EPA Oil and Gas NESHAP Technology Review - No Changes to Current Standards, New Methanol Limits Proposed
EPA completed its technology review of the National Emission Standards for Hazardous Air Pollutants (NESHAP) for crude oil and natural gas production facilities and natural gas transmission and storage facilities under Clean Air Act section 112. The Agency is not proposing any revisions to current emission standards in the Oil and Gas NESHAP. EPA is proposing new standards for methanol emissions from regulated emission points at crude oil production facilities.
The Federal Register notice details EPA’s findings from the mandatory eight-year technology review. The review examined whether more stringent standards are necessary and appropriate based on developments in practices, processes, and control technologies.
Current Standards Remain Unchanged
EPA’s analysis concluded that no revisions to existing NESHAP standards are warranted. The current requirements for benzene, toluene, ethylbenzene, xylene, n-hexane, and formaldehyde emissions from oil and gas facilities will continue to apply without modification.
What this means in practice: Existing monitoring, recordkeeping, and compliance obligations under 40 CFR Part 63, Subpart HH (for oil and gas production) and Subpart HHH (for natural gas transmission and storage) remain in effect. Facilities already subject to these requirements face no new compliance burdens from the technology review.
New Methanol Standards for Crude Oil Facilities
EPA is proposing emission standards for methanol from regulated emission points at crude oil production facilities. The proposed standards would apply to storage vessels, equipment leaks, and other emission sources already regulated under the NESHAP.
Specific methanol emission limits and compliance methods are detailed in the proposed rule text. The standards would require monitoring and control measures similar to those already in place for other hazardous air pollutants at these facilities.
How This Affects Environmental Consulting Work
Air Quality Permitting and Compliance
Consultants working on oil and gas facility permitting will continue using existing NESHAP requirements. No updates to air quality permit applications or compliance plans are needed based on the technology review findings.
Site Assessments Near Oil and Gas Operations
Environmental site assessments at properties adjacent to oil and gas facilities should continue evaluating potential impacts from currently regulated pollutants. The proposed methanol standards may require consideration of this additional pollutant in vapor intrusion evaluations and indoor air assessments.
Remediation Projects at Former Oil and Gas Sites
Cleanup standards and risk assessment approaches for sites with historical oil and gas operations remain unchanged. The technology review does not affect soil or groundwater cleanup levels for petroleum hydrocarbons or other contaminants typically found at these sites.
What to Watch
EPA will accept public comments on the proposed methanol standards through the Federal Register comment period. The Agency has not announced a timeline for finalizing any new methanol requirements.
The next mandatory technology review for the Oil and Gas NESHAP will occur in 2034, eight years after completion of the current review.
Bottom Line
The Oil and Gas NESHAP technology review maintains the status quo for existing emission standards while potentially adding methanol controls at crude oil facilities. Environmental consultants can continue using current regulatory frameworks for air quality work at oil and gas operations. For detailed air quality standards and monitoring requirements, see our program overviews.