Proposed Air Emission Rules For Oil And Gas Drilling Operations

The U.S. Environmental Protection Agency (EPA) has proposed standards to reduce regulated air emissions from oil and gas drilling operations. These proposed updated standards, issued in response to a court order, would rely on existing technologies to reduce emissions. The proposal would cut volatile organic compound (VOC) emissions from several types of processes and equipment used in the oil and gas industry, including a 95% reduction in VOCs emitted during the completion of new and modified hydraulically fractured wells.

EPA’s analysis of the proposed changes, which also include requirements for storage tanks and other equipment, estimates a net savings to the industry of $10s of millions annually from the value of natural gas that would no longer escape to the air. The proposal includes reviews of four air regulations for the oil and natural gas industry as required by the Clean Air Act: a new source performance standard for VOCs from equipment leaks at gas processing plants; a new source performance standard for sulfur dioxide emissions from gas processing plants; an air toxics standard for oil and natural gas production; and an air toxics standard for natural gas transmission and storage.

EPA is under a consent decree requiring the agency to sign a proposal by July 28, 2011 and take final action by Feb. 28, 2012. As part of the public comment period, EPA will hold three public hearings, in the Dallas, Denver and Pittsburgh areas.

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EPA Proposes Combining NESHAP and NSPS For Several Chemical Sectors

EPA is proposing to combine regulatory requirements under several chemical sectors into a single sector. The chemical sector is focused on the production of synthetic organic chemicals and their intermediates, which consists of many of the North American Industry Classification System codes beginning with "325".

This sector emits hazardous air pollutants such as methanol, butadiene, and benzene, and criteria air pollutants, such as sulfur dioxide, carbon monoxide, nitrogen oxides, and volatile organic compounds. The sector is subject to 14 different National Emission Standards for Hazardous Air Pollutants (NESHAP) and six different New Source Performance Standards (NSPS). Under this proposed action, EPA will consolidate these rules into a single chemical sector NESHAP that will address air toxics and a single chemical sector NSPS that will address criteria pollutants. Uniform standards (for heat exchangers, equipment leaks, storage vessels and transfer operations, control devices and closed-vent systems, and wastewater) are being developed in separate actions and will specify the work practices, equipment standards, and proper monitoring, recordkeeping, and reporting requirements. The regulatory text for the chemical sector NESHAP and NSPS are expected to reference the uniform standards, which will ensure that requirements are consistent across the chemical sector.

In the chemical sector NESHAP, EPA proposes to consolidate the NESHAP for Hazardous Organic Chemicals (HON, subparts F-I), Miscellaneous Organic Chemicals (MON, subpart FFFF), Ethylene (subparts XX and YY), Organic Liquids Distribution (OLD, subpart EEEE), Pesticide Active Ingredients (PAI, subpart MMM), Polyether Polyols (PEPOs, subpart PPP), Group IV Polymers and Resins (P&R IV, subpart JJJ), and Vinyl Chloride (part 61 subpart F) and revise these rules to address unregulated and under-regulated emission points under Maximum Achievable Technology (MACT) or technology review for these categories. At the same time, EPA will also perform a residual risk review for the MON, Ethylene, OLD, PAI, PEPOs, and P&R IV.

EPA is currently evaluating emissions from Vinyl Chloride facilities (currently covered by the HON and the Vinyl Chloride NESHAP) to see if additional emissions limitations are needed for combustion of chlorinated organic compounds. Similarly, the agency plans to review the six chemical sector NSPS and consolidate these requirements into a single sector NSPS and expand the scope of the rule, as necessary, to include additional emissions sources and limitations.

At the present time, EPA anticipates publishing a Notification of Proposed Rule Making in the Federal Register in December 2011.

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New SNUR Reporting For Glymes In Consumer Products

The U.S. Environmental Protection Agency is proposing to require companies report new uses of chemicals known as glymes in consumer products. EPA’s proposed action is based in part on the agency’s concerns that additional uses of these 14 chemicals in consumer products could lead to harmful reproductive and developmental health effects. Glymes are chemicals used in a wide array of applications including printing ink, paints and coatings, adhesives, household batteries and motor vehicle brake systems.

The proposed regulatory procedure is known as a significant new use rule (SNUR) under the Toxic Substances Control Act. The SNUR is intended to ensure that, prior to the manufacture, import, or processing of these chemicals for a significant new use, EPA will have 90 days to evaluate potential risks, and prohibit or limit the activity if warranted.

Comments on the proposed SNUR must be received on or before September 9, 2011.

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New “Most Efficient” Consumer Product Designation

U.S. Department of Energy (DOE) and U.S. Environmental Protection Agency (EPA) have announced a new product recognition label for the most energy-efficient products in their category. The new designation of “Most Efficient” aims to provide all manufacturers with an incentive for greater product energy efficiency while providing consumers new information about the products that comprise the top tier in the categories.

Products that receive the Most Efficient designation demonstrate exceptional efficiency performance. The Most Efficient recognition will represent approximately the top 5% of models on the market in the following categories: clothes washers, heating and cooling equipment, televisions, and refrigerator-freezers.

Consumers will be able to identify Most Efficient products on the Energy Star website and in stores by looking for the Most Efficient designation. In addition to meeting established performance requirements, products must also be Energy Star qualified and certified by an EPA-recognized certification body. EPA is encouraging manufacturers to submit products that meet the requirements for recognition.

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Secondary Air Quality Standards For Nitrogen Oxides And Sulfur Oxides

U.S. Environmental Protection Agency (EPA) is proposing secondary air quality standards for nitrogen oxides (NOx) and sulfur oxides (SOx). The new standards would be identical to the public health standards finalized in 2010. EPA is proposing to retain the existing secondary standards for each pollutant.

EPA will accept comments for 60 days after the proposed rule is published in the Federal Register and will issue a final rule by March 2012.

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Proposed Changes To Hazardous Waste Recycling Requirements

The U.S. Environmental Protection Agency (EPA) has proposed new safeguards for recycling hazardous materials to protect public health and the environment. The proposed rule modifies EPA’s 2008 Definition of Solid Waste (DSW) rule, which revised hazardous waste regulations to encourage recycling of hazardous materials. The proposed rule is intended to improve accountability and oversight of hazardous materials recycling, while allowing f flexibility that will promote its economic and environmental benefits.

EPA is also releasing for public comment its draft expanded environmental justice analysis of the 2008 DSW final rule, which evaluates the rule’s potential impact on low-income and minority communities. EPA is also requesting public comment on the environmental justice analysis as well as on suggested changes received from peer review. The analysis and peer review comments will be available in the docket for this rulemaking once the proposal is published.

EPA’s re-examination of the 2008 DSW final rule identified areas in the regulations that could be improved to better protect public health and the environment with a particular focus on adjacent communities by ensuring better management of hazardous waste. The proposed rule includes provisions to address those areas through increased transparency and oversight and accountability for hazardous materials recycling. Facilities that recycle onsite or within the same company under the reduced regulatory requirements retained under the proposal would be subject to enhanced storage and recordkeeping requirements as compared to the 2008 rule. Companies that send their hazardous materials offsite for recycling would have tailored storage standards, while being required to send their materials to a permitted hazardous waste recycling facility. The proposed rule requires all forms of hazardous waste recycling to meet requirements designed to ensure materials are legitimately recycled and not being disposed of illegally.

EPA will accept comment on this proposal for 60 days after publication in the Federal Register.

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Proposed Expansion of TRI Reporting Industry Sectors

EPA has announced a proposed rule would expand the scope of industry sectors covered by Emergency Planning and Community Right-to-Know Act (EPCRA) section 313, also known as the Toxics Release Inventory (TRI).

As originally enacted, EPCRA 313 applied only to the manufacturing industry sectors. The statute, however, also allows the EPA Administrator to add sectors to TRI to the extent that doing so is relevant to the purposes of EPCRA 313. Under this authority, the EPA in 1997 added seven additional industry sectors to the list of sectors covered by TRI. The current proposed rule would add or expand coverage to the following industry sectors:

• Iron Ore Mining,



• Phosphate Mining,



• Municipal Waste Incineration,



• Industrial Dry Cleaning,



• Petroleum Bulk Storage, and



• Steam-Only Production from Fossil Fuels.

EPA currently expects to publish a Notice of Proposed Rule Making (NPRM) in the Federal Register around December 2012.

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