EPA Proposes Revision to NSPS OOOOa New Source Performance Standards for the Oil and Gas Industry

Author esparc-adminPosted on

On September 11, 2018, EPA proposed improvements to the 2016 New Source Performance Standards for the oil and gas industry (“2016 NSPS OOOOa”).  The main changes involve amendments to the fugitive monitoring frequency and repairing schedule requirements.  The new rule will significantly reduce regulatory burden and cost for energy producers and will streamline implementation and improve alignment between EPA’s rule and existing state programs.  eSPARC has reviewed the proposed rule and identified the key modifications in the table below.

EPA is currently submitting the proposed revision for publication in the Federal Register.  EPA will take public comment on the proposed amendments for 60 days after they are published in the Federal Register.  More information on the proposed revision is available at https://www.epa.gov/controlling-air-pollution-oil-and-natural-gas-industry/proposed-improvements-2016-new-source

If you would like to learn more about NSPS OOOOa and how this rule change may affect your oil and gas operations, eSPARC is available to help you navigate this challenging regulation.

 

Current 2016 NSPS OOOOa

2018 Proposed Amendment

Monitor and Repair Schedule

Monitoring Frequency for Well Sites(1)

Owners or operators at all new and modified well sites are required to conduct an initial monitoring survey within 60 days of the startup of production, and semiannual monitoring surveys afterward.

 
  • For low production(2) well sites initial monitoring survey within 60 days, and biennial monitoring afterward.
  • Once all major production and processing equipment is removed so that the site contains only wellheads, monitoring may be stopped.  However, separate tank batteries receiving oil or gas produced from wellhead-only sites are considered modified and would be subject to fugitive emissions monitoring requirements.

Monitoring Frequency for Compressor Stations(1)

 

Requires an initial monitoring survey within 60 days after startup of a new or modified compressor station, then quarterly monitoring afterward.
  • Initial monitoring survey within 60 days and either semi-annual or annual monitoring.
  • Monitor each compressor at the station at least once per calendar year when it is operating.

Schedule for Repairing Leaks

 

Repair leaking components within 30 days of detection and to re-survey the component within 30 days to verify that the repair was successful.

Repair leaking components within 60 days of detection and resurvey the component.  A first attempt at repair would be required during the first 30 days of that 60-day period.

Alignment with State Programs

 

Owners or operators had to request permission to meet a state or local program in lieu of EPA’s requirements by using the alternative means of emissions limitation (AMEL) process. 

Allows owners or operators to choose to base fugitive emissions monitoring and repair plans on requirements from certain states(3), in lieu of EPA’s requirements (prior notification to EPA required).

Standards for Pneumatic Pumps at Wells Sites

 

Methane and volatile organic compound (VOC) emissions from pneumatic pumps are required to be routed to an existing control device or process on site unless it is technically infeasible to do so.  This exemption was only allowed for existing well sites.

Expands the technical infeasibility provision to all well sites, including new well sites.

Professional Engineer Certifications

 

A professional engineer is required to satisfy pneumatic pump infeasibility and closed vent design certification.

Allows either a professional engineer OR in-house engineer with appropriate expertise to satisfy applicable certification requirements.

Notes:

  1. Additional changes proposed for Alaskan North Slope, though not discussed here.
  2. Low production well sites are defined as well sites that have a combined oil and natural gas production of less than 15 barrels of oil equivalent per day, averaged over the first 30 days of production.
  3. Acceptable state standards include – Well sites and compressor stations: California, Colorado, Ohio, and Pennsylvania & Well sites: Texas and Utah