epa’s nsps ooooa(quad oa) rule
TRANSCRIPT
2/29/2016 Page 1EPA’s NSPS OOOOa (Quad Oa) Rule -“Getting Ready for Compliance”
EPA’s NSPS OOOOa(Quad Oa) Rule
Jay ChristopherBusiness Unit Manager, Air & Process ServicesTrihydro Corporation
“Getting Ready for Compliance”
2/29/2016 Page 2EPA’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
2/29/2016 Page 3EPA’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
2/29/2016 Page 4EPA’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
2/29/2016 Page 5EPA’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
2/29/2016 Page 6EPA’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
2/29/2016 Page 7EPA’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
2/29/2016 Page 8EPA’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
2/29/2016 Page 9EPA’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)
2/29/2016 Page 10EPA’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)
2/29/2016 Page 11EPA’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)
2/29/2016 Page 12EPA’s NSPS OOOOa (Quad Oa) Rule -“Getting Ready for Compliance”
RecordkeepingRecordkeeping
• 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
2/29/2016 Page 13EPA’s NSPS OOOOa (Quad Oa) Rule -“Getting Ready for Compliance”
ReportingNotifications• 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
2/29/2016 Page 14EPA’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 reportinghttp://www.epa.gov/compliance/next-generation-compliance
2/29/2016 Page 15EPA’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
2/29/2016 Page 16EPA’s NSPS OOOOa (Quad Oa) Rule -“Getting Ready for Compliance”
Jay ChristopherBusiness Unit Manager, Air
& Process [email protected]