What Is 40 CFR Part 60 Subpart OOOO?
40 CFR Part 60 Subpart OOOO, often called “Quad O,” is a set of federal regulations under Title 40 of the Code of Federal Regulations (CFR), which deals with environmental protection. Specifically, it falls under Part 60, the “Standards of Performance for New Stationary Sources” (NSPS), administered by the U.S. Environmental Protection Agency (EPA). Subpart OOOO establishes emission standards for the crude oil and natural gas production, transmission, and distribution sector, targeting volatile organic compounds (VOCs) and, indirectly, methane emissions from new or modified sources.
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Full Title: Standards of Performance for Crude Oil and Natural Gas Facilities for Which Construction, Modification, or Reconstruction Commenced After August 23, 2011, and On or Before September 18, 2015.
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Published: August 16, 2012, in the Federal Register (77 FR 49542), with amendments since.
What It Covers
Subpart OOOO applies to specific “affected facilities” in the oil and gas industry built, modified, or reconstructed within that date range. It’s part of the EPA’s effort under the Clean Air Act to curb air pollution from this sector. The facilities include:
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Gas Wells: New or hydraulically fractured wells (focus on well completions).
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Storage Vessels: Tanks holding crude oil, condensate, or produced water with potential VOC emissions above 6 tons per year.
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Centrifugal and Reciprocating Compressors: Equipment at processing plants or transmission lines.
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Pneumatic Controllers: Gas-driven devices used for process control (e.g., at well sites or compressor stations).
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Equipment Leaks: VOC leaks from components at onshore natural gas processing plants.
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Sweetening Units: Facilities removing hydrogen sulfide (H2S) from natural gas, with sulfur dioxide (SO2) emission limits.
Not covered: facilities after September 18, 2015 (those fall under Subpart OOOOa), or downstream of custody transfer to local distribution companies.
Key Requirements
The regulation sets performance standards to reduce VOC emissions, with specific actions depending on the facility type:
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Well Completions: For hydraulically fractured wells, operators must use “green completions” (Reduced Emission Completions, or RECs) to capture and route gas to a sales line or flare it, minimizing venting. Exceptions allow flaring if capture isn’t feasible.
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Storage Vessels: Tanks emitting over 6 tons of VOCs annually need controls (e.g., vapor recovery or 95% emission reduction via flares or other devices).
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Compressors: Centrifugal compressors with wet seals must reduce emissions by 95% (e.g., via flares), while reciprocating compressors require rod packing replacement every 26,000 hours or 36 months.
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Pneumatic Controllers: Must be low-bleed (less than 6 cubic feet/hour) unless high-bleed is justified for safety or function.
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Equipment Leaks: At gas plants, operators must implement a leak detection and repair (LDAR) program using methods like EPA Method 21.
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Sweetening Units: SO2 emissions must meet reduction efficiency tables (e.g., 99.9% for high sulfur output), with monitoring and testing.
Compliance and Reporting
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Initial Compliance: Operators demonstrate compliance via performance tests (e.g., for control devices), inspections, and records (e.g., well completion logs).
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Ongoing: Annual reports detail emissions, control device performance, and maintenance. Records must be kept for 5 years.
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Notifications: Submitted to the EPA or state agencies for startups, completions, or changes.
Why It Matters
Subpart OOOO was the EPA’s first big swing at regulating oil and gas emissions under the NSPS framework. VOCs contribute to ozone (smog), and methane (a potent greenhouse gas) often comes along for the ride, though methane wasn’t directly regulated here—it was a co-benefit. The rule came after a 2011 lawsuit by environmental groups forced the EPA to update NSPS for this sector, which hadn’t been touched since the 1980s.
Context as of March 13, 2025
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Evolution: Subpart OOOO only applies to facilities from August 23, 2011, to September 18, 2015. Later rules—Subpart OOOOa (2016, adding methane standards) and OOOOb/OOOOc (2024, expanding methane controls)—built on it. If a facility modifies post-2015, it might shift to those newer rules.
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Current Sentiment: Posts on X today highlight confusion (e.g., media mistaking “OOOO” for a typo), but also industry gripes about compliance costs versus environmentalists pushing for tighter rules. The regulation’s still active, though enforcement varies by administration.
Bottom Line
40 CFR Part 60 Subpart OOOO is a Clean Air Act regulation clamping down on VOC emissions from new or modified oil and gas facilities in a specific time window. It’s technical, industry-specific, and a bit of a relic now with newer rules in play—but it’s still law for those older sources. If you want details on a specific part (like well completions or compliance headaches), just ask!