EPA Poised To Relax Vapor Monitoring Deadlines and Streamline Bureaucratic Layers

Oilfield operators of every size have been busy implementing the Obama administration's labor-intensive requirements to detect and repair vapor leaks from wellsite equipment, often called the Quad Oa requirements, in reference to the federal rules at 40 CFR Part 60, Subpart OOOOa. On 11 September 2018, the US Environmental Protection Agency (EPA) announced proposed changes to these new source performance standards (NSPS) applicable to oil and gas well vapor leaks (known as "fugitive emissions"). EPA's proposed 2018 NSPS Rule would give operators more flexibility by allowing them to comply with certain state fugitive emissions requirements in lieu of federal requirements. The 2018 NSPS would also decrease the frequency of wellsite monitoring and extend the amount of time allowed for leak repairs. Additionally, the 2018 NSPS would clarify certain definitions for wellsite pneumatic pump standards and certification requirements.

These proposed changes would modify EPA's August 2016 final rule, "Oil and Natural Gas Sector: Emission Standards for New, Reconstructed, and Modified Sources." This 2016 NSPS Rule introduced fugitive emission standards for components at wellsites and compressor stations to control the emission of methane, a potent greenhouse gas, and other volatile organic compounds emissions. The following year, on 4 April 2017, the EPA announced that it would review the 2016 NSPS requirements. EPA's current 2018 NSPS proposal has been submitted for publication to the Federal Register. A final draft of the proposed rule is available on EPA's website. Following publication in the Federal Register, the EPA will accept comments on the 2018 NSPS for 60 days.

The most significant changes in the proposed 2018 NSPS Rule involve fugitive emissions monitoring and component repair requirements and the option to follow existing state monitoring and repair requirements in certain states, including Texas. "Fugitive emissions" refer to leaks that can occur at a wellsite or compressor station when the connections are not properly fitted, hatches are not properly weighted and sealed, or when seals and gaskets start to deteriorate. Overall, the proposed 2018 NSPS would streamline many fugitive emissions monitoring and repair requirements for well owners and operators.

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