Paper: Examining NSPS Updates Affecting the Oil and Gas Industry

In an effort to reduce the emissions of Volatile Organic Compounds (VOCs), EPA has passed several regulations that affect the oil and gas industry in a variety of ways. The resulting regulatory quagmire can be difficult to understand and this can make ensuring compliance challenging. This paper examines the recently passed updates to 40 CFR 60 New Source Performance Standard (NSPS) Subparts J, Ja, KKK, LLL, IIII, JJJJ and the new Subpart OOOO. A regulatory review is provided for each subpart that provides a brief explanation of the subpart, affected facilities, and basic compliance requirements, including monitoring, reporting and recordkeeping (MRR) requirements. Compliance strategies, such as flowcharts and relationship entity tables, will be introduced with appropriate subparts when available.