On Thursday, September 13, 2018 EPA posted the prepublication version of the proposed reconsideration amendments for the 2016 NSPS OOOOa rule, creating significant repercussions to rule compliance and fugitive emissions monitoring programs. We expect to see the rule published in the federal register in the coming week. EPA's reconsideration addresses three major areas:
- Fugitive emissions requirements,
- Well site pneumatic pump standards, and
- The requirements for certification of closed vent systems by a professional engineer (PE) based on specific objections to these requirements. This is a proposed rule; therefore, EPA is requesting further comments to develop the final rule.
A Little Background
NSPS OOOOa was published on June 3, 2016 with an initial compliance date of August 2, 2016. Over the last two years, there have been multiple revisions of the original rule. NSPS OOOOa includes both volatile organic compounds (VOC) and greenhouse gas (GHG) (methane) emission standards for certain equipment, processes, and activities that were new, modified, or reconstructed after September 18, 2015 across the oil and natural gas source category.
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Qualified Professional Engineer Requirements:
Incorporation of State Rules as Alternatives
Delay of Repair Provisions
Monitoring Plan/ Walking Path
Learn More/ Need Assistance
If you would like further information on NSPS OOOOa or assistance in implementing a program, please contact our compliance experts:
Senior Vice President
Associate Staff Scientist