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EPA’s NSPS OOOOa(Quad Oa) Rule

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Trihdro corporation recently presented on the EPA’s NSPS OOOOa(Quad Oa) Rule. View to learn what you need to do to get ready fro compliance.

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EPA’s NSPS OOOOa(Quad Oa) Rule

  1. 1. 2/29/2016 Page 1 EPA’s NSPS OOOOa (Quad Oa) Rule - “Getting Ready for Compliance” EPA’s NSPS OOOOa (Quad Oa) Rule Jay Christopher Business Unit Manager, Air & Process Services Trihydro Corporation “Getting Ready for Compliance”
  2. 2. 2/29/2016 Page 2 EPA’s NSPS OOOOa (Quad Oa) Rule - “Getting Ready for Compliance” NSPS OOOOa – What is it? • New Source Performance Standards (NSPS) Subpart OOOOa – “Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification, or Reconstruction Commenced After September 18, 2015” • Proposed rule published September 18, 2015; therefore this date becomes the effective date for NSPS OOOOa • Based on communication with EPA in January, EPA expects to finalize this rule “in the spring of this year” • Addition of methane gets all the publicity, but there is much more to this proposed regulation
  3. 3. 2/29/2016 Page 3 EPA’s NSPS OOOOa (Quad Oa) Rule - “Getting Ready for Compliance” Summary of the NSPS OOOOa Proposed Changes • Initial compliance date generally one year after publication of final rule • Changes to the definition of “new” and “modified,” and changes to the capital expenditure calculation methodology • Adds methane, which will bring gas plant residue gas into monitoring programs for sources that trigger NSPS • Fugitive emission monitoring of production sites as well as compressors • Storage tank “fugitive emissions” (aka thief hatch venting) • Expands the source category (oil well completions, pneumatic pumps, and fugitive emission components at well sites and compressor stations) • Next Generation compliance tracking, verification, and electronic reporting requirements
  4. 4. 2/29/2016 Page 4 EPA’s NSPS OOOOa (Quad Oa) Rule - “Getting Ready for Compliance” Some Important Aspects • Modification • Well Sites – Addition of a new well or fracturing or re-fracturing of an existing well • Compressors – Addition of a new compressor, or when a physical change is made to an existing compressor that increases compression capacity • Gas Plants – important changes to modification calculations • Initial OGI survey within 30 days of startup or modification, and semiannually thereafter, with step-up/down based on performance • Skip Period Monitoring – well sites and compressors • Skip to annual (< 1% leakers during two consecutive monitoring events) • Return to semiannual (leakers > 1% and < 3% during any monitoring event) • Drop to quarterly (leakers > 3% during any two consecutive semiannual events) • In order to document the % leaking, the rule indirectly infers component hard counts
  5. 5. 2/29/2016 Page 5 EPA’s NSPS OOOOa (Quad Oa) Rule - “Getting Ready for Compliance” Fugitive Emissions – General • Repairs and follow-up monitoring complete within 15 days of detection • Delay of repair until next scheduled shutdown or 6 months, whichever earlier • Verify by optical gas imaging (OGI) (no visible emissions) or Method 21 no detectable emissions (< 500 ppm) • Develop and implement corporate- wide and site-specific Site Monitoring Plans
  6. 6. 2/29/2016 Page 6 EPA’s NSPS OOOOa (Quad Oa) Rule - “Getting Ready for Compliance” Fugitive Emissions – Well Sites • Affected facility for well sites includes the collection of components emitting fugitive emissions located on any oil, gas, or injection well pad • All equipment “necessary for production” • Exemption for sites with wellheads only, low production (< 15 barrels per day on initial production) • Best System of Emission Reduction (BSER) • Optical gas imaging (OGI) followed by repair
  7. 7. 2/29/2016 Page 7 EPA’s NSPS OOOOa (Quad Oa) Rule - “Getting Ready for Compliance” Fugitive Emissions - Compressors • Compressor station definition broadened • Natural gas transmission, storage, gathering, and booster stations • Compressors and associated piping and connections • Best System of Emission Reduction (BSER) • OGI survey to include distance piece, crankcase and blowdown vents, followed by repair • Compressor seal controls • Centrifugal wet seal systems - 95% control efficiency, or routing back to process (dry seal controls not required) • Reciprocating rod packing – allows an alternative to rod packing change outs or route through a closed vent system operated under negative pressure to process
  8. 8. 2/29/2016 Page 8 EPA’s NSPS OOOOa (Quad Oa) Rule - “Getting Ready for Compliance” Well Completion Control Requirements • Hydraulically fractured oil well completions required to implement Reduced Emission Completions (RECs) when feasible, with a completion combustion device • Wildcat, delineation, and low pressure wells – during completion, must use a completion combustion device • Well with gas-to-oil ratio of less than 300 scf gas/barrel oil - controls not required
  9. 9. 2/29/2016 Page 9 EPA’s NSPS OOOOa (Quad Oa) Rule - “Getting Ready for Compliance” Storage Vessels • Storage vessels that emit greater than 6 tons/year VOCs must install 95% efficient control device (VRU, enclosed combustor) • Flowback tanks used for greater than 60 days are storage vessels • Skid-mounted or mobile vessels are storage vessels if onsite for greater than 180 days (records required)
  10. 10. 2/29/2016 Page 10 EPA’s NSPS OOOOa (Quad Oa) Rule - “Getting Ready for Compliance” Pneumatics • Pneumatic controllers (expanded coverage) • Well sites, production gathering/boosting stations, and natural gas compressor stations (transmission/storage) – continuous bleed pneumatic controllers using natural gas must be low bleed (some exceptions) • Pneumatic pumps – natural gas, chemical/methanol or diaphragm (newly covered) • Natural gas processing plants - separate affected facilities and must have a natural gas bleed rate of 0 scfh (some exceptions) • Other locations – reduce emissions by 95%, exempt if the location does not otherwise need/have an emission control device (enclosed combustor, VRU)
  11. 11. 2/29/2016 Page 11 EPA’s NSPS OOOOa (Quad Oa) Rule - “Getting Ready for Compliance” Performance Testing and Monitoring • Initial Compliance Tests • For control devices – performance test within 180 days following startup • Enclosed combustors • Initial and ongoing performance testing if not on list of EPA-approved combustors http://www3.epa.gov/airquality/oilandgas/implement.html • Enclosed combustion units – opacity monitoring • Alarms – equipment outage alarms to nearest field office (60.5416)
  12. 12. 2/29/2016 Page 12 EPA’s NSPS OOOOa (Quad Oa) Rule - “Getting Ready for Compliance” Recordkeeping Recordkeeping • All required records must be maintained either onsite or at the nearest local field office for five years • Significant detail required for well completion/flowback records • Significant additional recordkeeping burden
  13. 13. 2/29/2016 Page 13 EPA’s NSPS OOOOa (Quad Oa) Rule - “Getting Ready for Compliance” Reporting Notifications • Notice two days prior to each well completion operation (exempt if subject to similar state notification requirements) • Fugitive emission sources largely exempt Annual Reporting • Initial compliance report due one year + 90 days after final rule publication • Performance testing – submit using EPA’s Electronic Reporting Tool • Semiannual fugitive emissions reporting also submitted electronically
  14. 14. 2/29/2016 Page 14 EPA’s NSPS OOOOa (Quad Oa) Rule - “Getting Ready for Compliance” Next Generation Compliance • Compliance tracking • Continuous monitoring requirements • Compliance verification • EPA requested comments on requiring 3rd party auditing, or self-auditing, of the fugitive emissions programs •Electronic reporting http://www.epa.gov/compliance/next-generation-compliance
  15. 15. 2/29/2016 Page 15 EPA’s NSPS OOOOa (Quad Oa) Rule - “Getting Ready for Compliance” Next Generation Compliance • Third-party evaluation of manufacturer tested combustors • PE certification • EPA requested comments on independent verification of system design and control device design/installation • Public access to compliance data
  16. 16. 2/29/2016 Page 16 EPA’s NSPS OOOOa (Quad Oa) Rule - “Getting Ready for Compliance” Jay Christopher Business Unit Manager, Air & Process Services jchristopher@trihydro.com

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