1165990 - Perspectives on the Proposed New Source Performance Standards at Subparts OOOOb and OOOOc to Reduce Methane from the Oil and Natural Gas Industry

The EPA proposed updates to New Source Performance Standards (NSPS) for sources in the Oil and Natural Gas (O&G) Industry on November 15, 2021. Subpart OOOOb will apply to new, modified, or reconstructed after November 15, 2021, and Subpart OOOOc will apply to existing sources not subject to Subpart OOOOb. Methane emission reductions headline the rule's benefits, and the changes will also significantly reduce Volatile Organic Compounds (VOC) and organic Hazardous Air Pollutant (HAP) emissions.

This presentation will summarize the proposal and its implications to the O&G Industry. The basics of the regulatory action will be outlined, including the unique regulatory mechanisms for regulating methane and regulating existing sources via “emissions guidelines.” Proposed requirements for each type of regulated affected facility will be summarized, focusing on emission generation and control for understanding by a broad audience. Overall, this presentation will describe the depth and breadth of EPA’s efforts to curb emissions of methane and co-pollutants from the O&G industry.

Significant impacts to the industry are expected for storage tank batteries and natural gas-driven pneumatic controllers, requiring the installation of emissions controls or equipment replacement. Storage tanks are more likely to become subject to the rule and controls by considering the entire tank battery rather than individual tanks. Pneumatic controllers are ubiquitous small sources of emissions at upstream facilities used to regulate various physical parameters in the process. Many controllers are powered by natural gas and are in locations without access to electricity. EPA is proposing to require control of all new and existing pneumatic controllers, posing many logistical challenges and requiring costly equipment replacements.

If available, the presentation will consider the EPA’s supplemental proposal (due in early 2022).