Oil and gas operations will be impacted by the risk management program regulations to be promulgated by the U.S. Environmental Protection Agency (EPA) under the Clean Air Act, as amended in 1990 (CAA). In part, the CAA requires facilities with certain hazardous substances above threshold quantities to conduct hazard assessments, implement accident prevention and emergency response programs and prepare risk management plans. The EPA has published final lists of toxic and flammable substances; hydrogen sulfide and several hydrocarbons were listed. The risk management program regulations have been proposed.
This paper provides an overview of the statutory requirements for accidental release prevention in section 112(r) of the CAA. The applicability of the final lists to the oil and gas industry is described and the proposed risk management program regulations are summarized. Examples of analyses illustrating potential effects of accidental releases of "sour" gas, methane, propane and pentane are presented. The paper concludes with a brief discussion of some major issues raised in public comments to the proposed rule.