October 28, 2016
Control Techniques Guidelines (CTG) for the Oil and Natural Gas Industry
POSTED BYKen Kirk, P.G.
On Oct. 20, 2016, U.S. Environmental Protection Agency (EPA) issued guidelines for reducing volatile organic compound (VOC) emissions from existing oil and natural gas equipment. These guidelines are referred to as “Control Techniques Guidelines (CTG) for the Oil and Natural Gas Industry“. EPA states “CTGs are not regulations and do not impose legal requirements on sources; rather, provide recommendations for state and local air agencies to consider in determining reasonably available control technology (“RACT”) for reducing emissions from covered processes and equipment”. EPA defines RACT as “the lowest emission limitation that a particular source is capable of meeting by the application of control technology that is reasonably available considering technological and economic feasibility.”
EPA’s Fact Sheet for the final CTG “estimates VOC emissions would be reduced by about 80,000 tons per year, if all affected states implement the recommendations as outlined in the oil and gas CTGs. According to EPA, “VOCs contribute to the formation of ground-level ozone, or smog, which can harm the respiratory system, aggravate asthma and lung diseases, and is linked to premature death from respiratory causes”. The Fact Sheet further indicates that “EPA did not conduct a regulatory impact analysis for the CTGs, because they are RACT recommendations to the states and are not regulations”; and that “EPA is providing information on the estimated costs of reducing emissions from each type of equipment covered in the guidelines to assist the states in making their RACT determinations.
However, Howard J. Feldman, American Petroleum Institute Senior Director of Regulatory and Scientific Affairs, stated that “EPA and states should not pile on additional guidelines and regulations on the oil and gas industry until EPA completes its Oil and Gas Information Collection Request (ICR) and subsequent analyses”. Mr. Feldman further states that “moving forward with these guidelines without robust data could impose unachievable emission reduction requirements on the industry, while adding potentially significant costs to the American economy, jobs, consumers and the environment”.