December 16, 2021

Controlling Emissions From the Oil and Natural Gas Industry

On November 15, 2021, EPA proposed a three-part CAA rule designed to significantly reduce emissions of greenhouse gasses (GHGs) and volatile organic compounds (VOCs) from the crude oil and natural gas source category. [86 FR 63110] First, EPA proposes to revise two current NSPS (Part 60, Subparts OOOO and OOOOa) to reflect a 2021 congressional joint resolution disapproving of a 2020 rule weakening emission standards for the source category. Second, the agency wants to update, strengthen, and expand the methane and VOC emission requirements for sources constructed, modified, or reconstructed after November 15, 2021, by promulgating a new Subpart OOOOb. Third, EPA is proposing emission guidelines for existing sources (“designated facilities”) to limit methane emissions under a new Subpart OOOOc. Comments may be submitted until January 14, 2022 under Docket No. EPA-HQ-OAR-2021-0317.

The rule would take a multi-pronged approach to reduce the emissions of methane and VOCs from hundreds of thousands, if not millions, of sources in the oil and natural gas industry. Requirements would include finding and repairing methane leaks from well sites and compressor stations, transitioning to zero-emitting technologies for pneumatic controllers, eliminating venting of associated gas from oil wells, strengthening requirements for storage tanks, broadening the types of pneumatic pumps covered by the standards, and much more. New Subparts OOOOb and OOOOc would also include a fugitive emissions monitoring and repair program using optical gas imaging procedures established in a proposed Part 60, Appendix K. EPA estimates an emissions reduction of 41 million tons of methane and 12 million tons of VOCs over a 12-year period.

This proposal does not actually include the proposed regulatory language. Instead, the agency is waiting on comments and intends to issue a supplemental proposal in 2022. The 2022 proposal would provide the proposed regulatory text and may expand on or modify the 2021 proposal depending on public input. A final rule is expected by the end of 2022. More information on the proposal, including a redlined regulatory text reflecting Subpart OOOOa changes, is available on EPA’s website.

Applicability Dates for Proposed Subparts

Subpart

Source type

Applicability dates

Part 60, Subpart OOOO

New, modified, or reconstructed

After August 23, 2011 and on or before September 18, 2015

Part 60, Subpart OOOOa

New, modified, or reconstructed

After September 18, 2015 and on or before November 15, 2021

Part 60, Subpart OOOOb

New, modified, or reconstructed

After November 15, 2021

Part 60, Subpart OOOOc

Existing

On or before November 15, 2021

Source: Adapted from EPA [86 FR 63117]

 


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This document addresses issues of a general nature related to the federal RCRA regulations. Persons evaluating specific circumstances dealing with the RCRA regulations should review state and local laws and regulations, which may be more stringent than federal requirements. In addition, the assistance of a qualified professional should be enlisted to address any site-specific circumstances.