On Thursday, September 13, 2018 EPA posted the prepublication version of the proposed reconsideration amendments for the 2016 NSPS OOOOa rule, creating significant repercussions to rule compliance and fugitive emissions monitoring programs.  We expect to see the rule published in the federal register in the coming week. EPA's reconsideration addresses three major areas:

1. Fugitive emissions requirements,
2. Well site pneumatic pump standards, and
3. The requirements for certification of closed vent systems by a professional engineer (PE) based on specific objections to these requirements. This is a proposed rule; therefore, EPA is requesting further comments to develop the final rule.

A Little Background

NSPS OOOOa was published on June 3, 2016 with an initial compliance date of August 2, 2016. Over the last two years, there have been multiple revisions of the original rule. NSPS OOOOa includes both volatile organic compounds (VOC) and greenhouse gas (GHG) (methane) emission standards for certain equipment, processes, and activities that were new, modified, or reconstructed after September 18, 2015 across the oil and natural gas source category.

What’s Changing

1. Qualified Professional Engineer Requirements:
2. Incorporation of State Rules as Alternatives
3. Initial Monitoring
4. Repair Provisions
5. Delay of Repair Provisions
6. Monitoring Plan/ Walking Path
7. Well Sites
8. Compressor Stations

Learn More/ Need Assistance

If you would like further information on NSPS OOOOa or assistance in implementing a program, please contact our compliance experts:

Cal Niss
Senior Vice President
[email protected]

Dan Wood
Associate Staff Scientist
[email protected]