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December 2021 – OOOO A(hhh!)

OOOO A(hhh!)

Quad O or more technically, 40 CFR Part 60 Subpart OOOO, and also known as the New Source Performance Standards (NSPS) for crude oil and natural gas facilities, establishes emission standards and compliance schedules for the control of volatile organic compounds (VOCs) and sulfur dioxide (SO2) emissions from crude oil and natural gas production facilities – and most notably, methane emission standards.

US EPA has proposed updating the NSPS OOOO regulations, which will be contained in the new OOOOb subpart, to further reduce methane emissions. New (or modified or reconstructed after 11/15/2021) crude oil and natural gas facilities will be subject to OOOOb through the regulation of emission sources previously not regulated under the existing OOOO and OOOOa standards (OOOO and OOOOa pertain to sources new, modified, or reconstructed before and after 9/18/2015, respectively).

The proposal includes increased monitoring frequency, increased components included in inspections, enhanced definition of a “leak,” and more stringent repair requirements. Table 2 in the Federal Register notice lists the expansive changes (https://www.federalregister.gov/documents/2021/11/15/2021-24202/standards-of-performance-for-new-reconstructed-and-modified-sources-and-emissions-guidelines-for ).

Second to this update, the US EPA is proposing nationwide emission guidelines (EG) for states to limit methane emissions from crude oil and natural gas facilities. In the first set of nationwide EG, the EG are designed to inform states in the development, submittal, and implementation of state plans that are required to establish standards of performance for greenhouse gases (GHGs) from their designated facilities in the Crude Oil and Natural Gas source category. The EG being proposed in this rulemaking will be in a new subpart, 40 CFR part 60, subpart OOOOc. Table 3 in the Federal Register notice lists the proposed rule specifics.

Third in this update is the creation of Appendix K – Determination of Volatile Organic Compound and Greenhouse Gas Leaks Using Optical Gas Imaging – a detailed process for utilizing optical gas instrumentation (OGI) for leak detection. The more onerous requirements include: documenting routes to ensure all components are monitored, assurance that surveys are performed within the operating envelope, and component monitoring must include at least two angles, a dwell time of 5 seconds per angle per component, and include breaks to reduce Operator fatigue. In addition, training requirements and much more robust reporting requirements are also included..

Within the proposal, US EPA is seeking comment on: Advanced methane detection techniques, such as using fixed detectors, aerial monitoring and satellite monitoring; and crowd sourcing event reporting.

Finally, US EPA is making the textual changes to subpart OOOO and OOOOa that were affected by the 2020 Policy Change roll back.

The 60-day comment period began November 15, 2021, so the US EPA is accepting comments until January 15, 2022 although they recommend getting your comments in by December 15, 2021.

Shaun Gilday, CPEA, PMP

Senior Advisor/Principal