On October 15, 2018, USEPA proposed amendments to the new source performance standards (NSPS) for the oil and natural gas sector at 40 CFR Part 60, Subpart OOOOa (“Subpart OOOOa”). The proposed amendments to Subpart OOOOa are a result of USEPA’s reconsideration of certain aspects of Subpart OOOOa in 2017. Specifically, the proposed amendments address the Subpart OOOOa provisions governing fugitive emissions requirements, well site pneumatic standards, and professional engineer certification requirements.
With respect to the fugitive emissions requirements, EPA is proposing to revise the monitoring frequencies depending on the type of well site and to eliminate monitoring requirements when all major production and processing equipment is removed from a well site. Several amendments to definitions related to fugitive emissions are also proposed.
With respect to pneumatic pumps, EPA is proposing to expand the technical infeasibility provision to all well sites. EPA is also proposing to amend the certification requirements for closed vent system design and technical infeasibility for pneumatic pumps by allowing certification by either a professional engineer or an in-house engineer with relevant expertise.
Other proposed amendments are intended to clarify the requirements for requesting alternative means of emission limitation, the location of a separator during flowback operations, whether screenouts and coil tubing cleanouts are regulated as part of flowback operations. Finally, EPA proposed amendments to clarify several issues regarding the implementation of Subpart OOOOa including alternative work practice standards for reciprocating compressors, calculating potential emissions from storage vessels, exempting equipment at onshore processing plants that is used only during emergencies, and streamlining reporting and recordkeeping requirements.
Comments on the proposed amendments to Subpart OOOOa are due by December 17, 2018.