GPA Midstream Seeks EPA Clarification on NHV Monitoring Requirements

GPA Midstream submitted comments to the U.S. Environmental Protection Agency (EPA) requesting clarification on net heating value (NHV) monitoring and reporting requirements.

The request follows EPA's April 2026 amendments to the New Source Performance Standards for the crude oil and natural gas sector.

GPA Midstream expressed support for these updates and asked EPA to confirm how the NHV monitoring exemption should be applied in specific operating scenarios.

The association comments seek consistency between EPA's regulatory text and its preamble explanation. GPA Midstream asked EPA to confirm that operators may rely on the NHV monitoring exemption when they can demonstrate that any additional gas streams will not reduce the combined inlet stream below the minimum NHV threshold. Without this clarification, even minor changes to gas streams could be interpreted as triggering monitoring requirements, potentially leading to unnecessary compliance burdens without improving emissions outcomes.

GPA Midstream emphasized that operators should be able to make site-specific determinations using reasonable methods such as engineering analysis, process knowledge, operating history, and equipment specifications. The filing highlighted common scenarios - such as produced water tanks, storage vessel vent streams, and intermittent nitrogen purges - where clarification is important to avoid misinterpretation of the rule.

In addition to regulatory clarity, GPA Midstream asked for updates to EPA's reporting system to allow operators to clearly document when NHV monitoring is not required based on prior determinations.

Addressing the requests in the letter would align EPA's rules with their intended purpose, reduce compliance uncertainty, and enable regulators and operators to focus on conditions that meaningfully affect emissions performance.

Many details need to be finalized regarding OOOOb and OOOOc regulations. Members interested in engaging on this issue may join the Environmental Committee and the OOOO Workgroup.