EPA Issues Amendments to New Source Performance Standards for the Oil and Natural Gas Industry
September 23, 2020
By: Melissa Dakas
Summary
On August 13, 2020, EPA issued two final rules amending the 2012 and 2016 New Source Performance Standards for the Oil and Natural Gas Industry (NSPS OOOO and OOOOa). These rules establish emission standards for the control of Greenhouse Gases (GHG), volatile organic compounds (VOC) and sulfur dioxide (SO2) from a wide range of operations and equipment included in the oil and natural gas industry. The rule changes include policy amendments to both the 2012 and 2016 NSPS that remove the transmission and storage segment and the emissions standards applicable to those sources. In addition, EPA acknowledged that the emission standards used to control VOCs also reduce methane emissions therefore, the separate methane emission standards were removed for the production and processing segments because they are redundant.
Specific Amendment Changes to Note
The technical amendments made to the 2016 NSPS address numerous petitions of reconsideration brought to EPA’s attention since the rule was issued. The technical amendments include the following changes:
- Reducing the frequency of fugitive emission monitoring requirements;
- Streamlining the application process for the use of an alternative means of emission limitation (AMEL);
- Expanding the existing exemptions from control requirements and types of monitoring that may be used for pneumatic pumps; and
- Clarify that VOC emissions from storage vessels can be averaged over a tank battery for standard applicability determinations; and
- Allow for either a professional or in-house engineer to certify a closed vent system.
What This Means For You
Owners or operators subject to either NSPS OOOO or OOOOa should review the impact of the final rule on your current compliance program. The two final rules are estimated to yield net benefits equivalent to $100 million per year and reduce the regulatory burden on small oil and natural gas producers that make up over 80% of the industry.
For More Information
The final amendments and other related information are available at https://www.epa.gov/controlling-air-pollution-oil-and-natural-gas-industry/actions-andnotices-about-oil-and-natural-gas#regactions. The Policy Amendments and Technical Amendments become effective on the date of publication in Federal Register.
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Melissa Dakas
Ms. Dakas has 20 years of project management and solution development experience in the chemical engineering and environmental compliance fields. The last 15 years of her career have been spent in environmental consulting navigating the complex environmental requirements of the Northeast states, the Caribbean, and the Texas Gulf Coast Regions. Ms. Dakas specializes in air permitting and compliance through working with both industry and government to implement business objectives while conforming to environmental regulations.
