The EPA's NSPS OOOOa rule establishes new performance standards for crude oil and natural gas facilities, effective one year after the final rule publication. Key changes include the inclusion of methane monitoring, revised definitions of 'new' and 'modified' facilities, and updated compliance tracking and reporting requirements. The rule also mandates specific controls for fugitive emissions, well completions, and storage vessels, with rigorous recordkeeping and performance testing protocols.

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. 2/29/2016 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

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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

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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

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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

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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

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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. 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

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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)

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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)

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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)

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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

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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

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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

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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. 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