EPA’s NSPS OOOOa (Quad Oa)...

3/7/16 EPA’s NSPS OOOOa (Quad Oa) Rule -“Getting Ready for Compliance”

EPA’s NSPS OOOOa(Quad Oa) Rule

Jay ChristopherBusiness Unit Manager, Air & Process ServicesTrihydro Corporation

“Getting Ready for Compliance”


NSPS OOOOa – What is it?• 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 rule published September 18, 2015; therefore this date becomes the effective date for NSPS OOOOa

• Based on communication with EPA in January, EPA expects to finalize this rule “in the spring of this year”

• Addition of methane gets all the publicity, but there is much more to this proposed regulation


Summary of the NSPS OOOOa Proposed Changes• Initial compliance date generally one year after publication of final rule

• Changes to the definition of “new” and “modified,” and changes to the capital expenditure calculation methodology

• Adds methane, which will bring gas plant residue gas into monitoring programs for sources that trigger NSPS

• Fugitive emission monitoring of production sites as well as compressors

• Storage tank “fugitive emissions” (aka thief hatch venting)

• Expands the source category (oil well completions, pneumatic pumps, and fugitive emission components at well sites and compressor stations)

• Next Generation compliance tracking, verification, and electronic reporting requirements


Some Important Aspects• Modification

• Well Sites – Addition of a new well or fracturing or re-fracturing of an existing well • Compressors – Addition of a new compressor, or when a physical change is made to an

existing compressor that increases compression capacity

• Gas Plants – important changes to modification calculations

• Initial OGI survey within 30 days of startup or modification, and semiannually thereafter, with step-up/down based on performance• Skip Period Monitoring – well sites and compressors

• Skip to annual (< 1% leakers during two consecutive monitoring events)

• Return to semiannual (leakers > 1% and < 3% during any monitoring event)

• Drop to quarterly (leakers > 3% during any two consecutive semiannual events)

• In order to document the % leaking, the rule indirectly infers component hard counts


Fugitive Emissions – General• Repairs and follow-up monitoring

complete within 15 days of detection• Delay of repair until next scheduled

shutdown or 6 months, whichever earlier

• Verify by optical gas imaging (OGI) (no visible emissions) or Method 21 no detectable emissions (< 500 ppm)

• Develop and implement corporate-wide and site-specific Site Monitoring Plans


Fugitive Emissions – Well Sites• Affected facility for well sites includes the collection of components

emitting fugitive emissions located on any oil, gas, or injection well pad• All equipment “necessary for production”

• Exemption for sites with wellheads only, low production (< 15 barrels per day on initial production)

• Best System of Emission Reduction (BSER)• Optical gas imaging (OGI) followed by repair


Fugitive Emissions - Compressors• Compressor station definition broadened

• Natural gas transmission, storage, gathering, and booster stations

• Compressors and associated piping and connections

• Best System of Emission Reduction (BSER)• OGI survey to include distance piece, crankcase and blowdown vents, followed by

repair

• Compressor seal controls• Centrifugal wet seal systems - 95% control efficiency, or routing back to process (dry

seal controls not required)

• Reciprocating rod packing – allows an alternative to rod packing change outs or route through a closed vent system operated under negative pressure to process


Well Completion Control Requirements• Hydraulically fractured oil well

completions required to implement Reduced Emission Completions (RECs) when feasible, with a completion combustion device

• Wildcat, delineation, and low pressure wells – during completion, must use a completion combustion device

• Well with gas-to-oil ratio of less than 300 scf gas/barrel oil - controls not required


Storage Vessels• Storage vessels that emit greater

than 6 tons/year VOCs must install 95% efficient control device (VRU, enclosed combustor)

• Flowback tanks used for greater than 60 days are storage vessels

• Skid-mounted or mobile vessels are storage vessels if onsite for greater than 180 days (records required)


Pneumatics• Pneumatic controllers (expanded coverage)

• Well sites, production gathering/boosting stations, and natural gas compressor stations (transmission/storage) – continuous bleed pneumatic controllers using natural gas must be low bleed (some exceptions)

• Pneumatic pumps – natural gas, chemical/methanol or diaphragm (newly covered)• Natural gas processing plants - separate affected

facilities and must have a natural gas bleed rate of 0 scfh (some exceptions)

• Other locations – reduce emissions by 95%, exempt if the location does not otherwise need/have an emission control device (enclosed combustor, VRU)


Performance Testing and Monitoring• Initial Compliance Tests

• For control devices – performance test within 180 days following startup

• Enclosed combustors• Initial and ongoing performance testing if not on list of EPA-approved combustors

http://www3.epa.gov/airquality/oilandgas/implement.html

• Enclosed combustion units – opacity monitoring

• Alarms – equipment outage alarms to nearest field office (60.5416)


RecordkeepingRecordkeeping

• All required records must be maintained either onsite or at the nearest local field office for five years

• Significant detail required for well completion/flowback records

• Significant additional recordkeeping burden


ReportingNotifications• Notice two days prior to each well

completion operation (exempt if subject to similar state notification requirements)

• Fugitive emission sources largely exemptAnnual Reporting• Initial compliance report due one year + 90

days after final rule publication

• Performance testing – submit using EPA’s Electronic Reporting Tool

• Semiannual fugitive emissions reporting also submitted electronically


Next Generation Compliance• Compliance tracking

• Continuous monitoring requirements

• Compliance verification• EPA requested comments on

requiring 3rd party auditing, or self-auditing, of the fugitive emissions programs

• Electronic reportinghttp://www.epa.gov/compliance/next-generation-compliance


Next Generation Compliance• Third-party evaluation of

manufacturer tested combustors

• PE certification • EPA requested comments

on independent verification of system design and control device design/installation

• Public access to compliance data


Jay ChristopherBusiness Unit Manager, Air

& Process [email protected]

EPA’s NSPS OOOOa (Quad Oa)...

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