NSPS OOOOa 90-Day Stay Finalized
June 9, 2017

In a Federal Register Notice dated June 5, 2017, the EPA granted a reconsideration and partial stay of the Oil and Natural Gas New Source Performance Standards in NSPS OOOOa. Consult the Federal Notice EPA–HQ–OAR–2010–0505; FRL–9963–40–OAR for details.

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Specifically, the action is reconsidering:

  1. NSPS OOOOa equipment leaks monitoring for well sites and compressor stations.
  2. Pneumatic pumps standards and the requirements for certification by professional engineer regarding the technical infeasibility of not controlling or capturing the vent gas from the device.

The action gives a 90-day stay for compliance with the following listed items. The stay is effective from June 2, 2017, until August 31, 2017.

  1. Fugitive leak monitoring requirements at well sites and compressor station sites.
  2. Requirements for controlling affected pneumatic pumps using natural gas at a well sites.

To implement the stay, the action in the Federal Register notice modified the rules in 40 CFR 60 Subpart OOOOa. 

Reasons for the Stay

In the notice, the EPA stated that the stay was based on administrative petitions regarding various parts of NSPS OOOOa including:

  1. The applicability of the fugitive emissions requirements to low production well sites.
  2. The process and criteria for requesting and receiving approval for the use of an alternative means of emission limitations (AMEL) for compliance with fugitive emissions requirements.
  3. Requirements for certification of closed vent system by professional engineer for pneumatic pumps.
  4. Well site pneumatic pump standards.

This current action only applies to the above listed parts of NSPS OOOOa; it has no impact on NSPS OOOO requirements.

  1. NSPS OOOO applies to facilities constructed, modified or reconstructed after August 23, 2011, and on or before September 18, 2015.
  2. NSPS OOOOa applies to new affected facilities (equipment and processes) constructed, reconstructed and modified after September 18, 2015.

Get Prepared and Stay in Compliance

HY-BON/EDI can assist your company tocomply with all aspects of the NSPS OOOO and OOOOa rules. Our thorough understanding of oil and gas processes and expertise with storage tank emission controls (VRUs, VRTs, VCUs) and leak monitoring makes us a leader in providing certainty to your compliance needs.

Our IQR (Identify, Quantify and Rectify) services include leak monitoring that meets NSPS OOOOa requirements. Our IQR services can also assist with emission controls selection for your facility.

Contact us today g2khaH8@OSP&]#[vDxpr\NH\`d6 and g2khaH8@OSP&G#CE]#[[nXNU_{6W2@rPi//.