EPA issues new guidelines aimed at reducing harmful VOC emissions from oil and gas infrastructure
27 October 2016
On October 20, the US Environmental Protection Agency (EPA) issued new guidelines targeting volatile organic compound (VOC) emissions from existing oil and natural gas equipment and facilities in certain states and areas with the worst ozone problems.
While the agency set standards in 2012 and 2016 for new and modified equipment and activities, the new VOC guidelines address older equipment which account for most of the current air pollution from oil and gas activities.
Under the new Control Techniques Guidelines (CTGs), states that are contributing to ozone problems in other states are responsible for determining which measures constitute reasonably available control technology (RACT). They then must adopt these measures as state regulations, to protect their own and their neighbouring states' residents from ozone-derived smog pollution.
Smog, also known as ground-level ozone, is formed by volatile organic compounds (VOCs) and nitrogen oxides (NOx) interacting in the atmosphere. A recent report by the Clean Air Task Force, ‘Gasping for Breath’, estimated the public health toll from ozone smog linked to oil and gas development at: approximately 750,000 asthma attacks, 500,000 missed days of school, and 2,000 asthma-related emergency rooms visits. These impacts are not limited to communities immediately surrounding oil and gas fields, but are also seen in places like Chicago and New York due to the regional nature of ozone pollution.
The new EPA guidelines do not cover low-producing wells, i.e. those that produce less than 15 barrel equivalents per day, but instead call on states to address emissions from these based on site-specific data on a voluntary basis. Environmental groups, while welcoming the overall guidelines, have been critical of this exemption.
This follows a move by EPA in September to update to the Cross-State Air Pollution Rule, created under the Clean Air Act and was finalised in 2011.
This reduces sulphur dioxide and oxides of nitrogen pollution emitted from coal-fired power plants across the eastern states. Those emissions, and the resulting particulate pollution and ozone — more commonly known as soot and smog — drift across the borders of those states and can contribute to dangerous levels of pollution in downwind states. The Supreme Court upheld the Cross-State Air Pollution Rule in April of 2014.
The background to this is increasing opposition in some states to pollution blowing across their borders from others where emissions regulation and enforcement is more lax.
In early October, for example, New York and five other north eastern US states started a lawsuit against the Environmental Protection Agency over enforcement of smog standards on nine upwind states, ranging as far west as Illinois and as far south as North Carolina.
Eleven north eastern states - Connecticut, Delaware, Maine, Maryland, Massachusetts, New Hampshire, New Jersey, New York, Pennsylvania, Rhode Island, Vermont and the District of Columbia - are part of an "Ozone Transport Region" under the Clean Air Act, a designation that calls on the group of states to work together on smog-reduction policies.
Led by New York State Attorney General Eric Schneiderman, a coalition of those states - including Connecticut, Massachusetts, New Hampshire, New York, Rhode Island, and Vermont - is now seeking to extend the Ozone Region designation to upwind states that contribute "dangerous ground-level ozone" pollution to states downwind, Schneiderman's office said after filing the suit in a US District Court.
The upwind states that the coalition seeks to add to the Ozone Region include Illinois, Indiana, Kentucky, Michigan, North Carolina, Ohio, Tennessee, Virginia and West Virginia.