EPA Delays Air Regulations
EPA has announced postponements of air emissions regulations due to go into effect this summer.
EPA has announced at least four postponements of upcoming regulations regarding air emissions and air quality.
⚡ TL;DR: Some air regulations face implementation delays, but compliance deadlines for existing rules remain firm. Manufacturers should not interpret delays as permission to postpone compliance work.
RMP Rule Amendment
In the final days of the Obama administration, EPA issued amendments to the Risk Management Program (RMP) rule. These included additional requirements for process hazard analysis, incident investigation, emergency preparedness, public availability of chemical hazard information, additional regulatory definitions, and audit requirements. In order to give the agency more time to review petitions, hear additional comments, and consider revisions, the new effective date has been moved to February 19, 2019.
Emissions Standards for New, Reconstructed, and Modified Sources for Oil and Gas; NSPS Subpart OOOOa
EPA has issued a stay on certain parts of OOOOa until August 31, 2017. It is reconsidering the rule as a whole, including fugitive emissions monitoring requirements for well sites and compressor stations. Initially, companies were to have a monitoring plan in place and perform initial LDAR compliance by June 6, 2016. EPA also wants to take another look at the entire rule. For now, they’ve issued a stay on fugitive emissions requirements, PE certifications, and standards for pneumatic pumps at well sites.
Ozone Standard
EPA has delayed the National Ambient Air Quality Standards (NAAQS) for ground level ozone. EPA is giving states another year to develop and refine their air quality plans. Last fall, states were to turn in their recommendations on what to do about those areas which couldn’t reach the 70 ppb standard. Then EPA was to make their final designations and set those recommendations into motion by October of this year. Now those designations have been postponed to October 2018.
Landfill Methane Emissions From Municipal Solid Waste Landfills
Over 1,000 municipal solid waste facilities were going to be impacted by two separate standards relating to methane emissions. EPA has issued a stay until August 29 to reconsider items such as design approval, definition of cover penetration, annual liquids reporting, surface emissions reporting, corrective action timelines, and overlapping requirements. EPA estimates that implementation of the changes as written could cost businesses more than $100 million per year to install and operate gas collection and control systems.
⚠️ What’s at stake: Noncompliance with federal environmental regulations results in significant civil and criminal penalties, operational shutdowns, and facility remediation costs that can exceed millions of dollars.
Frequently Asked Questions
Q: What is the EPA’s Risk Management Program (RMP) rule and what does it regulate?
The EPA’s Risk Management Program (RMP) rule requires facilities handling hazardous chemicals to develop risk management programs including process hazard analysis, incident investigation procedures, emergency preparedness plans, and audit requirements. The RMP rule aims to prevent accidental releases of hazardous chemicals that could harm workers or the public. Recent amendments expanded RMP requirements for public disclosure of chemical hazard information. Facilities storing or processing chemicals above threshold quantities must comply with RMP requirements. iSi Environmental helps facilities in Kansas, Oklahoma, and Texas develop comprehensive RMP programs.
Q: What is LDAR and why is it important for oil and gas operations?
LDAR (Leak Detection and Repair) is a fugitive emissions monitoring program required by EPA for oil and gas facilities including well sites, compressor stations, and pipeline operations. LDAR requires periodic inspections to identify leaks of volatile organic compounds and methane, repairs within specified timeframes, and documentation of monitoring and repair activities. LDAR reduces greenhouse gas emissions and improves air quality. EPA NSPS Subpart OOOOa specifies LDAR monitoring frequency and PE (Professional Engineer) certification requirements. iSi Environmental helps oil and gas operators implement compliant LDAR programs.
Q: What are the National Ambient Air Quality Standards (NAAQS) and how do they affect facility operations?
NAAQS are EPA standards for outdoor air quality for pollutants like ozone, particulate matter, nitrogen oxides, and sulfur dioxide. States must develop air quality plans to meet NAAQS standards in all areas (attainment areas maintain standards, non-attainment areas work toward compliance). Facilities in non-attainment areas face tighter permitting requirements and may need additional emission controls. EPA designates attainment/non-attainment status and sets compliance timelines. Facilities must monitor applicable NAAQS standards for their region. iSi Environmental helps facilities assess NAAQS impacts on their operations and permitting.
Q: What methane emissions standards apply to municipal solid waste landfills?
EPA has issued standards for methane emissions from municipal solid waste landfills requiring gas collection and control systems, annual liquids monitoring, surface emissions reporting, and corrective actions for non-compliance. The standards aim to reduce methane emissions and greenhouse gases. Implementation requires capital investment in collection systems and ongoing operational costs. Landfill operators must comply with design approval, cover penetration standards, and reporting requirements. iSi Environmental helps landfill operators implement compliant methane emissions control systems.
Not sure where your facility stands with current regulations? iSi Environmental helps manufacturing facilities and industrial operations understand their compliance obligations and close operational gaps. Get started with a compliance assessment.
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