New Rule Revisions for Oil and Gas Industry

On July 28, 2011 U.S. EPA released its draft Standards of Performance for New Stationary Sources (NSPS) and proposed revisions to the National Emission Standards for Hazardous Air Pollutants (NESHAP) rules affecting natural gas production, transportation, distribution, and storage. The Federal Register notice for the proposal appeared on August 23, 2011. The NSPS and NESHAP also affect oil production. Currently, the NSPS (40 CFR Part 60, Subparts KKK and LLL) regulate only gas processing plants while U.S. EPA’s NSPS proposal (40 CFR Part 60, Subpart OOOO) will affect well sites where “fracking” is taking place and will potentially regulate multiple pieces of equipment that have not been previously considered for regulation (e.g., compressors, pneumatic controllers, and condensate and crude oil storage tanks). The updated NESHAP standards for natural gas transmission and storage (40 CFR Part 63, Subpart HHH) consider emissions from glycol dehydrators and the revised NESHAP for oil and natural gas production (40 CFR Part 63, Subpart HH) affects glycol dehydrators, crude oil tanks, condensate tanks, and leaking valves at gas processing plants. 

U.S. EPA will elicit public comment for a 60-day period beginning on the date the proposed rules are published in the Federal Register. The public will also be able to participate in three (3) scheduled public meetings. ALL4 will provide a more detailed summary of the proposed rules in the September edition of 4 The Record.