4 The record articles

Further Delay of Implementation of Certain NSPS Subpart OOOOa Requirements

Posted: June 29th, 2017

Authors: Roy R. 

On June 5, 2017, the U.S. Environmental Protection Agency (U.S. EPA) granted reconsideration and stayed the effectiveness of certain fugitive emissions, pneumatic pump, and Professional Engineer (P.E.) certification requirements of 40 CFR Part, 60 Subpart-OOOOa Standards of Performance for Crude Oil and Natural Gas Facilities (Subpart OOOOa) until August 31, 2017.  Less than two weeks later, U.S. EPA proposed to further extend these stays.  In two separate Federal Register (FR) notices published on June 16, 2017, U.S. EPA is proposing the following:

  • A stay of two years beyond August 31, 2017 for the requirements mentioned above.  The intent of the two-year stay is to provide U.S. EPA with sufficient time to propose, accept comment, and issue permanent changes to Subpart OOOOa
  • An additional 3-month stay that would be effective immediately upon publication to the FR because it would not be considered a major rule change.  Since the two-year stay is expected to be considered a major rule under the Congressional Review Act, it cannot become effective immediately upon publication to the FR.  To avoid a potential gap between the current 2-month stay that was issued on June 5, 2017 and the finalization of the proposed 2-year stay, U.S. EPA is proposing this additional 3-month stay.

We believe more changes are in store for Subpart OOOOa beyond those addressed in the current stays.  ALL4 will continue to track these changes and will provide updates our blog and newsletter, accordingly.  In the meantime, if you have questions regarding your current obligations under Subpart OOOOa, contact Roy Rakiewicz at 610.933.5246 x127, or rrakiewicz@all4inc.com.


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