NSPS Subpart OOOO:

pdf IPAA Comments on proposed revisions to Quad O storage vessel regulations (pdf) 69.03 kB

pdf Independent Producers Second Rulemaking Comments (pdf) 1.58 MB

In August 2012, the U.S. Environmental Protection Agency (EPA) finalized elements of its Clean Air Act (CAA) New Source Performance Standards (NSPS) and National Emission Standards for Hazardous Air Pollutants (NESHAPS) for the Oil and Natural Gas Sector. The NSPS portion, under Subpart OOOO of the US Code of Federal Regulations (CFR), applies to affected facilities that commence construction, reconstruction, or modification after August 23, 2011.

IPAA Training Materials:

(1) IPAA created a compliance guide to help operators understand the theoretical steps for determining whether an operator’s storage vessel is subject to Subpart OOOO. (pdf IPAA NSPS Storage Tank Compliance Guide (pdf) 154.18 kB )

(2) IPAA worked with the consulting firm Trinity Consultants to develop a presentation that explains EPA’s NSPS Subpart OOOO. This web-based presentation, among other things, provides tools to help operators calculate their “potential to emit” pollutants regulated under the NSPS Subpart OOOO. The “potential to emit” calculation is essential to determine if the NSPS regulations apply to the facility. Please note that actual calculation methods involve field work and technical assistance, whether performed in-house or through hired consultants. However, this presentation should provide helpful insights. (pdf NSPS OOOO Storage Tank IPAA Webinar Slides (pdf) 4.85 MB )

(3) Finally, operators can find additional information related to EPA’s Subpart OOOO on EPA’s website – found here with a list of manufacturer-tested combustion control devices available here.

Notification Requirement for Well Completions:

Operators should note that EPA’s requirements for natural gas well completion notifications took effect on October 15, 2012. Pursuant to this aspect of NSPS Subpart OOOO, companies are required to provide advance notice of hydraulic fracturing. Companies can meet this provision by complying with state advance notification requirements. If a state does not have an advance notification requirement, companies must inform EPA no later than two days before the well completion using hydraulic fracturing begins by sending an email to the appropriate EPA region – email addresses found here.