file. - Otsego County Conservation Association

7.5.1.3 Natural Gas Production Facilities Subject to NESHAP 40 CFR Part 63, Subpart HH
(Glycol Dehydrators)
In their current state the DEC’s proposed regulations that address benzene emissions will be out
of date before they are even enacted. On page 7-106 the rdSGEIS states that, “All glycol
dehydrator units used at the well pad will be required to assure compliance with the 1 ton per
year (Tpy) benzene emission limit…” However, the EPA has proposed to eliminate the 1 Tpy
benzene compliance option for glycol dehydrators xiii : “The proposed changes would eliminate the
1 ton per year benzene compliance option for glycol dehydrators … at major sources.”
7.5.1.3 Natural Gas Production Facilities Subject to NESHAP 40 CFR Part 63, Subpart HH
(Glycol Dehydrators)
and
7.5.3 Summary of Mitigation Measures to Protect Air Quality
and
7.6 Mitigating GHG Emissions
On July 28, 2011 the EPA proposed a set of sweeping regulations that would significantly reduce
harmful air pollution from the oil and gas industry xiv . These proposed regulations would allow
continued responsible growth of the industry and are currently in use as best practices in several
states. These regulations affect multiple stages of gas development, particularly well completion
and gas transmission. The four regulations are: 1) a new performance standard for volatile
organic compounds (VOCs); 2) a new source performance standard for sulfur dioxide; 3) an air
toxics standard for oil and natural gas production; and 4) an air toxics standard for natural gas
transmission and storage. These proposed federal regulations impose tighter restrictions than
those proposed by DEC on the amounts of pollutants that the natural gas industry is allowed to
release into the air, resulting in significant benefits to public health and welfare over and above
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