NSPS OOOOa Proposed Revisions
October 29, 2018

On October 15, 2018, the U.S. Environmental Protection Agency (EPA) published a notice in the Federal Register for a proposal rule to revise 40 CFR 60 Subpart OOOOa (Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification or Reconstruction Commenced After September 18, 2015). The proposed changes are in response to petitions to reconsider several parts of the rule.

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The proposed rule makes affects the following:

  • Fugitive leak monitoring requirements
  • Well site pneumatic pump standards
  • Requirements for certification of closed vent systems (piping) by a professional engineer

There are also proposed rule amendments, clarifications and technical corrections related to the proposed changes.

Comments/Public Hearing

Interested parties can submit comments on or before December 17, 2018. Submit your comments, identified by Docket ID No. EPA-HQ-OAR-2017-0483, at https://www.regulations.gov.

EPA will hold a public hearing on the proposed rule. The hearing is scheduled for Wednesday, November 14, 2018, from 8:00 a.m. to 8:00 p.m. (local time) in the EPA Region 8 Office at 1595 Wynkoop Street, Denver, CO.

See NSPS OOOOa Hearing Date Link

Fugitive Leak (LDAR) Monitoring Changes

The proposed rule affects the frequency of fugitive leak monitoring as listed below:

  1. Non-low production well sites (greater than or equal to 15 BOE)
    • Annual leak monitoring after initial survey
    • Consecutive annual monitoring surveys must be conducted at least 9 months apart and no more than 13 months
  2. Low production well sites (less than 15 BOE)
    • Biennial (once every other year) monitoring after initial survey
    • Consecutive biennial monitoring surveys must be conducted no more than 25 months apart
  3. Compressor stations (not located on Alaska North Slope)
    • Semiannual after the initial survey
    • Consecutive semiannual monitoring surveys must be conducted at least 4 months apart and no more than 6 months apart
  4. Alaska North Slope compressor stations
    • Annual leak monitoring after initial survey
    • Consecutive annual monitoring surveys must be conducted at least 9 months apart and no more than 13 months

A low production well is defined as 15 barrels of oil equivalent (BOE) per day averaged over the first 30 days of production. The rule defines BOE as equal to (cubic feet of gas)÷5658.52.

Leak monitoring would no longer be required when all major production and processing equipment is removed from a well site such that it becomes a wellhead only well site.

Several definitions related to fugitive emissions are included in this proposal. New terms defined are: “first attempt at repair” and “repaired” specific to the fugitive emissions requirements.

The proposal states “first attempt at repair” must be completed within 30 days of identifying a component with fugitive emissions, with final repair completed within 60 days. The proposed definition of ‘‘repaired’’ includes a requirement to verify the fugitive emissions are repaired before the repair considered completed.

Well site pneumatic pump standards

The proposed rules to expand the technical infeasibility provision to all well sites by eliminating the categorical distinction between greenfield sites and non-greenfield sites (and the categorical restriction of the technical infeasibility provision to existing sites) for the pneumatic pump requirements.

The proposal would avoid the potential of requiring a greenfield site to control the pneumatic pump emissions should it be technically infeasible to do so, while having no impact on the compliance obligations of other greenfield sites that do not have this issue.

The requirement for an engineering certification of the technical infeasibility of not controlling a pneumatic pump (see below) is changed to allow certification by a professional engineer or an in-house engineer.

Professional Engineer (PE) certification of closed vent systems

The proposed rule amends the certification requirements for closed vent system (piping) design for storage tanks and technical infeasibility for controlling pneumatic pumps by allowing certification by qualified professional engineer (PE) or by an in-house engineer with expertise on the design and operation of the piping or the affected pneumatic pump.

HY-BON/EDI Vent Gas Management and Vapor Combustion Units (VCU)

HY-BON/EDI can assist your company with its vent gas management and flaring needs to comply with NSPS OOOOa rules. Our IQR Emissions Services (LDAR) direct measurement services can quantify the amount of gas from storage tanks to determine if a vapor recovery unit (VRU) is feasible and to size a needed combustion device. We routinely conduct NSPS OOOOa LDAR monitoring for hundreds of sites.

We offer field proven Vapor Combustion Units (VCU) that meet EPA’s NSPS OOOOa requirements and Bureau of Land Management (BLM) requirements for flaring gas from routine and emergency operations.

Contact us at cUMqYO!?96Ni]#[rcZyjc7GJGbv or cUMqYO!?96Nis=v0]#[W36WMfh5Es=X|xfx for more information.