On November 2, 2021, USEPA proposed sweeping regulations that would limit emissions of methane, a powerful greenhouse gas, and other harmful air pollution from facilities in the oil and gas industry. The proposed regulations would impact new and, for the first time, existing facilities in the production, gathering, processing, and transmission and storage segments.
The proposed rule under the New Source Performance Standards is a major step in the Biden administration’s larger plan to combat climate change.
For new sources constructed after the promulgation date (NSPS OOOOb), the proposed rule includes:
For existing sources, the proposed rule will apply retroactively to any existing operating facility constructed on or before the rule promulgation date – including those currently regulated under Subpart OOOO or OOOOa – by requiring states to meet the new emission guidelines through the development of State Implementation Plans. The requirements for existing sources will be more stringent than Subparts OOOO and OOOOa.
|Source type||Proposed requirement||Implications|
|Fugitive emissions: well sites with methane emissions > 3 tons per year (tpy)||
Quarterly optical gas imaging (OGI) for sites > 8 tpy
Semiannual OGI for sites > 3 tpy
|The monitoring threshold is based on methane and not volatile organic compounds (VOC). 3 tpy is equivalent emissions to single well battery.|
|Well liquids unloading||Zero methane emissions/best management practices||The rule is not specific to the technology, and the burden is on the operator to demonstrate that zero emission technology is not feasible.|
|Reciprocating compressors||Rod packing replacement
||Rod packing will be replaced based on monitored leak rate (2 scfm) as opposed to at scheduled intervals.|
|Pneumatic pumps at natural gas plants||Zero emission
||This is more stringent than current requirements to control to 95%.|
|Associated gas||Route to sales or use/control device
||Associated gas must be recovered for sale or use and can only be routed to flare if recovery is not feasible.|
Comments on the current proposal are due 60 days from promulgation and can be made at regulations.gov.
In addition, USEPA is soliciting comments for further proposals to control emissions from other source categories such as abandoned wells, pigging operations, blowdown activities and tank truck loading.