NSPS Subparts OOOO/OOOOa Compliance

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NSPS Subparts OOOO/OOOOa Compliance Implement emissions control strategies to reduce risk and ensure environmental compliance. Regulatory Compliance Consulting for the Oil and Gas Industry Did you know? OOOO requirements are already in effect. Contact Kendrick for details and assistance with your facility compliance needs. kendrickconsultingllc.com Emissions Control Strategies Subpart OOOO focuses on VOC and SO2 control and applies to facilities that were constructed, modified, or reconstructed after August 23, 2011. Subpart OOOOa, which applies to facilities that were constructed, modified, or reconstructed after September 18, 2015, added additional controls on methane emissions and other facility operations. In July 2017, the U.S. Court of Appeals for the District of Columbia Circuit rejected an EPA proposal to defer and review Obama-era rules related to volatile organic and methane gas emissions under the Clean Air Act. The proposal would have effectively suspended many of the New Source Performance Standards for Crude Oil and Natural Gas Production, Transmission and Distribution (40 CFR Part 60, Subparts OOOO/OOOOa).

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Transcript of NSPS Subparts OOOO/OOOOa Compliance

Implement emissions control strategies to reduce risk and ensure environmental compliance.
Regulatory Compliance Consulting for the Oil and Gas Industry
Did you know? OOOO requirements are already in effect. Contact Kendrick for details and assistance with your facility compliance needs.
kendrickconsultingllc.com
Emissions Control Strategies
Subpart OOOO focuses on VOC and SO2 control and applies to facilities that were constructed, modified, or reconstructed after August 23, 2011.
Subpart OOOOa, which applies to facilities that were constructed, modified, or reconstructed after September 18, 2015, added additional controls on methane emissions and other facility operations.
In July 2017, the U.S. Court of Appeals for the District of Columbia Circuit
rejected an EPA proposal to defer and review Obama-era rules related
to volatile organic and methane gas emissions under the Clean Air Act.
The proposal would have effectively suspended many of the New Source
Performance Standards for Crude Oil and Natural Gas Production,
Transmission and Distribution (40 CFR Part 60, Subparts OOOO/OOOOa).
kendrickconsultingllc.com
001-10/17
Other Services KCLLC has proven experience and provides services in the following areas:
Operations & Maintenance (O&M) and Standard Operating Procedures (SOP)
Pipeline Integrity and Risk Management (IMP)
Control Room Management (CRM)
In-Line Inspection (ILI) Services
MOP and MAOP Verification
Operator Qualifications (OQ)
Public Awareness (PA)
Construction Oversight, Acquisition Support and Due Diligence
Compliance Records Management
Underground Storage
Contact us with your emissions compliance needs. 12331 E. Cornell Ave. Aurora, CO 80014
(720) 535-6782 • [email protected]
Our Services Kendrick Consulting LLC provides compliance program support for Subparts OOOO/ OOOOa - regulated facilities. Our experienced team of compliance specialists and advisors can provide guidance and solutions for upstream and midstream operations. Some exemptions and emissions thresholds may apply to affected facilities and provide regulatory relief. Let us help your facilities maintain compliance with economic and effective lifecycle solutions.
Subparts OOOO/OOOOa Compliance Requirements and Deadlines
One of the keys to Subpart OOOO compliance is the development and implementation of a Leak Detection and Repair (LDAR) Program to identify emissions and make repairs. A written LDAR Monitoring Plan provides detailed information about methods, frequencies and repair procedures for regulated equipment. LDAR surveys occur quarterly (compressor stations), semi-annually (well sites), and annually (other equipment) for implementing LDAR Program.
Facility Requirements Well Sites Gathering Gas Processing Transmission
Hydraulically fractured wells
8/2/2016
Wet seal centrifugal compressors
Install and operate closed vent and monitoring systems, source testing, annual reporting
8/2/2016 8/2/2016 8/2/2016
Reciprocating compressors
Install and operate closed vent system, periodic rod packing replacement, annual inspections and reporting
8/2/2016 8/2/2016 8/2/2016
8/2/2016 8/2/2016 8/2/2016 8/2/2016
Pneumatic pumps Install and operate closed vent system, perform inspections, annual reporting
11/30/2016 11/30/2016
Storage tanks Calculate potential to emit, install and operate closed vent system, engineer certification, source testing, annual reporting
8/2/2016 8/2/2016 8/2/2016 8/2/2016
6/3/2017 6/3/2017 8/2/2016 6/3/2017
8/2/2016