EPA Proposed Updates to the Gasoline Distribution Rule Appendix K
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Michael Stroud
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EPA Proposed Updates to the Gasoline Distribution Rule Appendix K

The Environmental Protection Agency continues its efforts to reduce climate-changing emissions related to fossil fuels industry, particularly around the oil and gas sector. In November 2022, EPA issued a proposed rule to strengthening its previous proposals to reduce harmful emissions such as methane and other harmful emissions. On November 15, EPA issued this supplemental proposal to update, strengthen, and expand previous proposed standards intended to significantly reduce emissions of greenhouse gases (GHGs).https://www.epa.gov/system/files/documents/2022-11/EPA%27s%20Supplemental%20Oil%20and%20Natural%20Gas%20Proposal.%20Changes%20Since%20November%202021.%20Fact%20Sheet.%20.pdf (EPA Link for supplemental information request). 

The EPA 2022 proposal sought to accomplish four tasks. First, the EPA proposes standards for certain sources that were not addressed in the November 2021 proposal. Second, the EPA proposes revisions that strengthen standards for sources of leaks, provide greater flexibility to use innovative advanced detection methods, and establish a super emitter response program. Third, the EPA proposes to modify and refine certain elements of the proposed standards in response to information submitted in public comments on the November 2021 proposal. Finally, the EPA proposes details of the timelines and other implementation requirements that apply to states to limit methane pollution from existing designated facilities in the source category under the Clean Air Act (CAA). 

To achieve the more comprehensive emissions reductions from oil and natural gas, EPA is proposing to improve standards and add supplemental protocols to help detect harmful emissions. The new standards and requirements are located in what is referred to as “Appendix K.” Specifically, the November 2022 proposal would include the use of optical gas imaging (OGI). OGI identifies methane leaks and other emissions using a thermal infrared camera.  

The proposed Appendix K would apply only if an EPA rule specifies that Appendix K should be used. Under the supplemental proposal for the oil and natural gas industry, it would apply to OGI surveys used to detect leaks at onshore natural gas processing plants. Additionally, the proposed Appendix K includes requirements for the performance of infrared cameras, operator training, developing operating envelopes for surveys, monitoring plans, and recordkeeping.  

To develop the proposed Appendix K requirements, EPA conducted a literature review of technology development and examined current applications of OGI technology. EPA commissioned laboratory studies and OGI technology evaluations and hosted a virtual workshop to gather input on OGI use and rule development. EPA is accepting public comments by February 13, 2023. EPA is also holding a public hearing on January 10, 11, and 12 on the proposed changes.  

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