Haynes and Boone looks at new EPA guidelines
The U.S. Environmental Protection Agency has published new final Control Techniques Guidelines (CTGs) targeting volatile organic compound emissions from existing oil and natural gas equipment and processes in certain states and nonattainment areas.
The agency looked at all the points where it found that emissions can occur throughout the oil and natural gas industry. Primarily, these emissions are organic compounds such as methane, ethane, VOC, and organic hazardous air pollutants (HAP), the agency said.
The goal is to meet EPA’s national standards for ground-level ozone. Although the CTGs are not regulations and do not impose legal requirements directly on pollution sources, they do provide recommendations that states and affected areas may adopt in implementing required emissions controls for those sources by January 2021, energy attorneys Haynes and Boone said in a press release.
The final CTGs are one of a series of steps that EPA has taken to reduce VOCs, methane, and other air pollutants from the oil and natural gas industry. These guidelines cover select sources of VOC emissions in the onshore production and processing segments of the oil and natural gas industry and storage vessel VOC emissions in all segments of the industry, except for downstream natural gas distribution systems. The EPA also provided recommendations for reducing VOC leaks at production gathering and boosting stations and at oil and natural gas well sites, Haynes and Boone said.
The CTGs will become effective upon publication in the Federal Register. Haynes and Boone’s expert counsel in these and other EPA guidelines, regulations and environmental requirements applicable to the oil and gas industry are Christopher J. Reagen , Suzanne Beaudette Murray , Robert (Bob) P. Thibault , Jeff Civins , James D. Braddock.
The EPA guideline document published in Oct. 2016 may be downloaded here.
