Existing Source Regulations and Information Collection Requests (ICR) for Oil and Gas Sources
On March 10, the EPA announced their plans to develop methane rules for existing sources located in the oil and gas production, processing and transmission segments under Clean Air Act Section 111(d). Building off of proposed regulations requiring methane reductions from new and modified sources (i.e., NSPS Subpart OOOOa for oil and gas sources), EPA is now developing standards for existing sources as well (not entirely unlike the process used for developing requirements for existing electric generating units under the Clean Power Plan). EPA announced their intent to "move quickly" and to "start immediately" to develop regulations controlling methane emissions from existing oil and gas industry sources.
In order to begin the regulatory development process, EPA will start with an Information Collection Request (ICR) that will be launched in April. The ICR helps EPA identify the most significant sources of emissions and the kinds of technologies that work best to reduce emissions. It is not unusual for EPA to issue ICRs, but how many they issue and to whom is different for each ICR initiated. For example, several years ago the EPA issued an ICR to the aerospace industry in several phases, and ultimately required mandatory responses from only some sites. EPA issued ICRs to the petroleum refining industry in 2011, and issued the ICR industry-wide (as there are a limited number of refineries throughout the country).
While it is difficult to tell exactly how EPA may issue this ICR for the oil and gas industry, it does seem that requiring an industry-wide response is not an approach EPA will likely take. However, EPA seems likely to require a number of operators in the production, processing and transmission sectors to provide information. For more information regarding EPA's plan to develop these regulations, Please Call Jeff Voorhis, PE @
HY-BON/EDI Products and Services
Let HY-BON/EDI assist your company respond to the upcoming EPA request and stay in compliance.
Our company’s 60 plus years of experience can help with your vent gas management (VGM) needs. This includes the following:
- Vent gas measurement and leak detection using our LDAR IQR services
- Vapor recovery units (VRU)
- Vapor recovery towers (VRT)
- Vapor combustion devices (VCU)
- Field Service (VRU/VCU maintenance, tank seal inspection/replacement, leak detection, LDAR)