Products & Services
Catalytic Products International eNews - April 2012
Natural Gas Rules Finalized
Richard Trzupek, Principal Consultant, Mostardi Platt Environmental
On April 17 EPA published final rules covering the natural gas industry. These rules, which we’ve been following closely in the past months, affect well-head operations, transmission, storage, and natural gas processing. The target has been reductions in emissions of both Volatile Organic Compounds (VOC) and methane. View our revised white paper outlining the final regulations.
Perhaps the most controversial and expensive part of the rule was a requirement to utilize “green completions” whenever feasible. Recognizing that the equipment required for green completions is not yet available in sufficient quantity for the entire industry to utilize the technique EPA extended the compliance date with this portion of the rule to January 1, 2015. Other control techniques, such as traditional pit flaring will be allowed after the compliance date, but only in cases where safety consideration or other technical difficulties make green completions infeasible to accomplish.
While flaring will be allowed, EPA also specifies that flares must be at least 95 percent efficient. Recent tests by the Agency in the refinery sector suggest that many flares may not meet this destruction requirement and that EPA may require proof of a flare’s efficiency with respect to VOC control. On the plus side for the industry, EPA modified the definition of a green completion to focus on performance, rather than specific equipment requirements. This will allow for cost-effective innovation in the industry going forward.
EPA also decided not to finalize requirements for compressors and pneumatic controllers in the transmission segment of the industry. The Agency received a large number of comments about the feasibility of meeting these requirements, as well as the cost-effectiveness of the reductions that would be achieved. By delaying implementation of these requirements, EPA acknowledged that it needs to gather more information before it can issue rules that make sense for both the industry and the environment.
Despite some of the favorable changes, these rules will have far-reaching effects in the natural gas industry, including:
- More stringent controls of the tail-gas from sulfur recovery units
- Control of VOC emissions from more dehydration units
- Control of VOC emissions from more liquids storage tanks
- Additional Leak Detection and Repair (LDAR) requirements
- More stringent requirements for excess emissions events that occur during start up, shut down and malfunctions
Issuances of these rules are the result of lawsuits initiated by environmental groups. Assuming that neither those groups nor industry groups challenge these rules, EPA will begin the long process of ensuring compliance almost immediately.
Recently, a contract drug manufacturing company faced violation of their state operating permit, costly fines, and potential Title V permit classification. To avoid penalties, a more robust abatement device had to be installed; one that met the necessary emissions standards for volatile organic compounds (VOCs).
The pharmaceutical industry faces unique challenges in complying with environmental pollution and emission control regulations.
Check out this recent feature article highlighting the following three pharmaceutical process case studies:
- Fluidized bed drying
- Tablet coating and reaction vessels
- Batch operations
Download: EPA Eyes Flare Operations White Paper
Industry is looking for new fuels that can replace coal, oil and natural gas. This free white paper takes a look at some of the technical and regulatory challenges involved in developing alternative fuel projects.
Our goal at CPI is to not only help you reduce your air pollutant emissions in the smartest way possible, but to also be a resource for you. If you have questions you can submit your thoughts on our frequently asked questions page, or contact us directly with your comments.