Future-proofing your facility for EPA’s methane rules By Jeremy Sell, PE, Vice President, Air and Process Services, Trihydro Corporation
ON NOVEMBER 15, 2021, the U.S. En-
1) Updates to OOOOa, primarily to con-
text. Industry commenters have noted
vironmental Protection Agency (EPA)
form with Congressional Review Act
concern that the compliance date of
published proposed rules that establish
resolution
proposed OOOOb should not be estab-
additional new source performance
2) Proposed OOOOb
lished until actual rule language has been
standards (NSPS) and emissions guide-
3) Proposed OOOOc
released but it is not clear how EPA will
lines for the crude oil and natural gas
4) Proposed Appendix K, focused on op-
proceed with the date.
source category under the Clean Air
tical gas imaging (OGI) monitoring
Act (CAA). The proposed rule, entitled
protocols and procedures
Standards of Performance for New, Re-
The November 2021 proposal did
constructed, and Modified Sources and
not contain specific regulatory text for
Emissions Guidelines for Existing Sources:
OOOOb or OOOOc. EPA has indicated
Oil and Natural Gas Sector Climate Re-
it will issue a supplemental proposal
view, is comprised of three parts (plus
sometime in 2022 containing details on
proposed Appendix K):
proposed requirements with regulation
As the oil and gas industry awaits specific rule language, several actions can be taken in the near term to prepare for the anticipated OOOOb and OOOOc rules, which the EPA expects to finalize by the end of 2022. OOOOb: Proposed standards for new, modified, and reconstructed sources after November 15, 2021
Under a new subpart called NSPS OOOOb, the EPA proposes to update the current requirements under CAA section 111(b) for methane and VOC emissions from affected sources that commenced construction, modification, or reconstruction after November 15, 2021. OOOOb includes standards for emission sources not regulated under NSPS OOOOa and is intended to address fugitive emissions from well sites and compressor stations, storage vessels, pneumatic controllers, reciprocating compressors, pneumatic pumps, and equipment leaks at natural gas processing plants. 22 The Treasure State Journal® 2022
