On August 28, 2019, the U.S. Environmental Protection Agency (EPA) announced its proposal to amend two components of current New Source Performance Standards (NSPS) OOOO and OOOOa regulations applicable to the oil and gas industry. EPA stated the reason for the amendments is to remove regulatory duplication. The proposed action includes:
- Removal of methane and volatile organic compound (VOC) requirements for all transmission and storage sources, including underground storage vessels, transmission compressor stations and pneumatic controllers. With this change, only compressor and booster stations located between a well site and processing facility will be subject to regulation.
- Removal of methane requirements for production and processing sources.
If Not That, Then This: An Alternative
The action also includes an alternative proposal to maintain VOC standards for all sources except sources associated with transmission and storage (downstream of natural gas plant processing). EPA stated that because VOC emission controls also reduce methane, keeping the VOC requirements makes standalone methane requirements redundant.
Once the NSPS amendments are published in the Federal Register, EPA will accept comments for 60 days. EPA will also hold a public hearing in Texas, with date and details to be determined soon.
At this time, EPA is also requesting comments regarding its authority to interpret section 111(b) of the Clean Air Act (CAA), including which information EPA should consider when quantifying pollutant emissions as well as to which emissions criteria pollutants should be compared. Specifically, EPA is seeking to determine if it should revise the approach it took to regulate methane in the NSPS OOOOa rule.
You can view the USEPA’s fact sheet summarizing the action here.
Questions? Contact our air compliance team:
Cal Niss, Senior Air Compliance Specialist