAR) services help operators comply with State and federal leak monitoring. Our LDAR services meet the requirements of EPA’s NSPS OOOOa and greenhouse gas reporting rules in 40 CFR 98 Subpart W.