NSPS OOOO Compliance: 7 Mistakes Small Oil & Gas Operators Are Making (And How to Fix Them)

Your methane emissions are being watched. And if you think the EPA isn't paying attention to smaller operators, think again. NSPS OOOO compliance isn't just for the big players anymore: it's becoming the difference between staying in business and facing hefty fines that can shut down operations overnight.

The New Source Performance Standards (NSPS) OOOO and OOOOa regulations are like a regulatory minefield. One wrong step, and you're looking at violations that can cost thousands of dollars per day. But here's the thing: most small oil and gas operators are making the same seven critical mistakes when it comes to compliance.

Let's dive into these mistakes and, more importantly, how to fix them before they cost you your business.

Mistake #1: Playing Russian Roulette with Equipment Identification

The mistake: Many small operators assume they know which equipment falls under NSPS OOOO without conducting a proper assessment. They're essentially playing Russian roulette with a blindfold on.

Here's what's really happening: NSPS OOOO applies to facilities where construction, modification, or reconstruction commenced after August 23, 2011, but on or before September 18, 2015. NSPS OOOOa covers facilities where work began after September 18, 2015. These regulations control volatile organic compounds (VOCs), methane emissions, and sulfur dioxide from equipment including hydraulically fractured natural gas wells, crude oil storage tanks, pneumatic pumps, and compressors.

The fix: Stop guessing. Conduct a comprehensive equipment inventory with a qualified compliance consultant. Document every piece of equipment with its installation date, modification history, and applicable regulations. You need to know exactly what you're dealing with before you can manage it properly.

Mistake #2: Treating Asset Management Like an Optional Extra

The mistake: Small operators often view asset management systems as "nice to have" rather than compliance necessities. This is like trying to navigate cross-country with a torn road map from 1995.

The first critical step in NSPS compliance is identifying applicable equipment and sources. This requires determining which equipment and facilities at your operation fall under EPA OOOOa regulations, including well sites, compressor stations, and pneumatic controllers. Without proper asset management, you're flying blind.

The fix: Implement a systematic asset management approach. This doesn't require expensive software: even a well-organized spreadsheet can work for smaller operations. Track every applicable piece of equipment with its compliance requirements, inspection schedules, and maintenance records. Make this your operational bible.

Mistake #3: Confusing OOOO with OOOOa Requirements

The mistake: Treating OOOO and OOOOa as the same regulation is like using a screwdriver when you need a wrench: wrong tool, wrong results.

Many operators don't realize these are distinct regulations with different requirements and timelines. OOOOa is generally more stringent and applies to newer facilities, but both can affect your operations simultaneously if you have equipment from different installation periods.

The fix: Create separate compliance checklists for OOOO and OOOOa requirements. Know which regulation applies to which equipment. When in doubt, assume the more stringent OOOOa requirements apply: it's better to over-comply than face violations.

Mistake #4: Ignoring the NHV Monitoring Deadline Ticking Bomb

The mistake: While most operators know about the January 2027 deadline extensions, many are overlooking the shorter Net Heating Value (NHV) monitoring deadline of November 28, 2025.

This is a critical oversight. On July 28, 2025, the EPA extended most compliance deadlines to January 22, 2027, but NHV monitoring requirements got only a short extension. This deadline is approaching fast, and many operators aren't prepared.

The fix: Prioritize NHV monitoring compliance immediately. Don't wait until late 2025 to address this requirement. Set up your monitoring systems, train your staff, and establish proper documentation procedures now. Treat this as your highest priority compliance item.

Mistake #5: Running Leak Detection Programs Like Weekend Hobby Projects

The mistake: Approaching equipment leak detection and repair (LDAR) programs with a casual, "when we get around to it" mentality. This is like having a smoke detector with dead batteries: it looks like you're protected, but you're actually at serious risk.

NSPS regulations require systematic leak detection programs with specific frequencies and repair timelines. Many small operators either skip regular monitoring or fail to properly document their efforts.

The fix: Establish a formal LDAR program with:

• Scheduled monitoring intervals based on equipment type

• Trained personnel who understand proper detection techniques

• Clear repair protocols with documented timelines

• Proper recordkeeping that can withstand regulatory scrutiny

Remember, consistency beats perfection. A simple, well-executed program trumps a complex system that gets ignored.

Mistake #6: Treating Flare Monitoring Like Set-and-Forget Technology

The mistake: Installing flares and enclosed combustion devices without proper ongoing monitoring and maintenance programs. This is like buying a car and never checking the oil.

Flares require continuous compliance monitoring, proper operation, and regular maintenance. Many operators install compliant equipment but fail to maintain compliance over time.

The fix: Develop comprehensive flare management procedures including:

• Regular performance monitoring to ensure proper combustion efficiency

• Maintenance schedules for pilot systems and control equipment

• Documentation protocols for all monitoring and maintenance activities

• Emergency response procedures for flare system failures

Your flares are working 24/7: your monitoring program should match that commitment.

Mistake #7: Keeping Records Like They're State Secrets

The mistake: Poor documentation and recordkeeping that makes proving compliance impossible during inspections. This is like claiming you studied for a test but having no notes to show for it.

Many small operators focus on doing the work but fail to document it properly. When regulators come calling, good intentions don't count: only documented compliance matters.

The fix: Implement a systematic recordkeeping approach:

• Document everything in real-time, not after the fact

• Use standardized forms for consistent data collection

• Maintain backup systems for critical compliance records

• Regular record reviews to ensure completeness and accuracy

• Easy retrieval systems for inspection readiness

Think of your records as your insurance policy against violations. They need to be comprehensive, accurate, and readily available.

The Path Forward: Smart Compliance for Small Operators

Here's the reality: NSPS OOOO compliance doesn't have to be overwhelming. The key is systematic preparation and professional guidance. While the regulations are complex, the compliance approach can be straightforward with the right expertise.

Consider working with experienced compliance consultants who understand both the regulatory requirements and the practical challenges facing small operators. Professional compliance consulting can help you avoid these common mistakes while developing cost-effective compliance strategies.

Your Next Steps

Don't wait until you're facing a violation notice to address these issues. Start with equipment identification and asset management: these form the foundation of everything else. Then tackle the NHV monitoring requirements given the shorter timeline.

Remember, compliance isn't just about avoiding fines: it's about protecting your business, your employees, and the environment. You're worth more than a checkbox on a regulatory form. Invest in proper compliance systems that will serve your operation for years to come.

The extended deadlines give you breathing room, but that time window is closing. Use it wisely. Your future self will thank you for the effort you put in today.

Ready to get your NSPS OOOO compliance on track? The mistakes are common, but they're also completely preventable with the right approach and expert guidance.