EPA’s Methane Agenda – Will the Oil & Gas NSPS OOOOa...

Presented By:

Jay Christopher

Trihydro Corporation

EPA’s Methane Agenda – Will the Oil & Gas NSPS OOOOa Regulation Affect Other Sectors?

Why Should Other Sectors Care About Oil & Gas NSPS Requirements?

Methane is not a big issue to us, isn’t that what

this rule is all about?



Methane is not a big issue to us, isn’t that what

this rule is all about?


Not exactly.


• EPA often uses precedent in many different ways.

• The rule has several issues that could become precedent

setting for the other industry sectors.

• While we all have plenty to worry about (that is why we

are here this week), we need to pay attention to these

other issues.



• Topics where NSPS OOOOa may

establish, directly or indirectly,

some important precedents

affecting other sectors:

• Leak detection and repair programs

• NSPS General Provisions,

particularly around “modification”

and “affected facilities”

• Methane

• Next Generation Compliance


• New Source Performance Standards (NSPS) Subpart OOOOa –

“Standards of Performance for Crude Oil and Natural Gas Facilities for

which Construction, Modification, or Reconstruction Commenced After

September 18, 2015”

• Proposed on September 18, 2015; final on June 3, 2016; effective date

August 2, 2016

• NSPS VVa level of control for VOC and methane for new, modified, and

reconstructed equipment, except optical gas imaging is preferred

method

• Expanded the NSPS OOOO source category (e.g. oil well completions,

pneumatic pumps, and fugitive emission components at well sites and

compressor stations)

• Incorporates Next Generation compliance tracking, verification, and

electronic reporting requirements

NSPS OOOOa Background


Leak Detection and Repair (LDAR)

Here’s a new acronym for you

BSER

EPA’s Methane Agenda – Will the Oil & Gas NSPS OOOOaRegulation Affect Other Sectors?

Leak Detection and Repair (LDAR)

Best System of Emissions

Reduction

Clean Air Act Section 111(a)(1) defines a standard of performance as

“(A) standard for emissions of air pollutants which reflects the degree

of emission limitation achievable through the application of the best

system of emission reduction which (taking into account the cost of

achieving such reduction and any non-air quality health and

environmental impact and energy requirement) the Administrator

determines has been adequately demonstrated.’’


LDAR – OOOOa BSER Determinations

Source BSERFinal Standards of

Performance for GHGs and VOCs

Fugitive emissions from well sites and compressor stations

Well Sites: Monitoring and repair based on semiannual monitoring using optical gas imaging (OGI)

Monitoring and repair of fugitive emission components using OGI with Method 21 as an alternative at 500 ppm

A monitoring plan must be developed and implemented and repair of the sources of fugitive emissions must be completed within 30 days of finding fugitive emissions

Compression Stations: Monitoring and repair based on quarterly monitoring using OGI

Equipment leaks at natural gas processing plants

Leak detection and repair at 40 CFR part 60, subpart VVa level of control

Follow requirements at NSPS part 60, subpart VVa level of control as in the 2012 NSPS

EPA’s Methane Agenda – Will the Oil & Gas NSPS OOOOaRegulation Affect Other Sectors?

What Should We Pay Attention to Regarding LDAR and BSER?

• As BSER, optical gas imaging (OGI) is not just favored over

Method 21, OGI is now recognized as a demonstrated

emission reduction technology.

• EPA abandoned skip period monitoring and specifies fixed

monitoring frequencies (semiannual for well sites, quarterly for

compressor stations), regardless of performance.

• EPA selected 500 ppm as the Method 21 leak rate if using

Method 21 for initial or follow-up monitoring in lieu of OGI,

based on the concept that a camera can sometimes see leaks

under 10,000 ppm.


• Frequency of monitoring.

• Methodology (OGI or Method 21).

• Instrumentation information

(manufacturer and model number).

• Procedures and timeframes for

identifying and repairing fugitive

emissions components from which

fugitive emissions are detected, including

timeframes for fugitive emission

components that are unsafe to repair.

• Procedures to verify component repairs.

• Records that will be maintained under

the monitoring program.

• Site map

• A defined observation path that

ensures fugitive emissions

components are within sight of the

path. The observation path must

account for interferences.

• If using Method 21, a list of equipment

to monitored and how components will

be identified in the field (i.e., tagging,

P&ID drawings, etc.).

• A written plan for all of the fugitive

emission components designated as

difficult-to-monitor.

• A written plan for fugitive emission

components designated as unsafe-to-

monitor.

LDAR – Emissions Monitoring Plans


• If using OGI:

• Verification that OGI equipment meets

specification in the regulation.

• Ability to image the gases in the spectral

range for the compound of highest

concentration.

• Capable of imaging a 50% methane/50%

propane gas with a 10,000 ppm

concentration at a flow rate of ≤ 60

grams/hour from a ¼-inch diameter

orifice.

• Initial and daily camera verification checks.

• Procedure to determine the operator’s

maximum viewing distance from equipment

and ensure that this distance is maintained.

• Procedure to determine maximum wind

speed during which monitoring can be

performed to ensure monitoring occurs

only at wind speeds below this threshold

(EPA does not specify this wind speed).

• Procedure to ensure an adequate thermal

background is present.

• Procedure to deal with adverse monitoring

conditions.

• Procedure to deal with adverse

interferences (e.g., steam).

• Training and experience needed to

perform surveys.

• Procedures for calibration and

maintenance.

LDAR – Emissions Monitoring Plans (there’s more!)


• Date of the survey

• Beginning and end time of the survey

• Name of operator(s) performing survey

• Training and experience of the operator

• Monitoring instrument used

• Ambient temperature

• Sky conditions

• Maximum wind speed

• Any deviations from the monitoring plan or a statement that there

were no deviations from the monitoring plan

LDAR – OGI Recordkeeping


Other LDAR Topics

• Delay of Repair

• DOR until next scheduled shutdown or two years maximum

• Repairs required if there is an unscheduled or emergency shutdown

• Repair Timeframe

• 30 days to complete repair, additional 30 days to remonitor

• Repair Verification

• If using OGI, then no visible emissions; if Method 21, then < 500 ppm

• Soap bubble test specifically recognized to verify repair


• Modification

• Explicit definitions for some scenarios (addition of a new

compressor or increase in horsepower at a compressor station;

drilling a new well at an existing well site; and more. The trigger

does not specifically require an emissions increase.

• If accomplished without capital expenditure, then not a

modification, but:

• EPA changed the General Provisions calculation to determine

capital expenditure very conservatively.

• Asset guideline repair allowance (“B” value) set at 4.5

• Base year in calculation fixed at 2011

General Provisions


• Centrifugal compressor

• Reciprocating compressor

• Continuous bleed natural gas-

driven pneumatic controller not

located at a natural gas

processing plant with a natural

gas bleed rate greater than six

standard cubic feet per hour

• Continuous bleed natural gas-

driven pneumatic controller at a

natural gas processing plant

• Storage vessel with the potential

to emit six tons per year or more

of VOC (and storage vessels are

viewed as once in/always in)

• Natural gas-driven pneumatic

diaphragm pump at a natural gas

processing plant

• Natural gas-driven pneumatic

diaphragm pump in operation 90

days or more located at a well site

“Affected Facility”In OOOOa, EPA is pushing to smaller “affected facilities.” In

OOOOa, affected facilities are each individual:


• Methane is part of NSPS

OOOOa, but does not change

implementation of LDAR that

much.

• Equipment has to be in VOC

service, and then methane is

included.

• Residue (or dry) gas by itself is

not directly controlled.

• Another instance where a

greenhouse gas (methane) is

a regulated pollutant under

the Clean Air Act.

Methane


Next Generation Compliance

“Thus EPA’s Next Generation Compliance and rule effectiveness

strategies, in and of themselves, impose no requirements or

obligations on the regulated community. The strategies establish

no regulatory terms for any sector or facility nor create rights or

responsibilities in any party. Rather, the strategies describe

general compliance assurance and regulatory design principles,

approaches, and tools that EPA may consider in conducting

rulemaking, permitting, and compliance assurance, and

enforcement activities” [EPA Subpart OOOOa preamble language,

81 FR 35884, June 4, 2016].


• Establishes OGI as a BSER (seems

precedent setting).

• Alarms on bypass lines that could

route a regulated stream away from

a control device, alarmed to the

nearest field office location.

• Performance testing of control

devices by either the operator or the

manufacturer (flares or combustors

commonly used at oil and gas

production facilities). Performance

test reports submitted via EPA’s

Electronic Reporting Tool, CEDRI

(similar to Refinery Sector Rule.

Next Gen (type) Requirements in OOOOa


Next Gen (type) in OOOOa (con’t)

• Closed vent system designs (for venting storage vessels to a control

device) must be certified by a qualified professional engineer (PE).

• Pneumatic pump emissions at an oil and gas site must be routed to

an existing control device or back to the process. If infeasible, there

are significant documentation requirements, including certification

of technical infeasibility by a qualified PE.

• Documentation that oil and gas well completion operations were

properly controlled with appropriate control devices (reduced

emission completion, or REC) by including digital pictures with geo-

locations in the annual report (this is an alternative to more

conventional reporting).


• 3rd-party verification of the adequacy of

closed vent system design (instead of

relying on PE certification).

• Electronic submittal of LDAR (OGI or

Method 21) semiannual reports.

• Once the Electronic Reporting and

Recordkeeping proposed rule (March

20, 2015) goes final, this reporting

requirement will happen.

• Require leak detection and repair

programs to undergo regular third-party

audits, and that the facilities had to

certify that the auditors were both

competent and independent.

Next Gen That Did Not Make the Final Cut


Presenter


Jay Christopher

Senior Scientist Specialist

[email protected]

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EPA’s Methane Agenda – Will the Oil & Gas NSPS OOOOa...

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