Oil Gas NSPSNESHAPS Bob Lebens WESTAR Oil Gas

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Oil & Gas NSPS/NESHAPS Bob Lebens WESTAR

Oil & Gas NSPS/NESHAPS Bob Lebens WESTAR

Oil & Gas NSPS/NESHAPS § § § Oil & Gas Federal Regulatory History Current

Oil & Gas NSPS/NESHAPS § § § Oil & Gas Federal Regulatory History Current Proposal Compared to State Programs Basin Impacts Schedule

Oil & Gas NSPS/NESHAPS § 1985 NSPS - Gas Processing Plants § 1999 O&G

Oil & Gas NSPS/NESHAPS § 1985 NSPS - Gas Processing Plants § 1999 O&G Production, Storage Transport MACT § Gas Star Voluntary Program § 2011 NSPS/NESHAPS § Oil & Gas § Extraction § Distribution § Pipeline Transportation of Gas

Oil & Gas NSPS/NESHAPS § Applies to 25, 000 wells fractured/refractured each year §

Oil & Gas NSPS/NESHAPS § Applies to 25, 000 wells fractured/refractured each year § Storage tanks and other associated equipment § Emission Reductions § VOCs: 540, 000 tons, 26% reduction § Methane: 3. 4 million tons, 26% reduction (through VOC controls) § O&G = 40% US methane emissions § Air Toxics: 38, 000 tons, 30% reduction

Compared to State Regulations § Wyoming, Colorado § Most comprehensive and stringent Oil &

Compared to State Regulations § Wyoming, Colorado § Most comprehensive and stringent Oil & Gas control requirements § Alaska, Montana, New Mexico, North Dakota, Utah § Some States have limited minor source programs § Complete Analysis in WRAP Report

Basin Impacts § San Juan, New Mexico § Older equipment remains in place §

Basin Impacts § San Juan, New Mexico § Older equipment remains in place § New Basins - Pieance, Colorado § Newer, cleaner equipment

Schedule § Proposal Comments due November 30, 2011 § EPA seeking comment in 65

Schedule § Proposal Comments due November 30, 2011 § EPA seeking comment in 65 areas § Promulgation § Court ordered deadline - February 28, 2012