The U.S. Environmental Protection Agency’s (EPA) September 18, 2015, proposal to tighten New Source Performance Standards (NSPS) applicable the oil and gas industry is primarily recognized for its first-ever direct regulation of methane emissions and for its expansion of the existing NSPS (Subpart OOOO) from natural gas wells to both natural gas and oil wells. While the agency’s proposal is most closely associated with these “upstream” sources, it also represents, not only the first effort to regulate methane emissions from oil and gas transmission equipment, but the first regulation of air emissions from equipment and facilities in the midstream sector. “Midstream” operations link “upstream” to “downstream” refining and marketing. Midstream activities are focused on transportation (particularly pipeline transportation), but also encompass processing and storage facilities.
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