New NSPS OOOOa Regulations Affecting Methane and VOC Emissions from the O&G Sector Finalized as of June 3, 2016

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Courtesy of AEREON

The EPA has issued three final rules that will curb emissions of methane, smog-forming volatile organic compounds (VOCs) and toxic air pollutants such as benzene from new, reconstructed and modified oil and gas sources, while providing greater certainty about Clean Air Act permitting requirements for the industry.

The EPA’s amended and new regulations affecting methane (CH4) and VOC emissions from the oil and gas sector have been finalized and the new rules were published in the Federal Register on June 3, 2016, amending 40 CFR 60 Subpart OOOO. The final NSPS rules become effective August 3, 2016.

These rules revise NSPS OOOO and create the new NSPS OOOOa. NSPS OOOO affects oil and gas facilities constructed, modified or reconstructed after August 23, 2011, and on or before September 18, 2015. NSPS OOOOa affects facilities constructed, modified or reconstructed after September 18, 2015. NSPS OOOOa includes CH4 and VOC emission standards.

Requirements for the oil and gas upstream industry for gas processing facilities are:

NSPS OOOO changes (changes to NSPS OOOO also apply to NSPS OOOOa and include):

  • Replacement storage vessels (tanks) are subject to the same requirements as the storage vessel that it replaced.
  • Reconnected storage vessels are subject to the same requirements as those that applied before being removed from service.
  • Requires flow indicators and alarms for bypasses from control devices for storage tanks and compressor wet seals.
  • Exempts storage vessels with a capacity greater than 100,000 gallons used to recycle water that has been passed through two stage separation.
  • For enclosed combustion devices (VCU) stack tested, it increases the limit for total organic carbon (TOC) in the exhaust gases to a level equal to or less than 275 parts per million by volume as propane on a wet basis corrected to 3 percent oxygen.
  • Adds a definition of “Capital expenditure” for determining if a modification has occurred.
  • The final amendments to the current NSPS OOOO do not change the requirements for operations already covered by the current NSPS OOOO standards.

Affected Sources for NSPS OOOOa include new, reconstructed and modified processes and equipment after September 18, 2015.

  • Completions of hydraulically fractured wells at gas wells and oil wells (NSPS OOOO only affected
  • gas wells).
  • Fugitive equipment leaks – well sites and compressor stations.
  • Compressors – reciprocating and centrifugal located at production gathering and boosting stations.
  • Crude oil, condensate and produced water storage tanks.
  • Pneumatic controllers using natural gas.
  • Pneumatic pumps – natural gas-driven diaphragm pumps.

Dates to be aware of:

  • All revised and new NSPS rules become effective August 2, 2016.
  • NSPS OOOO applies to facilities constructed, modified or reconstructed after August 23, 2011, (i.e., original proposed date of Subpart OOOO) and on or before September 18, 2015.
  • NSPS OOOOa applies to new affected facilities (equipment and processes) constructed, reconstructed and modified after September 18, 2015.
  • Facilities constructed on or before August 23, 2011, (and not modified or reconstructed after that date) are not affected by the new final rules.

Deferred Emission Sources
For liquids unloading operations, the EPA stated in the proposal that they did not have sufficient information to propose a national standard for liquids unloading. This emission source may be included in a future NSPS rule making.

Summary of New NSPS OOOOa Emission Sources and Standards
The following summarizes the emission sources covered by NSPS OOOOa. Consult the rule itself for actual requirements

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