Oil & Gas Sector NSPS 40 CFR Part 60, Subpart OOOO

David Mahler, P.E.

Thomas Sullivan, P.E.

Zephyr Environmental Corporation

EPA must review NSPS rules every 8 years and revise if appropriate

EPA failed to review the oil and gas sector NSPS rules as required

NGO complaint resulted in a Consent Decree

EPA proposed new rules on August 23, 2011

Final rules signed in April 2012 and published in Federal Register on August 16, 2012

Background

Oil & Gas Sector NSPSs

Existing NSPS KKK affected sources Gas processing plant

fugitive VOC sources

Existing NSPS LLL affected sources Gas processing plant

sweetening units (SO2)

New NSPS OOOO affected sources Natural gas wellheads

Pneumatic controllers

Compressors

Storage vessels

Emission control systems

Gas processing plant fugitive VOC sources

Gas processing plant sweetening units (SO2)

NSPS KKK and LLL apply to gas processing plants that commenced construction, modification or reconstruction between January 20, 1984 and August 23, 2011

NSPS OOOO will apply to affected sources that that commenced construction, modification or reconstruction after August 23, 2011

Gas processing plants that contain NSPS KKK sources may also contain NSPS OOOO sources

Application of NSPS KKK, LLL & OOOO

Differences between proposed and final rules New compressor definition Limited Notifications

Gas well completions Compressors Process units at natural gas processing plants Sweetening units at NGPP

Definition of a gas well Gas well or natural gas well means an onshore well

drilled principally for production of natural gas

Focus on small sources Flare is defined as an open flame (without enclosure) Tank emission calculations methods are undefined

General Discussion Points

New MACT standards for small glycol dehys at major HAP sources

Major site HAP emissions of more than 10 tpy (any single HAP) or 25 tpy (total HAPs)

Dehy capacity

The affected source is each natural gas well completion following hydraulic fracturing

Refracturing provisions are more complicated

From 10/15/12 to 1/1/15, during well flowback: Route all gas that cant be directed to a pipeline to a

flare, unless flaring would result in a fire hazard

After 1/1/15, during well flowback: When feasible, route gas to a pipeline, well or other

recovery system

Route all other gas to a flare, unless flaring would result in a fire hazard

Notification prior to completion

NSPS OOOO Gas Wellhead Facilities

The affected source is each new, modified or reconstructed centrifugal compressor with wet seals (as of 8/23/11)

Compressors at a well site are excluded

The wet seal degassing reservoir must be routed to a control device for 95+% control

The compliance deadline is October 15, 2012

NSPS OOOO Centrifugal Compressors

The affected source is each new, modified or reconstructed reciprocating compressor (as of 8/23/11)

Compressors at a well site are excluded

Each rod packing must be replaced every 26,000 hours or 36 months of operation

The timing starts on October 15, 2012 or start of operation

Notification due 30 days later

NSPS OOOO Reciprocating Compressors

The affected source is each new, modified or reconstructed continuous bleed natural gas driven pneumatic controller (as of 8/23/11)

Pneumatic pumps and intermittent bleed controllers are not affected sources

A pneumatic controller at a gas processing plant must have zero emissions of natural gas

A pneumatic controller at any other location must be low bleed (continuous natural gas bleed rate

The affected source is each new, modified or reconstructed storage vessel (as of 8/23/11)

Storage tanks with >6 tpy of VOC emissions must be vented to a control device with >95% reduction of VOC emissions

The compliance deadline is October 15, 2013

TCEQ interpretation A storage tank control device is not subject to NSPS OOOO if actual emissions from the control device are

The affected source is the group of listed fugitive sources in a new, modified or reconstructed process unit at a gas processing plant

Gas processing plant is defined as extraction of NGLs or fractionation of NGLs, not including Joule-Thompson valves

The LDAR standard for NSPS OOOO will be NSPS VVa, rather than NSPS VV as it relates to NSPS KKK 500 ppm leak threshold, rather than 10,000 ppm Connector monitoring

The capital expenditure threshold will apply to modified affected sources

NSPS OOOO Fugitive Sources

Control devices in VOC service must reduce VOCs >95%

Must performance test the device unless:

Flare meets requirements of 40 CFR 60.18

Control device is certified by the manufacturer to meet requirements of 40 CFR 60.5412

NSPS OOOO Control Devices

Closed vent systems convey gas from wet seal fluid degassing systems and/or storage tanks to a control device

Design and operate closed vent system with no detectable emissions

If the system contains a bypass device, install a flow meter with alarm to indicate when bypass is active

Cover openings (access hatches, sampling ports, gauge wells) must be covered

NSPS OOOO Closed Vent Systems

Notifications & Records:

Control device continuous parameter monitoring

Documented monitoring plans

Performance testing and design analyses

NSPS OOOO Control Devices

Initial notifications Compressors, Natural Gas Processing Plants and sweetening units at NGPPs

Annual reports Due one year after initial startup or October 15,

2012, whichever is later

Reporting content mirrors recordkeeping content

Performance test reports Submitted to WEBFIRE

NSPS OOOO Reports

Compliance Management Strategies

Well Completions Compliance

Completion venting procedure

Work instructions for well venting, notification and recordkeeping

Form for recordkeeping

Defined responsibilities (photos, etc.)

Personnel training in completion venting procedure

Record management

Centrifugal Compressors - Compliance

Compressor inventory

Location

Seal type (e.g. dry/wet)

Manufacturer, model, serial number

Date of first installation (pre/post 8/23/11)

Date of last rebuild (pre/post 8/23/11)

Inventory management of change (wet seals)

Purchasing controls for new compressors

Responsibilities for inventory management

Reciprocating Compressors - Compliance (1)

Compressor inventory Location

Manufacturer, model, serial number

Date of first installation (pre/post 8/23/11)

Date of last rebuild (pre/post 8/23/11)

Inventory management of change Purchasing controls for new compressors

Responsibilities for inventory management

Reciprocating Compressors - Compliance (2)

Affected compressor operation tracking Month or hour counting basis?

Procedure for counting

Defined responsibilities for counting and recordkeeping

Trained personnel (operations, maintenance)

Pneumatic Controllers - Compliance

Inventory of in-service controllers Location

Type (e.g. high/low/no/intermittent bleed)

Manufacturer, model, serial number

Date of first installation (e.g. pre/post 8/23/11)

Bleed rate documentation (new controllers)

Inventory management of change Purchasing specs and controls for new controllers

Responsibilities for inventory management

Trained personnel (purchasing, engineering, maintenance)

Storage Vessels - Compliance

Tank inventory

Location

Date of installation (pre/post 8/23/11)

Inventory management of change

Purchasing controls for new tanks

Responsibilities for inventory management

Tank emissions tracking

Pre-startup emissions determination

Post-startup emissions review

Trained personnel (engineering, operations, maintenance)

Emission Control Systems - Compliance (1)

Design specifications

Control system performance

Monitoring systems and devices

Continuous data management systems

Documentation specifications

Vendor documentation

Monitoring plan

Control device testing specifications

Trained personnel (engineering)

Emission Control Systems - Compliance (2)

Operating procedures

Normal operation, startup, shutdown

Form for routine checks and deviation recordkeeping

Defined responsibilities for operation, recordkeeping and response to deviations

Closed vent system inspection procedures and recordkeeping

Trained personnel (operations)

Record management procedures

Reporting - Compliance

Internal data reporting procedures

New affected source information

Continuous monitoring and deviation data

Periodic inspection data

Quality assurance

Defined responsibilities

Trained personnel

Field Operations, Instrumentation, Environmental, Purchasing

Rule Avoidance Strategies

Storage tanks Proce