On December 2, 2023, EPA released the final rule language from the original proposal introduced in December of 2022. EPA has made some changes to various items from the proposed rule language, such as:
- Revised new source date to December 6, 2022 from November 15, 2021
- Included a year phase in for process controllers and natural gas-driven pneumatic pumps
- Updated liquids unloading requirements to be best management practices instead of zero emissions
- Revised the super emitter program that aims to increase EPA involvement and exclude OGI surveys as a method for monitoring these occurrences
- Revised dry seal activation level to 10 scfm per seal
NSPS OOOOb
The updates to NSPS Subpart OOOOb will impact various sources in the Oil and Gas sector that were constructed, reconstructed, or modified after December 6, 2022. The final rule will be in place once it is published in the Federal Register. The original proposed rule language included significant changes that would force the industry to greatly reduce its VOC and methane emissions.
The final rule language in Subpart OOOOb has been updated to address various concerns from stakeholders. While rigorous requirements remain, there is a phase in period for certain affected facilities that are subject to this standard such as process controllers and pumps. When compared to its predecessor, Subpart OOOOa, Subpart OOOOb is much more restrictive and will potentially require significant capital investment from the Oil and Gas industry.
EG OOOOc
The emission guideline that has been released congruently with NSPS OOOOb is Emission Guideline (EG) OOOOc. Similar to NSPS OOOOb, EG OOOOc incorporates various comments from stakeholders that were not accounted for in the proposed rule language. EG OOOOc seeks to have states incorporate these emission guidelines into their State Implementation Plan (SIP). All existing sources in the industry will need to comply with the emission guidelines in the prescribed timeline. States will have 18 months to implement the guidelines into their SIP. Industry will have 36 months for compliance with these updated rules.
Looking for a platform to learn more about these rules and discuss with others in the oil and gas industry? Trinity is offering in-person collaborative workshops in various cities across the country. Click here to see if we are coming to a city near you!
