Air Compliance in the U.S.: A Systematic Guide for EP Service Companies to Evaluate, Establish, and Ensure Ongoing Compliance

摘要

This paper discusses the complexities that E&P service companies face in the U.S. as they manage their air compliance program for their base facilities, wellsite operations, and transportation fleets while tackling the enormous amount of federal, state, county, and local air regulations. Examples of point sources (e.g., chemical blending facilities), pollution-control devices (e.g., dust collectors), and fugitive emissions (e.g., cutting sacks of dry chemicals) found within the oilfield services sector are presented, and discussions of air permit or permit exemption requirements are included for each example. This paper is intended to share best practices for establishing and maintaining an air compliance program, including the tools (e.g., compliance matrix) and systematic techniques for managing air compliance. These practices have application across state boundaries, regardless of the site location. The compliance program includes: 1) determining if a site(s) is currently in compliance with applicable air regulations, permits or permit exemptions, including aspects related to preplanning and scope, whom to involve, audit privilege, and disclosure; 2) bringing a site into compliance once nonconformances have been identified, 3) maintaining compliance even if operational changes such as human factors, equipment, chemicals, or new construction occur, and 4) implementing operational controls to ensure compliance with continual regulatory changes.