Proposed Changes to NSPS OOOO and OOOOa
On August 28, 2019, the EPA published proposed rule changes affecting NSPS OOOO and OOOOa oil and gas regulations and have entered a sixty-day public comment period. The EPA has developed two proposals, one they describe as “primary” and the other as “alternative”.
The primary proposal seeks to accomplish two things. First, to remove the NSPS applicability (methane and VOC) entirely from the transmission and storage part of the oil and gas industry stating that they are a separate source category from production and processing, which was the original target for the rule. The second part of the primary proposal identifies the correlation between VOC and methane emissions and therefore, by controlling one, the other is also affected in the same manner. This change would remove any requirements associated with methane emissions.
The alternative proposal is like the primary in that it seeks to remove all the methane requirements from the NSPS regulation for oil and gas sites, however, the alternative proposal does not attempt to disassociate the transmission and storage areas from production and processing. In this proposal, all the current VOC emission standards and compliance requirements remain in place as currently applied.
Complete details of the proposed amendment and fact sheet can be found here.