NSPS Subpart OOOO: Applicability and Compliance Basics

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Roy Rakiewicz of ALL4 Inc, presents "General Applicability of NSPS Subpart OOOO: Applicability and Compliance Basics". The presentation provides detailed information on: affected facilities, rule structure, storage vessel affected facilities, and gas well affected facilities.

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  • Section 111 of the Clean Air Act, "Standards of Performance of New Stationary Sources," requires EPA to establish federal emission standards for source categories which cause or contribute significantly to air pollution. These standards are intended to promote use of the best air pollution control technologies, taking into account the cost of such technology and any other non-air quality, health, and environmental impact and energy requirements. These standards apply to sources which have been constructed or modified since the proposal of the standardSubpart OOOO is one of 94 NSPS written since 1971
  • Construction means fabrication, erection, or installation of an affected facilityModification - Except as provided under paragraphs (e) and (f) of this section, any physical or operational change to an existing facility which results in an increase in the emission rate to the atmosphere of any pollutant to which a standard applies shall be considered a modification within the meaning of section 111 of the Act.Things that are not modifications:Routine maintenance repair, and replacementIncrease in production if the increase is achieved without a capital expenditureAddition of air pollution controlsRelocation or change in ownership of an existing facility“Reconstruction” means the replacement of components of an existing facility to such an extent that:The fixed capital cost of the new components exceeds 50 percent of the fixed capital cost that would be required to construct a comparable entirely new facility, andIt is technologically and economically feasible to meet the applicable standards set forth in this part
  • Rule applicability is very broad – covers a wide variety of related but divergent equipment and operationsNot written in a user friendly manner – need to all possible sections that could apply to ascertain full impact and compliance obligationShares basic structure with other NSPSGeneral provisions - Subpart A apply as well and impact OOOO applicability
  • Need to determine if your tank is a “storage vessel” as defined by Subpart OOOOProduced water means water that is extracted from the earth from an oil or natural gas production well, or that is separated from crude oil, condensate, or natural gas after extraction.Intermediate hydrocarbon liquid means any naturally occurring, unrefined petroleum liquid.Condensate means hydrocarbon liquid separated from natural gas that condenses due to changes in the temperature, pressure, or both, and remains liquid at standard conditions.Mobile storage vessels must be removed (and not replaced with a similar unit) for > 30 days. Process vessels not specifically defined, but examples include surge control vessels, bottoms receivers or knockout vesselsPressure vessel means a storage vessel that is used to store liquids or gases and is designed not to vent to the atmosphere as a result of compression of the vapor headspace in the pressure vessel during filling of the pressure vessel to its design capacity - Pressure vessels designed to operate in excess of 204.9kilopascals and without emissions to the atmosphere.
  • Need to determine if your tank is a “storage vessel” as defined by Subpart OOOO
  • Losses need to include flash, working, and breathing losses of VOCE & P TANK From 1997, no longer supported by API but used extensively. Based on a pressurized sample.Vazquez-Beggs from early 80’s based on empirical data, needs to be supported by sampling, and is not very accurateGas to Oil ratio based on sampling and analysis and is accurate, flash emissions onlyTanks (AP-42) is user input based, is for working and breathing losses, and is accurateFlash emissions are the emissions released when a liquid under higher pressure moves to a vessel or area with a lower pressure. Example: Soda Can
  • In general, state protocols to determine emissions from storage vessels include the collection of pressurized samples to accurately account for flash emissions. Direct measurement of tank emissions is also an acceptable method to determine tank emissions (flash, working, and breathing), but is expensive and labor intensive. States may have prescriptive requirements associated with emissions testing as well.For emission testing, most states require preparation and approval of a test protocol
  • Reconsideration resulted in division of storage vessels into Group 1 or Group 2 vessels
  • 4 TPY must be determined using generally accepted model or calculation methodology
  • What happens if emissions increase to > 4TPY of VOC?Controls need to be in place before fluids are introduced into tank from a fractured or re-fractured well30 days to install controls if PTE increased without re-fracturing, example could be removal of tanks from a battery that results in more fluids through the remaining tanks as a result of parallel filling.
  • Pay attention to requirements associated with affected storage vessels removed and placed back into service – storage vessels are subject to the “once in – always in” rule even though vessels only serve to store crude oil, condensate, light hydrocarbons, and produced water. Return to service requirement similar to requirements associated changes at tanks complying with 4 TPY uncontrolled VOC limit except for 60 compliance requirement without fracking.
  • Design, installation, and operation of covers, closed vent systems, and control devices is very prescriptive.
  • Delineation wells, low pressure wells, and wildcat wells are not subject to the green completion requirements (i.e. post January 1 2015), but must capture and direct flowback emissions to a completion combustion device.Exceptions include fire or explosion hazard, or where heat from a combustion device may impact tundra, permafrost, or waterways.Compliance still required with other provisions (logs, compliance demonstration, continuous compliance, recordkeeping, notification and reporting)
  • Deviations are cases where well completion operations with hydraulic fracturing were not performed in compliance with § 60.5357
  • NSPS Subpart OOOO: Applicability and Compliance Basics

    1. 1. NSPS Subpart OOOO: Applicability and Compliance Basics Kentucky Oil & Gas Association 2013 Western Kentucky Meeting September 12, 2013 Roy Rakiewicz – All4 Inc. www.all4inc.com Kimberton, PA | 610.933.5246 Kennesaw, GA | 678.460.0324
    2. 2. Introduction   2 Environmental Standards, Inc. All4 Inc. Your environmental compliance is clearly our business.
    3. 3. Presentation Overview     General Applicability Affected Facilities Rule Structure Storage Vessel Affected Facilities • • • •  Gas Well Affected Facilities • • • • • 3 Standards for storage vessel affected facilities Recordkeeping for storage vessel affected facilities Reporting for storage vessel affected facilities Compliance for storage vessel affected facilities Standards for gas well affected facilities Recordkeeping for gas well affected facilities Reporting for gas well affected facilities Notification for gas well affected facilities Compliance for gas well affected facilities Your environmental compliance is clearly our business.
    4. 4. General Applicability  Commence construction, modification or reconstruction after August 23, 2011 • Construction • Modification • Reconstruction  Presentation will address: • Storage vessels • Gas wells 4 Your environmental compliance is clearly our business.
    5. 5. Subpart OOOO Affected Facilities        5 Gas wells Centrifugal compressors Reciprocating compressors Pneumatic controllers Storage vessels Leak standards at onshore processing plants Sweetening units at onshore natural gas processing plants Your environmental compliance is clearly our business.
    6. 6. Subpart OOOO Structure  Determining applicability • Effective date • Construction, reconstruction, or modification       6 Deadlines Standards Compliance Demonstration Monitoring Testing Notification, recordkeeping, and reporting Your environmental compliance is clearly our business.
    7. 7. Storage Vessels  Storage vessel is a tank containing: • • • •  Crude oil, Condensate, Intermediate hydrocarbon liquids, or Produced water Storage vessels are not: • Skid-mounted or permanently attached to something that is mobile and on-site for < 180 consecutive days • Process vessels • Pressure vessels 7 Your environmental compliance is clearly our business.
    8. 8. Storage Vessels Affected Facility  Single storage vessel • Oil and natural gas production segment • Natural gas processing segment • Natural gas transmission and storage segment  Potential to emit (PTE) of volatile organic compound (VOC) emissions > than 6 tpy • PTE determined using a generally accepted model or calculation methodology • Based on the maximum daily throughput • Can rely on enforceable limitations to < 6 TPY VOC • PTE based on VOC emissions after any vapor recovery unit (VRU) 8 Your environmental compliance is clearly our business.
    9. 9. Storage Vessels  What is a “generally accepted model or calculation methodology” • Not specified by the rule, but examples provided by U.S. EPA in response to comment document include:     API’s E&P TANK software Vasquez-Beggs Equation (VBE) Gas oil ratio (GOR) calculations Process simulation software: • HYSIM, HYSYS, WINSIM, and PROSIM  TANKS 4.0 Calculations from AP-42 • For working and breathing losses only 9 Your environmental compliance is clearly our business.
    10. 10. Storage Vessels  State-specific tank emission protocols: • California Air Resource Board (CARB)   Draft Determination of Methane, Carbon Dioxide, and Volatile Organic Compounds from Crude Oil and Natural Gas Separation and Storage Tank Systems http://www.arb.ca.gov/cc/oilgas/flash_test_procedure_apr24.pdf • Wyoming:  http://deq.state.wy.us/aqd/Oil%20and%20Gas/March%202010% 20FINAL%20O&G%20GUIDANCE.pdf • Texas   10 http://www.tceq.texas.gov/assets/public/permitting/air/Guidanc e/NewSourceReview/guidance_flashemission.pdf http://www.tceq.texas.gov/assets/public/permitting/air/NewSou rceReview/oilgas/produced-water.pdf Your environmental compliance is clearly our business.
    11. 11. Example Wyoming Protocol Method Emissions Calculated Comments 1 Direct measurement    2 Process Simulator  Flash only PROMAX, HYSIM, HYSIS, etc. Software is expensive but results are accurate when based on site-specific sampling and lab analysis. 3 AP E&P Tanks Software V 2.0    Working Breathing Flash Requires site specific sampling. Not as accurate as more expensive process simulators and no longer supported by the software producer (American Petroleum Institute). 4 Laboratory measurement of the Gas-Oil-Ratio (GOR) from a pressurized liquid sample  Flash only This is a direct laboratory analysis of the flash vapors emitted from a pressurized oil/condensate sample. EPA Tanks 4.0.9d   Working Breathing only 5 Working Breathing Flash Sampling and lab analysis required. Results are relatively accurate. Program distributed by the EPA through their website at: http://www.epa.gov/ttn/chief/efpac/efsoftware.html From Chapter 6, Section 2, page 22 of Wyoming Permitting Guidance for Oil and Gas Production Facilities: http://deq.state.wy.us/aqd/Oil%20and%20Gas/March%202010%20FINAL%20O&G%20GUIDANCE.pdf 11 Your environmental compliance is clearly our business.
    12. 12. Storage Vessels  Group 1 storage vessels • Storage vessel for which construction, modification, or reconstruction commenced after August 23, 2011 and on or before April 12, 2013 • Determine VOC PTE by October 15, 2013 • Comply (install capture and controls) by April 15, 2015  Group 2 storage vessels • Storage vessel for which construction modification, or reconstruction commenced after April 12, 2013 • Determine VOC PTE by the later of April 15, 2014 or 30 days after start-up • Comply (install capture and controls) by the later of April 15, 2014 or 60 days after start-up 12 Your environmental compliance is clearly our business.
    13. 13. Standards for Storage Vessel Affected Facilities  Group 1 storage vessels • Submit notification identifying location of each Group 1 vessel with initial annual report • Reduce VOC emissions by 95% by April 15, 2015 or • Maintain uncontrolled VOC to < 4 TPY after demonstrating that uncontrolled VOC emissions have been < 4 TPY for 12 consecutive months • Uncontrolled VOC emissions determined on a monthly basis thereafter using average throughput for the month 13 Your environmental compliance is clearly our business.
    14. 14. Standards for Storage Vessel Affected Facilities  Group 2 storage vessels • Reduce VOC emissions by 95% by April 15, 2014 or within 60 days after startup or • Maintain uncontrolled VOC to < 4 TPY after demonstrating that uncontrolled VOC emissions have been < 4 TPY for 12 consecutive months • Uncontrolled VOC emissions determined on a monthly basis thereafter using average throughput for the month 14 Your environmental compliance is clearly our business.
    15. 15. Standards for Storage Vessel Affected Facilities  Conditions regarding uncontrolled 4 TPY VOC compliance option if conditions at well change: • If well undergoes fracturing or re-fracturing:  Reduce VOC emissions by 95% as soon as liquids from the well are routed to the storage vessel • If VOC emissions increase to > 4 TPY without fracturing or re-fracturing  15 Reduce VOC emissions by 95% within 30 days of the determination Your environmental compliance is clearly our business.
    16. 16.  Standards for Storage Vessel Affected Facilities Storage vessels removed from service • Submit notification in annual report identifying all affected vessels that are removed from service during the period • If returning to service and associated with fracturing   Comply with control requirement options immediately Submit notification in annual report • If returning to service and not associated with fracturing    16 Determine VOC emissions within 30 days If uncontrolled VOC emissions > 4 TPY must comply with control requirements within 60 days of return to service Submit notification in annual report Your environmental compliance is clearly our business.
    17. 17. Standards for Storage Vessel Affected Facilities  Storage vessel control requirements • Control device option   Storage vessel cover and all openings must form continuous impermeable barrier over the entire surface area of the liquid Liquids, gases, and fumes must vent through a closed vent system to a control device or process • Floating roof option  Meet requirements of 40 CFR Part 60 Subpart Kb • Vapor recovery units (VRU) must meet closed vent system requirements and have an operational uptime of 95% 17 Your environmental compliance is clearly our business.
    18. 18. Controls for Storage Vessel Affected Facilities  Covers • Cover and all openings on the cover shall form a continuous barrier over the entire surface area of the liquid in the storage vessel • Each cover opening shall be secured in a closed, sealed position (gasket lid or cap) whenever material is in the unit… • Each storage vessel thief hatch shall be weighted and properly seated…  Closed vent system (CVS) • Design the CVS to route all gases, vapors, and fumes emitted from the material in the storage vessel to a control device • Design/operate a CVS with no detectable emissions, as determined using olfactory, visual and auditory inspections • Meet control system bypass requirements as applicable 18 Your environmental compliance is clearly our business.
    19. 19. Controls for Storage Vessel Affected Facilities  Control device • Enclosed combustion device (e.g., thermal vapor incinerator, catalytic vapor incinerator, boiler, or process heater) • Designed to reduce the mass content of VOC emissions by 95.0 percent or greater    Ensure that each enclosed combustion device is maintained in a leak free condition Install and operate a continuous burning pilot flame Operate the enclosed combustion device with no visible emissions • Operation of control devices at all times when gases, vapors, and fumes are vented from the storage vessel affected facility through the closed vent system 19 Your environmental compliance is clearly our business.
    20. 20. Monitoring for Storage Vessel Affected Facilities  Closed Vents and Covers • Conduct monthly olfactory, visual and auditory inspections for defects that could result in air emissions  Control devices • Monthly visible emissions test (Method 22)  >14 days between tests • All inspection, repair and maintenance activities for each unit must be recorded in a maintenance and repair log and must be available for inspection • Continuous parametric monitoring system  20 Combustion zone temperature for thermal oxidizers Your environmental compliance is clearly our business.
    21. 21. Testing for Storage Vessel Affected Facilities  Control device • Testing exemptions   Certain flares and boilers Performance test conducted by the manufacturer • Testing requirements     EPA Methods to determine sample port location and gas volumetric flowrate Collection of integrated bag samples or grab samples EPA Method 25A at inlet and outlet of control device Calculation of control device efficiency on a mass basis • Test schedule   21 Initial compliance test 180 days after start-up Testing every 60 months thereafter Your environmental compliance is clearly our business.
    22. 22. Recordkeeping for Storage Vessel Affected Facilities    VOC PTE determination for each storage vessel with calculation methodology and/or calculation model used Deviations from requirements Mobile vessel consecutive days on site • If removed and returned or replaced within 30 days, entire period will count as consecutive days   Closed vent system inspections and results Control devices: • • • • 22 Minimum and maximum operating parameter values Continuous parameter monitoring data Results of all compliance calculations Results of all inspections Your environmental compliance is clearly our business.
    23. 23. Reporting for Storage Vessel Affected Facilities   Initial annual report due January 15, 2014 Subsequent reports due 90 days following end of reporting period • General information • Storage vessel information        23 Identification and location of each storage vessel affected facility constructed, modified, or reconstructed during the period Documentation of VOC emission rates Records of deviations that occurred during the reporting period Identification of each Group 1 storage vessel with location coordinates Compliance statement regarding initial compliance requirements Storage vessel affected facilities removed from service Storage vessel affected facilites returned to service Your environmental compliance is clearly our business.
    24. 24. Compliance for Storage Vessel Affected Facilities  Initial compliance • • • • • •  Determine potential VOC emission rate Reduce VOC emissions as required Meet control requirements Submit required notification information Maintain required records Submit Group 1 notifications Continuous Compliance • Reduce VOC emissions as specified • Demonstrate continuous compliance with performance requirements   24 Cover and closed vent system Control devices Your environmental compliance is clearly our business.
    25. 25. Gas Wells  Gas well affected facility • Gas well or natural gas well means an onshore well drilled principally for production of natural gas  Key distinctions • Delineation wells • Low pressure gas wells • Wildcat wells 25 Your environmental compliance is clearly our business.
    26. 26. Standards for Gas Wells  Completions with hydraulic fracturing begun before January 1, 2015 • Capture/direct flowback to a completion combustion device (with reliable continuous ignition source) • Exceptions include fire/explosion hazards, or where high heat may negatively impact tundra, permafrost or waterways • “General duty” to “safely maximize resource recovery and minimize releases to the atmosphere during flowback and subsequent recovery” 26 Your environmental compliance is clearly our business.
    27. 27. Standards for Gas Wells  Completions with hydraulic fracturing begun after January 1, 2015: • Route the recovered liquids into one or more storage vessels or re-inject the recovered liquids into the well or another well and; • Route the recovered gas into a gas flow line or collection system, re-inject the recovered gas into the well or another well, use the recovered gas as an onsite fuel source, or use the recovered gas for another useful purpose that a purchased fuel or raw material would serve, with no direct release to the atmosphere 27 Your environmental compliance is clearly our business.
    28. 28. Standards for Gas Wells  Completions with hydraulic fracturing begun after January 1, 2015 (cont.): • All salable quality gas must be routed to the gas flow line as soon as practicable   Flow line means a pipeline used to transport oil and/or gas to a processing facility, a mainline pipeline, re-injection, or routed to a process or other useful purpose In cases where flowback emissions cannot be directed to the flow line • Capture/direct flowback to a completion combustion device (with reliable continuous ignition source) 28 Your environmental compliance is clearly our business.
    29. 29. Recordkeeping for Gas Wells  All completions with hydraulic fracturing: • Records of completions • Records of deviations • Daily log records for each completion:   Post-January 1, 2015 - location, API well No., duration (hours) of flowback, duration of recovery to flow line, duration of combustion, duration of venting, and reasons for venting Pre-January 1, 2015 – same as above, except for recovery to flow line requirements • Exemption records (e.g., fire, explosion, heat, etc.) • Records of required digital photographs (for post January 1, 2015 completions) 29 Your environmental compliance is clearly our business.
    30. 30. Reporting for Gas Wells  Annual reports • Initial report due January 15, 2014 • Subsequent reports due 90 days following end of the reporting period • General information     Company name and address Identification of each facility included Beginning and end date of the report period Certification of truth, accuracy, and completeness • Gas well information   30 Records of each well completion operation for each gas well affected facility conducted during the reporting period or a list of completions with hydraulic fracturing and associated records Records of deviations that occurred during the reporting period Your environmental compliance is clearly our business.
    31. 31. Notifications for Gas Wells  Commencement of well completion • Electronic or written notification two (2) days prior to the commencement of each completion      The anticipated commencement date Contact information of owner/operator API well number Latitude/longitude coordinates Planned flowback date • State advance notice requirements are acceptable 31 Your environmental compliance is clearly our business.
    32. 32. Compliance for Gas Wells  Initial compliance is demonstrated by: • Submit required notifications/annual report • Maintain completion logs • Maintain records of digital photographs of completions (for post January 1, 2015 completions):      Date and latitude/longitude imbedded or stored with the digital file Equipment for storing or re-injecting recovered liquid Equipment for routing recovered gas to the gas flow line The completion combustion device (if applicable) connected to and operating at each gas well completion Continuous compliance is demonstrated by: • Submitting required reports • Maintaining required records 32 Your environmental compliance is clearly our business.
    33. 33. Key Points to Take Away     Subpart OOOO is a complicated rule with many “moving parts” Broad applicability over entire oil and gas sector Determining if a tank is a “storage vessel affected facility” will likely require process/emissions sampling Time is of the essence • Deadline for Group 1 tank VOC emissions determination is October 15, 2013 • Annual report for initial compliance period is due January 15, 2014 33 Your environmental compliance is clearly our business.
    34. 34. Contact Information Roy Rakiewicz Senior Consultant All4 Inc. 2393 Kimberton Road Kimberton, Pennsylvania 19442 rrakiewicz@all4inc.com www.all4inc.com (610) 933-5246 extension 127 (484) 269-6246 cell 34 Your environmental compliance is clearly our business.

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