natural gas transmission and storage facilities.
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In the transmission and storage segment,
compressors are used to maintain the pressure of the natural gas in transmission pipelines to
deliver extracted gas to its eventual end-user. Maryland’s Control of Methane Emissions from the
Natural Gas Industry regulations affect new and existing natural gas compressor stations, one
liquefied natural gas facility, and one underground storage facility in the transmission and storage
segment. The regulations set requirements to mitigate methane emissions through fugitive
emissions leak detection and repair, and control measure requirements to limit emissions from
compressors and pneumatic devices. Facility-wide GHG emission data is required to be calculated
and submitted to MDE annually. Additionally, owners and operators are required to notify MDE
and the public during “blowdown events,” which are the release of pressurized natural gas from
stations, equipment, or pipelines into the atmosphere so that maintenance, testing, or other
activities can take place.
Maryland adopted regulations as the EPA stalled and reversed direction on the stringency of
controls in the oil and gas industry from 2016 to 2021. Maryland regulations to detect and
mitigate methane emissions apply to both new facilities as well as existing facilities. This was a
more stringent approach than EPA had required in a 2016 New Source Performance Standards
(NSPS) rule for the oil and natural gas industry (40 CFR Part 60, Subpart OOOOa or 2016 NSPS
OOOOa) emission reduction of volatile organic compounds (VOCs) and methane.
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Then in 2018
and 2019, EPA proposed relaxation and reconsideration amendments to certain provisions of the
2016 NSPS OOOOa. EPA reduced the sources affected in each sector, rescinded all the methane
reduction requirements and kept only VOC requirements, minimized the leak detection
requirements, and reduced reporting requirements.
Maryland supports national rules for this industry sector as many states have much more activity
in oil and gas production than Maryland. Maryland, along with 14 other states, opposed EPA’s
reconsiderations and joined litigation against EPA for failing to perform a legal duty to control
emissions of methane from existing oil and gas operations.
Beginning in 2021, EPA reversed its direction and announced policies to strengthen the controls
required for GHG emissions in the oil and gas industry. In November 2021, EPA proposed New
Source Performance Standards Updates and Emissions Guidelines to Reduce Methane and Other
Harmful Pollution from the Oil and Natural Gas Industry.
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The proposal would expand and
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The U.S. Environmental Protection Agency. EPA Proposes New Source Performance Standards Updates,
Emissions Guidelines to reduce Methane and Other Harmful Pollution from the Oil and Natural Gas
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The U.S. Environmental Protection Agency. Crude Oil and Natural Gas Production, Transmission and
Distribution for Which Construction, Modification, or Reconstruction Commenced after August 23, 2011
and on or before September 18, 2015: New Source Performance Standards (NSPS).
https://www.epa.gov/stationary-sources-air-pollution/crude-oil-and-natural-gas-production-transmission-a
nd-distribution .
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The Maryland Department of the Environment. Maryland finalizes regulations to phase out
hydrofluorocarbons and reduce methane emissions.
https://news.maryland.gov/mde/2020/11/13/maryland-finalizes-regulations-to-phase-out-hydrofluorocarb
ons-and-reduce-methane-emissions/ .