Recent Changes and Update on NSPS OOOOa
March 27, 2018

On March 1, 2018, the U. S. Environmental Protection Agency (EPA) announced changes to NSPS OOOOa regarding monitoring of fugitive equipment leaks (aka LDAR) for well sites and compressor stations. The March 1, 2018, announcement will be effective after the rule changes are published in the Federal Register.

The changes included:

  1. Removal of requirements that sources of fugitive emission leaks be repaired during unscheduled or emergency shutdowns at well site and compressor stations. Owners and operators are still required to complete repairs during the next scheduled compressor station shutdown, well shutdown, well shut-in, after a planned vent blowdown, or within two years, whichever is earlier.
  2. Amends the fugitive emission leaks monitoring requirements to provide a separate monitoring schedule for well sites on the Alaskan North Slope to accommodate the area’s arctic climate.

No other changes were made to NSPS OOOOa. All other requirements are still in force.

NSPS OOOOa Pending Changes

On June 16, 2017, EPA proposed a two-year stay of the rule’s fugitive emissions LDAR requirements, well site pneumatic pump standards, and requirements that closed vent systems be certified by a professional engineer (PE) while the agency reconsidered issues associated with these requirements.

NOTE: The proposed two-year stay was never finalized.

These requirements are under review by EPA. The EPA requested comments on their Notice of Data Availability (NODA) published in the Federal Register on November 8, 2017. The comment period ended on December 8, 2017.

At this time, the LDAR requirements (except for the changes listed in March 1, 2018, announcement), well site pneumatic pump standards and PE certification of closed vent systems are still the same as the June 3, 2016, NSPS OOOOa rule. Companies must still comply with the rules as written.

EPA Small Business Guide to NSPS OOOOa

A good NSPS OOOOa resource for businesses is the EPA’s August 2016, “Small Entity Compliance Guide for Oil and Natural Gas Sector: Emission Standards for New, Reconstructed, and Modified Sources 40 CFR Part 60, Subpart OOOOa.”

See link to download: EPA NSPS OOOOa Guide Document

Get Prepared and Stay in Compliance

HY-BON/EDI can assist your company with NSPS OOOO and OOOOa compliance. 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 fugitive leak monitoring (LDAR) that meets NSPS OOOOa requirements. Our IQR services can also assist with emission controls selection for your facility.

Contact us today h7!Hfq*KZlY\]#[wI2Pw#@Sgymi and h7!Hfq*KZlY\3_J.]#[\sl*Z.mEbOIK@C6v.