On November 15, 2021, the U.S. Environmental Protection Agency (EPA) proposed New Source Performance Standard (NSPS) Subparts OOOOb and OOOOc. The public comment period closed on January 31, 2022, and it may be several years until existing sources are affected by Subpart OOOOc. However, we anticipate Subpart OOOOb will be finalized in late 2022 or early 2023. Below, we outline several actions that can be taken in the near term to better prepare for the proposed Subpart OOOOb.
- Keep track of new, modified, or reconstructed affected sources for which construction commenced after November 15, 2021.
Like all NSPS regulations, EPA proposed that the effective date to meet NSPS OOOOb requirements will be the proposed rule publication date (November 15, 2021). While it is possible EPA could establish a later effective date, it is conservative to use the currently proposed effective date as a basis. Therefore, facilities with the following features are advised to track new construction and potential modifications for which construction commenced after November 15, 2021:
- Oil and gas production well sites.
- Compressor stations.
- Storage vessels/batteries – EPA proposes that the emissions threshold will apply to tank batteries, not individual tanks. Modification triggers may include additional wells or refracturing that increase tank throughput.
- Natural gas-driven pneumatic controllers – the proposed standard will apply to each individual new controller.
- Well liquids unloading – while the final rule is not likely to impact already completed well liquids unloading activities, it could potentially require liquids unloading events immediately following final rule publication to meet the new standards. EPA has deemed each individual well liquids unloading event to be an affected source, meaning NSPS OOOOb requirements will apply to new unloading events at existing wells. The default requirement is proposed to be zero volatile organic compounds (VOC) and/or methane emissions.
- Centrifugal and reciprocating compressors, including horsepower ratings and blowdown/rod packing/wet or dry seal routing.
- Pneumatic pumps at natural gas processing plants and in the transmission and storage segment.
- Control devices, including inlet flow monitoring and pilot flame monitoring systems (or the ability to install once required).
- Consider designs (where applicable) to capture and control blowdown emissions associated with pig launchers and receivers.
- Consider designs to capture vapors associated with tank truck loading activities at new well pads.
- Evaluate ability to connect associated gas to a sales line (if not already planned), and if it must be flared, verify that flares will meet NSPS Subpart 60.18 requirements.
- Evaluate Optical Gas Imaging (OGI) activities (to meet proposed Appendix K requirements).
For the items below, go back in history as far as possible, as Appendix K emphasizes cumulative monitoring experience:
- Track each OGI technician’s classroom and field training activities.
- Track each OGI technician’s monitoring events and monitoring hours.
- Check current OGI equipment to ensure it is compliant and inquire on other required equipment sourcing.
- Be sure you have a system in place to track all OGI camera maintenance records.
- Consider general personnel training level and if you currently have senior OGI camera operators.
- Consider whether your existing data management approach can reasonably manage the additional data requirements included in proposed Appendix K. Trihydro’s LeakTracker ProTM provides an alternate for your consideration.
- Consider future-proofing facilities and budgets for complying with the proposed rules:
- Can costs be distributed over multiple budget cycles?
- Are there ways to future-proof the design of facilities not yet constructed or modified?
- Can potentially affected facilities be modified in a more effective, cost-efficient way to achieve compliance?
Connect with us at 4C
On April 6-8, 2022, Trihydro will be at the 4C Conference in Austin, Texas. We are offering a regulatory workshop covering proposed OOOOb, OOOOc, and Appendix K, and are also excited to present on data management approaches for proposed Appendix K.
Questions? Contact us!
We are tracking the EPA’s proposed methane rules and have assisted oil and natural gas clients in complying with NSPS and greenhouse gas (GHG) reporting requirements since 2010. If you have questions about how to prepare for anticipated regulatory requirements or would like to learn more about LeakTracker ProTM, submit a contact form and we will connect with you to learn more about how we can help.