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New Compliance Guide from EPA for Small Oil and Gas Operations

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A new Small Entity Compliance Guide has been released to help small oil and gas operations comply with the latest federal air quality emission standards. Published by the U.S. Environmental Protection Agency (EPA), this guide aims to simplify adherence to the 40 CFR Part 60, Subpart OOOOb regulations, which cover new, reconstructed, and modified sources within the oil and natural gas sector.

Overview

The guide, developed under the Small Business Regulatory Enforcement Fairness Act (SBREFA), addresses essential environmental and human health issues by setting standards to control greenhouse gas (GHG) and volatile organic compound (VOC) emissions from affected facilities. It provides a structured approach for small entities to navigate the complex regulatory landscape and ensure compliance with federal standards.

Key Features

  1. Applicability:
    • The guide outlines which entities and facilities are subject to the new standards, including specific criteria for well completions, liquids unloading, and associated gas management.
  2. Compliance Timetable:
    • A detailed timetable is provided to help small businesses understand the compliance deadlines for different types of facilities. For example, new or modified sources that commenced construction after December 6, 2022, must adhere to the regulations starting May 7, 2024.
  3. Super-Emitter Events:
    • It introduces the Super-Emitter Program, which mandates reporting and corrective actions for significant methane emissions events (100 kg/hr or more).
  4. Detailed Requirements:
    • Sections in the compliance guide cover specific environmental compliance requirements, such as testing, monitoring, reporting, and record-keeping for various types of equipment and operations.
  5. Support and Resources:
    • The compliance guide includes contact information for further assistance and references to additional resources and documents to help small entities stay compliant.

Compliance Support

Small oil and gas operators in Pennsylvania are encouraged to review the guide thoroughly and reach out for assistance in implementing these new standards. For more detailed information, the full compliance guide can be accessed or downloaded here.
Jeremy Hancher is the EMAP Program Manager located at the Widener University SBDC.  He holds over 15 years of experience in environmental compliance, environmental policy, and program management.  He is proud to be the team lead of the award-winning EMAP program which provides free and confidential environmental assistance to the Pennsylvania small business community in fulfillment of the requirements of the Pennsylvania Air Pollution Control Act and Section 507 of the federal Clean Air Act.
In 2015, Jeremy was part of the team effort when EMAP was recognized by US EPA Administrator Gina McCarthy for Outstanding Accomplishments by a State Small Business Environmental Assistance Provider in Providing Technical Environmental Assistance to the Small Business Community. Jeremy holds a Bachelor’s degree from the University of Pittsburgh, a Master’s degree from the University of Pennsylvania, and a certificate from the Wharton School.