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.

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

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. 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. 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. 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. 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. 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. 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. 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. 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. 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. 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. 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. 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. 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