Major new US Environmental Protection Agency (EPA) regulations that aim to curb methane and volatile organic compound (VOC) emissions became effective on May 7, 2024.The regulations target emissions from the oil and gas industry, addressing emissions through three main rulemakings:
The Clean Air Act (CAA) requires EPA to create New Source Performance Standards (NSPS) for industries that cause or significantly contribute to air pollution. Oil and natural gas operations are one of these industries.
In November 2021, EPA proposed draft versions of NSPS subparts OOOOb, OOOOc, and Appendix K as part of an initiative to reduce greenhouse gas (GHG) and volatile organic compound (VOC) emissions. After a public comment period, the agency published the finalized rules effective May 7, 2024.
OOOOb, OOOOc, and Appendix K New Rules
NSPS OOOOb establishes emission standards and compliance schedules to control GHG and VOC emissions from facilities in the crude oil and natural gas source category. It outlines emissions standards, test methods and procedures, and monitoring, reporting, notification, and recordkeeping requirements pertaining to these emissions. The rule applies to facilities that have been modified, constructed, or reconstructed since December 6, 2022.
The following sources are included:
Super-emitter events (60.5371b)
Well completions (60.5375b, 60.5399b)
Gas wells and liquids unloading operations (60.5376b, 60.5377b, 60.5399b)
Centrifugal compressors (60.5380b, 60.5386b, 60.5399b)
Reciprocating compressors (60.5385b, 60.5386b, 60.5399b)
Process controllers (60.5390b)
Pumps (60.5393b)
Storage vessels (60.5395b)
Fugitive emissions (60.5397b, 60.5398b, 60.5399b, 60.5424b)
Process unit equipment (60.5399b, 60.5400b, 60.5401b, 60.5402b, 60.5403b, 60.5422b)
Sweetening units (60.5405b, 60.5406b, 60.5407b, 60.5423b)
Requirements vary based on these categories. For example, centrifugal compressors that use wet seals at affected facilities must reduce methane and VOC emissions from each wet seal fluid degassing system by 95 percent, among other requirements. Meanwhile, pump affected facilities must be designed and operated with zero methane and VOC emissions to the atmosphere.
Notably, OOOOb establishes a third-party monitoring framework for “super-emitter events”—emissions events near oil and natural gas facilities that are identified using remote detection methods and have an emission rate of 100 kg/hr of methane or greater. Under the subpart, third parties, such as non-governmental agencies and other entities that are neither government agencies nor regulated facilities, can apply with EPA to become certified notifiers of super-emitter events. Reports from these third-party notifiers may impact companies affected by the methane waste emissions charge (WEC). (EPA approved the first third-party notifier in early January 2025.)
Further details about the emissions, monitoring, and reporting requirements can be found by clicking on the linked eCFR sections next to each category.
Meanwhile, NSPS OOOOc directs states and tribes to create emissions plans for all existing designated facilities under their jurisdiction. This subpart requires administrators and protectorates to submit a state or Tribal plan (SIP or TIP) to the EPA by March 9, 2026, detailing how the state will accomplish emissions reductions equal to or greater than those expected under OOOOb. It provides states and tribes with the flexibility to customize their plans based on regional circumstances and needs, but the plans must be at least as stringent as the corresponding emission guidelines.
Finally, Appendix K standardizes a written protocol for optical gas imaging (OGI) survey requirements in the oil and gas sectors. It outlines monitoring equipment, survey procedures, camera operator training, and recordkeeping requirements.
Trihydro Can Help
We have assisted oil and natural gas clients in complying with NSPS and GHG reporting requirements since 2010. If you have questions about how to prepare for regulatory requirements or would like to learn more about LeakTracker ProTM, Trihydro’s leak tracking software, submit a contact form, and we will connect with you to learn about how we can help.
