NSPS OOOO (No!) - Always Acousticenvirofdok.org/.../2013/03/...NSPS-OOOO-No-100413.pdf · NSPS OOOO...

NSPS OOOO (No!)

Joe Leonard – Devon Energy

EFO’s 22nd Annual Meeting

October 4th, 2013

About Devon

•  Founded as a private company in 1971

•  Became a public company in 1988

•  Has grown from 185 employees in 1981 to 5,000 employees today

•  Active driller in Oklahoma

NYSE: DVN www.devonenergy.com page 2

Agenda

•  NSPS OOOO Refresher –  Affected Facilities

•  Storage Vessels

•  Oklahoma Permit By Rules (PBR)

•  Questions


What is NSPS OOOO?

•  NSPS – New Source Performance Standard

•  Applies to sources constructed after a certain date –  8/23/2011

•  Technology over time –  Cheaper –  Increased availability


NSPS OOOO

•  Hydraulically Fractured Natural Gas Wells – Minimize emissions

•  Reciprocating Compressors –  Change rod packing

•  Centrifugal Compressors –  Control of wet seal emissions

•  Pneumatic Controllers –  No continuous high bleed

The heavy hitters…


What is OOOO?

•  Storage Vessels –  6 tons per year (tpy)


NSPS OOOO

•  Affected Facility

“has the potential for VOC emissions equal to or greater than 6 tpy” Group 1: 8/23/11 - 4/15/13 Group 2: 4/15/13 – Forever

*Note: Determination for G1 tanks must be made by 10/15/13

•  Compliance

“Reduce VOC emissions by 95.0 percent”

Group 1: 4/15/15 Group 2: 4/15/14

Storage Vessels - What Everyone Knows


NSPS OOOO

•  Cover inspections – monthly audio, visual and olfactory inspection

•  Control piping inspection – monthly audio, visual and olfactory inspection

•  Flare/combustor inspection –  Confirm pilot is lit –  15 minute smoke observation –  Audio, visual and olfactory inspection –  Check air vent for obstruction –  Check for liquid reaching the combustor

Storage Vessels – The Fine Print Monthly Inspection Requirements


NSPS OOOO

•  Tank ID with lat/long location

•  Determination of VOC rate

•  Deviations

•  Combustor manufacturer tests

•  Unsafe to inspect or difficult to inspect maintenance plans

•  For mobile tanks, records or dates onsite

•  Closed vent system and cover inspections

•  Control bypass inspections

•  Records of inspections, corrective actions taken, manufacturers operating instructions, procedures and maintenance schedules

•  Records of smoke reading –  Company, location, company rep, process unit, start time, observation period, accumulated

emissions time, end time

Storage Vessels – The Fine Print Recordkeeping & Reporting Requirements


EHS Engineering Guidance

•  Avoid becoming subject to the fine print! –  Process changes –  Reduce production –  Permit out –  Etc.

•  Run •  Run •  Run


Permit By Rule

•  Developed in response to NSPS OOOO

•  ≤40 tpy VOC PTE

•  ≤10 tpy single HAP PTE

•  ≤25 tpy combination HAP PTE

•  New & Existing Facilities

…Nothing special


Permit By Rule

•  ODEQ Form 100-223 •  Page 2 •  Second Section

But Wait!


Permit By Rule

•  Emissions are less than 6 tpy

•  “Compliance” with NSPS OOOO … without being subject to the fine print!

What Does “Enforceability” Mean?


Permit By Rule

•  Everyone gets what they want –  EPA gets “compliance”

–  Oklahoma gets to support local business

–  Industry continues to operate

–  Emissions are lowered


Happily Ever After


Summary

•  NSPS OOOO Refresher – Multiple affected sources –  Storage vessels may be heaviest hitter

•  Storage Vessels –  Groups 1 & 2 –  Avoid becoming subject to the rule!

•  Oklahoma PBR –  40 tpy limit –  Enforceability


Thank you

Questions?

NSPS OOOO (No!) - Always Acousticenvirofdok.org/.../2013/03/...NSPS-OOOO-No-100413.pdf · NSPS OOOO...

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