• EQC Considers Proposed Emissions Standards for Existing Oil and Gas Operations in the Upper Green River Basin
  • April 15, 2015
  • Law Firm: Holland Hart LLP - Denver Office
  • The draft emissions standards for oil and gas operations in the Upper Green River Basin ozone nonattainment area are slated for consideration by the Environmental Quality Council (EQC) on May 19, 2015. The rules, developed and approved by the Wyoming Department of Environmental Quality, Air Quality Division (AQD) in December of 2014, target volatile organic compound (VOC) emissions from oil and gas production facilities and compressor stations existing as of January 1, 2014 that are located within the nonattainment area.

    The rules target flash emissions from tanks, and emissions from dehydration units, leaks from pneumatic pumps and pneumatic controllers, and fugitive emissions. The proposed controls are as follows:
    • Storage tanks and dehydration units with VOC emissions in excess of 4 tons per year must install controls resulting in a 98% destruction efficiency by January 2017.
    • Existing pneumatic pumps must ensure a 98% efficiency, or the pump discharge streams must be routed into a sales or collection line or other closed-loop system.
    • Existing pneumatic controllers must use low (less than 6 standard cubic feet per hour) or zero bleed controls, or the discharge streams must be routed into a sales or collection line or other closed-loop system.
    • Single well facilities and compressor stations with fugitive emissions greater than 4 tpy of VOCs (including HAP components) must develop and implement a Leak Detection and Repair (LDAR) protocol by January 1, 2017.
    In addition, the proposed rules provide for comprehensive monitoring, recordkeeping, and reporting.

    The written comment period for these rules closes on April 13, 2015.