Raven Environmental Consulting, LLC.

Oil and Gas Sources are defined in 18 AAC 50.400(i)(6) as a Title V source that is not a “Large Power Plant” the purpose of which is the exploration for, extraction of, processing of, transportation of, or storage of crude oil, natural gas, or other petroleum products, or related activities, but does not include a petroleum refinery or liquefied natural gas (LNG) plant.

Portable Oil and Gas Operation means an operation that moves from site to site to drill or test one or more oil or gas wells, and that uses drill rigs, equipment associated with drill rigs and drill operations, well test flares, equipment associated with well test flares, camps, or equipment associated with camps; “portable oil and gas operation” does not include well servicing activities; for the purposes of this paragraph, “test” means a test that involves the use of a flare;

There is a different administrative fee structure under 18 AAC 50.400(a)(1)&(5) for an oil-and-gas source with the potential to emit more than 250 tons per year of any one pollutant, or an oil-and-gas source or thermal soil remediation unit source with the potential to emit equal to or greater than 100 and less than 250 tons per year of any one pollutant.

40 CFR 60

Permittees must comply with applicable New Source Performance Standard (NSPS) provisions. NSPS requirements are included in the applicable requirement definition under 40 CFR 71.2, which has been adopted by the Department under 18 AAC 50.040(j)(1).

Typically Oil and Gas Sources are subject to NSPS Subparts: A, Dc, GG, IIII, KKKK, and OOOOa for Reciprocating Internal Combustion Engines (RICE), combustion turbines, steam generating units, and newer oil and gas facilities.

These standards are designed to control air pollution from new, modified, and reconstructed sources in various industries, including oil and gas production. Several NSPS subparts are applicable to this sector, each addressing different aspects of emissions and operational practices. Here, we provide an overview of the relevant NSPS subparts for oil and gas production, including Subparts A, Dc, GG, IIII, KKKK, and OOOOa.

Subpart A: General Provisions

Subpart A outlines the general provisions applicable to all NSPS regulations. It includes requirements for notifications, recordkeeping, performance testing, and monitoring. This subpart sets the framework for compliance and enforcement across all specific subparts, ensuring that sources adhere to the standards set forth by the EPA.

Subpart Dc: Small Industrial-Commercial-Institutional Steam Generating Units

Subpart Dc applies to steam generating units with a heat input capacity between 10 and 100 million British thermal units per hour (MMBtu/hr). While not directly targeting oil and gas production facilities, this subpart is relevant for operations that utilize steam generation for various processes. It establishes standards for emissions of sulfur dioxide (SO2), particulate matter (PM), and nitrogen oxides (NOx).

Subpart GG: Stationary Gas Turbines

Subpart GG governs stationary gas turbines used in oil and gas production. These turbines are commonly employed in natural gas processing plants and compression stations. The subpart sets emission limits for NOx and SO2, as well as requirements for monitoring and reporting emissions. Compliance with Subpart GG ensures that stationary gas turbines operate within the EPA's prescribed limits, reducing their environmental impact.

Subpart IIII: Stationary Compression Ignition Internal Combustion Engines

Subpart IIII applies to stationary compression ignition internal combustion engines, such as diesel engines used in oil and gas production. These engines power equipment like generators and pumps. The subpart specifies emission standards for NOx, carbon monoxide (CO), hydrocarbons (HC), and PM. It also includes requirements for fuel sulfur content, engine certification, and testing procedures.

Subpart KKKK: Stationary Combustion Turbines

Subpart KKKK addresses stationary combustion turbines, including those used in oil and gas production for electricity generation and mechanical drive applications. The subpart establishes emission limits for NOx and SO2, along with requirements for performance testing, monitoring, and reporting. Compliance with Subpart KKKK helps minimize the environmental impact of combustion turbines in the oil and gas sector.

Subpart OOOOa: Crude Oil and Natural Gas Production, Transmission, and Distribution

Subpart OOOOa is specifically tailored to the oil and gas industry, covering crude oil and natural gas production, transmission, and distribution. It includes standards for volatile organic compounds (VOC), greenhouse gases (GHGs), and HAPs. The subpart targets emissions from equipment such as storage tanks, compressors, pneumatic controllers, and fugitive emissions sources. It also mandates leak detection and repair (LDAR) programs, ensuring that facilities promptly identify and address emission leaks.

40 C.F.R. 63

The Alaska Department of Environmental Conservation (ADEC) has incorporated by reference the National Emission Standards for Hazardous Air Pollutants (NESHAP) requirements for specific industrial activities, as listed in 18 AAC 50.040(c). NESHAP Subpart ZZZZ applies to owners and operators of any existing, new, or reconstructed stationary RICE located at major and area sources of Hazardous Air Pollution (HAP) emissions.