The oil and gas sector has seen massive regulatory change since 2016, particularly with respect to air compliance requirements. Regulations have issued, withdrawn, and modified by multiple regulatory agencies. In addition, challenges to some of these regulations have been made in the courts. The end result is a confusing mix of regulations, policies and expectations.
This workshop will provide some clarity and direction about what the oil and gas sector should be doing now. While not providing formal legal guidance, the workshop will address the compliance challenges confronting upstream and midstream oil and gas companies in meeting EPA and BLM regulations, as well as some evolving issues at the State level. We will particularly focus on EPA’s New Source Performance Standard (NSPS) OOOOa requirements around the implementation of a volatile organic compound (VOC) and methane leak detection and repair (LDAR) monitoring and reporting program as well as associated with the final Bureau of Land Management (BLM) venting and flaring rule (e.g., Waste Prevention) requirements. We will also provide some insights and approaches to recordkeeping and reporting approaches under these programs.