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 ServicesKCLLC 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

■ Leak Detection and EFRD Analysis

■ MOP and MAOP Verification

■ High Consequence Area (HCA) and Class Location Identification

■ Operator Qualifications (OQ)

■ Public Awareness (PA)

■ Pipeline and Process Safety Management Systems

■ Construction Oversight, Acquisition Support and Due Diligence

■ Compliance Records Management

■ Management Consulting and Process Improvement

■ Underground Storage

Contact us with your emissions compliance needs.12331 E. Cornell Ave. Aurora, CO 80014

(720) 535-6782 • info@kendrickllc.com

Our ServicesKendrick 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

Notification, vapor control, daily logs, annual reporting

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

Pneumatic controllers Equipment tagging, bleed rate determinations, bleed rate caps (zero for processing, 6 scf/h for all others), annual reporting

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

Equipment LDAR Program, leak surveys, repairs, source testing of control devices, annual reporting (at well sites/compressor stations), semiannual reporting (for all other regulated equipment)

6/3/2017 6/3/2017 8/2/2016 6/3/2017

Sweetening units Initial performance testing to demonstrate removal efficiency, operations and emissions monitoring, annual reporting

8/2/2016