In March 2022, the New York State Department of Environmental Conservation adopted two regulations applicable to owners and operators in the oil and natural gas sector: Part 200, General Provisions, and Part 203, Oil and Natural Gas Sector. The rules were adopted to protect the health and welfare of New York residents by 1) reducing methane in support of the goals set by the Climate Leadership and Community Protection Act; 2) reducing associated volatile organic compounds (VOCs); and 3) fulfilling the requirements of the EPA's 2016 Control Techniques Guidelines for the oil and gas industry.
The regulations specify standards and requirements for the following equipment and activities:
- Storage vessels with a potential to emit greater than or equal to 6 tonnes per year (tpy) of VOC installed prior to 2023 must have a vapor control efficiency of 95%; those installed in 2023 and after must not vent to the atmosphere.
- Natural gas actuated pneumatic devices and pumps shall not vent into the atmosphere except under special circumstances and shall comply with LDAR requirements. Emissions thresholds and repair requirements are specified for continuous bleed devices and intermittent bleed devices.
- Centrifugal compressors operating greater than 200 hours annually shall comply with specified LDAR requirements. Compressors with wet seals shall control the wet seal vent gas with the use of a vapor collection system or replace the wet seal with a dry seal.
- Reciprocating compressors operating greater than 200 hours annually shall comply with specified LDAR requirements.
- Operators must provide notification and information to the Department concerning blowdown activity at compressor stations and transmission pipelines.
- Operators shall record and report annually on pigging activity along natural gas pipelines.
- Owners or operators shall submit a baseline report to the Department containing information on relevant equipment, including separators, storage vessels, compressors, gas drying systems, pneumatic devices and metering and regulating systems. They shall maintain records of emissions and LDAR inspections for these equipment for at least 5 years from the date of initiation and make them available to the Department upon request.
- LDAR requirements: Owners and operators may comply using EPA Method 21, optical gas imaging, and/or an alternative technique approved by the Department. Subpart 203-7 specifies the frequency of LDAR inspection for each component.
The Department estimates that the adoption of the regulation will result in a decrease of emissions of up to 49% in the sector.