Comment of Sierra Club under CP14-119, et. al.

Oil and Natural Gas Sector: Standards of Performance for Crude Oil and Natural Gas Production, Transmission, and Distribution. Background Technical Support Document for Proposed Standards EPA-453/R-11-002 July 2011 Oil and Natural Gas Sector: Standards of Performance for Crude Oil and Natural Gas Production, Transmission, and Distribution. By: EC/R, Incorporated 501 Eastowne Dr, Suite 250 Chapel Hill, North Carolina 27514 Prepared for: Bruce Moore, Project Officer Office of Air Quality Planning and Standards Sector Policies and Programs Division Contract No. EP-D-07-061 Work Order No. 4-06 U.S. Environmental Protection Agency Office of Air and Radiation Office of Air Quality Planning and Standards Research, Triangle Park, North Carolina DISCLAIMER This report has been reviewed by EPAs Office of Air Quality Planning and Standards and has been approved for publication. Mention of trade names or commercial products is not intended to constitute endorsement or recommendation for use. ii FOREWORD This background technical support document (TSD) provides information relevant to the proposal of New Source Performance Standards (NSPS) for limiting VOC emissions from the Oil and Natural Gas Sector. The proposed standards were developed according to section 111(b)(1)(B) under the Clean Air Act, which requires EPA to review and revise, is appropriate, NSPS standards. The NSPS review allows EPA to identify processes in the oil and natural sector that are not regulated under the existing NSPS but may be appropriate to regulate under NSPS based on new information. This would include processes that emit the current regulated pollutants, VOC and SO2, as well as any additional pollutants that are identified. This document is the result of that review process. Chapter 1 provides introduction on NSPS regulatory authority. Chapter 2 presents an overview of the oil and natural gas sector. Chapter 3 discusses the entire NSPS review process undertaken for this review. Finally, Chapters 4-8 provide information on previously unregulated emissions sources. Each chapter describes the emission source, the estimated emissions (on average) from these sources, potential control options identified to reduce these emissions and the cost of each control option identified. In addition, secondary impacts are estimated and the rationale for the proposed NSPS for each emission source is provided. iii TABLE OF CONTENTS 1.0NEW SOURCE PERFORMANCE BACKGROUND .................................................................................. 1-1 1.1 Statutory Authority .......................................................................................................................................... 1-1 1.2 History of Oil and Gas Source Category ......................................................................................................... 1-2 1.3 NSPS Review Process.................................................................................................................................