Minor Source General Permits

VOC and Methane Standards for the Crude Oil and Natural Gas Source Category

On November 30, 2023, EPA finalized new volatile organic compound (VOC) and methane standards for the crude oil and natural gas source category.  This rulemaking was published in the Federal Register on March 8, 2024, and became effective on May 7, 2024.

The aforementioned rules include 40 CFR 60 Subpart OOOOb – Standards of Performance for Crude Oil and Natural Gas Facilities for Which Construction, Modification or Reconstruction Commenced After December 6, 2022.  Subpart OOOOb requires tank batteries with potential VOC emissions of 6 tons per year or more and/or methane emissions of 20 tons per year or more to be controlled.  Tank batteries with potential emissions below these thresholds (accounting for all legally and practically enforceable limits established by the permitting authority) do not require controls.

Most crude oil and natural gas production facilities in Louisiana are permitted under the Minor Source Air General Permit for Crude Oil and Natural Gas Production (i.e., the MSOG).  On July 31, 2024, LDEQ proposed to modify the MSOG to add the requirements of Subpart OOOOb and to establish legally and practically enforceable limits consistent with 40 CFR 60.5365b(e)(2) such that tank batteries constructed, modified, or reconstructed after December 6, 2022, with potential VOC and methane emissions of less than 6 and 20 tons per year, respectively, are not subject to Subpart OOOOb.  The comment period on the proposed modifications to the MSOG ends on September 4, 2024.

The following minor source general permits have been issued by LDEQ: