December 13, 2021
New rule adds natural gas processing facilities to the Toxics Release Inventory
A new U.S. Environmental Protection Agency (EPA) rule expands coverage of the Toxics Release Inventory (TRI) to most natural gas processing facilities. Such facilities receive raw natural gas from off-site wells, process the gas to meet industrial or pipeline specifications, and may also remove natural gas liquids, a class of heavier hydrocarbons. Meeting the reporting requirements may require operators to make changes to operations to collect additional data, and by reporting this information to EPA, operators will make information on the TRI-covered chemicals public and may face additional scrutiny.
Previously, facilities that recovered sulfur from natural gas were already covered under TRI. The new regulation expands the coverage to most facilities in the United States and its territories that process natural gas. According to EPA estimates, more than 320 natural gas processing facilities will become subject to the TRI reporting requirement. At these facilities, operators use more than 21 TRI-covered chemicals including n-hexane, hydrogen sulfide, toluene, benzene, xylene, and methanol. The TRI toxic chemical list already contains 770 individually listed chemicals and 33 chemical categories. As the list is subject to change, operators will need to continuously monitor for changes to avoid being out of compliance with this rule.
Some facilities, however, remain exempt from this reporting requirement, such as facilities that only separate or recover condensate from a natural gas stream. Natural gas compressor stations on transmission or distribution lines and Joule-Thompson and dew point depression valves located at or close to extraction sites are also exempt.
The regulation applies to the reporting year beginning January 1, 2022, and reports are due July 1, 2023, meaning many natural gas processing facilities may need to begin tracking their releases and other waste management quantities in January 2022 and submit TRI data beginning in 2023.
How Exponent Can Help
Exponent's multidisciplinary team of environmental and thermal scientists and chemical engineers can help firms assess the impact of the new reporting requirements. Our services that can help clients prepare for this new regulation include:
- Helping clients understand the opportunities and challenges associated with the new reporting requirements.
- Helping clients understand whether their facilities may be exempt from the reporting requirements.
- Helping clients determine potential reductions in TRI reporting requirements by converting processes at their facilities.