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
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