On December 10, 2022, the Pennsylvania Department of Environmental Protection (PADEP) published its latest regulation for the oil and gas industry. The short title for this new rule is “Control of VOC [Volatile Organic Compound] Emissions from Conventional Oil and Natural Gas Sources” (VOC Rule), but what it aims to do is require existing facilities, particularly ones that were built before the department’s existing rules were in effect, to reduce their emissions from certain equipment. PADEP has rules currently in place for oil and gas facilities, like the GP-5/5A and Exemption 38, but those regulations only apply to sources built after those rules were published. The VOC Rule applies not only to older shale locations but to conventional well pad facilities.
The VOC Rule specifically lists source categories on the Production, Midstream, and Transmissions sections of the oil and gas industry and requires all sites in Pennsylvania that are currently not meeting or exceeding those standards to do so within a certain timeframe.
The source categories listed in the VOC Rule are:
- Storage tanks
- Reciprocating and centrifugal compressors
- Gas-driven pneumatic controllers
- Gas-driven diaphragm pumps
- Fugitive emissions
These are part of sources that have been called out in federal and Pennsylvania regulations, specifically New Source Performance Standards (NSPS) Subpart OOOO/OOOOa and Exemption 38c. The VOC Rule uses many of the same requirements found in those regulations, and it’s applying them to facilities that previously were exempt.
Storage tanks now must meet the Exemption 38 threshold of 2.7 tons per year per tank of VOCs. This applies to all the segments of the industry previously listed. Operators have until February 8, 2023 to perform the necessary calculations to determine if their tanks exceed that threshold. If they do, operators must either install a 95% control device or a floating roof tank to comply. They have until December 10, 2023 to get the new equipment installed.
Reciprocating compressors, regardless of location, now must either change out the rod packing on the units every 26,000 hours or 36 months of service or route the packing vents to a control device. This is a departure from the NSPS OOOO requirements in that previous wellhead compressors were exempt from this requirement. Centrifugal compressors with wet seals also now must route the vents from those to a control device; however, units located on a well pad are exempt.
Continuous bleed gas-driven pneumatics now must meet the OOOO standard bleed rate of six cubic feet an hour unless you can cite a specific need for a controller with a higher rate for safety or other reasons. Controllers that exceed the bleed rate must be tagged to identify them as such. Gas-driven diaphragm pumps now must route their vent emissions to a control device or recover the gas.
Fugitive emissions, often a sore subject for operators, is a large section of the new VOC Rule. Compressor stations will now have to perform Leak Detection and Repair (LDAR) surveys every quarter as well as a monthly audio, visual, and olfactory (AVO) check. The first surveys will have to be performed by February 8, 2023. For well pads, the frequency of the surveys will depend on the current volume of production. Pads with a well making over 90,000 cubic feet per day (MCFD) will have to perform LDAR surveys every quarter and monthly AVO inspections. Well pads with a well producing more than 30 MCFD and a total pad production of 90 MCFD or greater will have to perform the AVO inspections monthly but only perform LDAR surveys annually.
The final portion of the VOC Rule will require operators to submit an annual report to demonstrate compliance. The first report will be due December 10, 2023, after that the annual report will be due to PADEP before June 1 every year.
CEC has been following the VOC Rule and has already made plans to assist our clients with compliance. If you have any questions regarding the new rule or how it may affect your operations, please contact our experts: