New NSPS OOOOa Regulations Affecting Methane and VOC Emissions from the O&G Sector Finalized as of June 3, 2016

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Courtesy of AEREON

 The EPA has issued three final rules that will curb emissions of methane, smog-forming volatile organic compounds (VOCs) and toxic air pollutants such as benzene from new, reconstructed and modified oil and gas sources, while providing greater certainty about Clean Air Act permitting requirements for the industry.

The EPA’s amended and new regulations affecting methane (CH4) and VOC emissions from the oil and gas sector have been finalized and the new rules were published in the Federal Register on June 3, 2016, amending 40 CFR 60 Subpart OOOO. The final NSPS rules become effective August 3, 2016.

These rules revise NSPS OOOO and create the new NSPS OOOOa. NSPS OOOO affects oil and gas facilities constructed, modified or reconstructed after August 23, 2011, and on or before September 18, 2015. NSPS OOOOa affects facilities constructed, modified or reconstructed after September 18, 2015. NSPS OOOOa includes CH4 and VOC emission standards.

See link here, for a table listing of affected emission sources for NSPS OOOO and OOOOa. 

Requirements for the oil and gas upstream industry for gas processing facilities are:

NSPS OOOO changes (changes to NSPS OOOO also apply to NSPS OOOOa and include):

  • Replacement storage vessels (tanks) are subject to the same requirements as the storage vessel that it replaced. 
  • Reconnected storage vessels are subject to the same requirements as those that applied before being removed from service.
  • Requires flow indicators and alarms for bypasses from control devices for storage tanks and compressor wet seals. 
  • Exempts storage vessels with a capacity greater than 100,000 gallons used to recycle water that has been passed through two stage separation. 
  • For enclosed combustion devices (VCU) stack tested, it increases the limit for total organic carbon (TOC) in the exhaust gases to a level equal to or less than 275 parts per million by volume as propane on a wet basis corrected to 3 percent oxygen. 
  • Adds a definition of “Capital expenditure” for determining if a modification has occurred.
  • The final amendments to the current NSPS OOOO do not change the requirements for operations already covered by the current NSPS OOOO standards.  

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