CASE STUDY
Committed to Clean Air: How a Natural Gas Producer Leads the Way with a Voluntary Audit
When one of North America’s leading natural gas producers expanded by acquiring numerous oil and gas facilities across Ohio, Pennsylvania, and West Virginia, they recognized the responsibility that came with growth. Situated in the Marcellus and Utica shale basins, these facilities represented a significant investment to meet the demand for reliable, lower-carbon energy, but also imposed regulatory complexities.
The newly acquired sites spanned EPA Regions 3 and 5, areas with a history of Clean Air Act enforcement activity and high-profile consent decrees. Instead of waiting for inspectors to come knocking on their door, the company opted to conduct a voluntary audit under the Clean Air Act. The objective was to identify and resolve air quality compliance risks proactively, reinforcing their commitment to environmental stewardship. This approach balanced business priorities with public accountability, proving that responsible energy production starts with asking tough questions and being ready to act.
Safeguarding Our Future with Clean Air and Corporate Accountability
The EPA states that the Clean Air Act has generated benefits exceeding its costs by a ratio of 30 to 1, primarily via improved health and economic productivity. Since 1970, emissions of key pollutants have decreased by 74%, despite significant economic growth.
Facilities that operate outside compliance not only face legal consequences but can also deteriorate air quality, impacting nearby communities and ecosystems. The client recognized that inaction could lead to a potential consent decree, civil penalties, and reputational damage. By choosing a voluntary audit, they positioned themselves as leaders in accountability.
Balancing Expectations, Navigating Complexity
Montrose’s Spirit Environmental team offered more than air quality expertise; they provided a human-centered, outcome-driven approach to regulatory engagement. Our role was to assist the client in addressing compliance issues without jeopardizing business objectives while fostering communication and trust between the client and the EPA.
Over a period of three years, we provided technical and strategic support across every stage of the audit. This included detailed desktop reviews to confirm permits, assess regulatory compliance, and evaluate vapor control systems. In the field, we conducted equipment inventories and used Optical Gas Imaging cameras to detect leaks and verify site conditions.
Results That Matter—For People and Planet
The audit identified compliance issues that, while challenging, became opportunities for improvement. Montrose’s Spirit team guided the client through necessary corrective actions, including retrofitting a dozen sites with advanced monitoring technology to track the performance of the vapor control systems in real-time. These upgrades reduced volatile organic compounds (VOCs), Hazardous Air Pollutants (HAPs), and greenhouse gas (GHG) emissions, improving air quality for nearby communities and helping the client meet both the regulatory requirements and their internal climate and sustainability commitments.
As a result, the client secured a Final Determination letter from the EPA, officially closing the audit without facing enforcement action, and embodying a proactive model for compliance in the industry.
A Model for Proactive Compliance
This initiative demonstrated a commitment to environmental responsibility in the oil and gas industry. By undertaking this comprehensive audit and investing in technology and smarter controls, the client avoided costly penalties while enhancing operational integrity. Montrose’s leadership helped transform regulatory challenges into opportunities, demonstrating how proactive compliance can strengthen both business resilience and environmental performance.
Features:
- 50+ facilities audited.
- 12 sites retrofitted with advanced monitoring technology.
- Led the way in emissions prevention with proactive real-time vapor monitoring.
