NSPS Subpart OOOOa Overview

  • Proposed 9/18/2015
  • Signed 5/12/2016
  • Not Yet in Federal Register
  • Adds Greenhouse Gas Reductions to Sources in NSPS OOOO Adds Requirements For:
    • Oil Wells
    • Pneumatic Pumps at Production Sites and Gas Plants
    • Fugitive Sources at Production Sites and Compressor Stations
  • Compliance period starts 60 days after it is signed into Federal Register
  • First compliance period ends 1 year after compliance period starts.

NSPS OOOOa Summary

No Substantive Changes to Sources from NSPSOOOO:

  • Centrifugal Compressors
  • Reciprocating Compressors
  • Pneumatic Controllers
  • Storage Vessels
  • Natural Gas Processing Plants
  • Sweetening Units at Natural Gas Processing Plants
  • Changes from NSP SOOOO
    • There are some additional monitoring and certi7ication requirements for closed vent systems for storage vessels and centrifugal compressors
    • Affects equipment subject to NSPS OOOO control requirements and VRUs used to exempt storage vessels from NSPS OOOO
    • Flares used to comply subject to design and monitoring requirements of NSPS Subpart A

Pneumatic Pumps

  • Any single natural gas-driven diaphragm pump manufactured, reconstructed or modi8ied after 9/18/2015.
  • Only applies for gas plants or well sites.
  • Pumps that operate less than 90 days at well sites are exempted.
  • Must maintain records of operation.
  • If the pump operates at all during one day, then that day counts towards the calendar day threshold.
  • Pumps at gas plants must have a natural gas bleed rate of zero within 180 days of FR date
  • Pumps at well sites required to have natural gas emissions reduced by 95%
  • Not required to install a control device just for the pumps if at an existing site, but must certify that there is no control device available and submit annual report.
  • If a control device is later installed, must control pump within 30 days of startup of the control device or within 30 days of ability to route to a process.
  • If the control device wouldn’t be able to achieve 95% reduction, must still route to control and certify that 95% is not achievable.
  • Certification involves sign-off by RO and professional engineer

Production Site Fugitives

  • Only applies to well sites that have emission sources – if it is just composed of wellheads, then it is not subject.
  • Applies to new or modified well sites as of 9/18/2015.
    • Modified if a new well is drilled at an existing well site.
    • Modified if a well at an existing well site is hydraulically fractured or re-fractured.
  • Can use OGI camera or Method 21
  • Must have emissions monitoring plan
  • Must conduct initial monitoring within 60 days of startup or 1 year of date of publication, whichever is later
  • Conduct periodic monitoring semiannually.
  • Repair any leaks within 30 days of finding the leak.
    • Leaks that need to be repaired during a shutdown must be repaired during the next shutdown or within 2 years, whichever is earlier.
    • Re-monitor leaking components within 30 days of being repaired or replaced.
  • Submit an annual report summarizing results.

Compressor Station Fugitives

  • Applies to new or modified compressor stations.
    • Modified if a compressor is added.
    • Modified if a compressor is replaced with a compressor of greater total horsepower.
  • Can use OGI camera or Method 21
  • Must have emissions monitoring plan
  • Must conduct initial monitoring within 60 days of startup or 1 year of date of publication, whichever is later
  • Conduct periodic monitoring quarterly.
  • Repair any leaks within 30 days of finding the leak.
    • Leaks that need to be repaired during a shutdown must be repaired during the next shutdown or within 2 years, whichever is earlier.
    • Re-monitor leaking components within 30 days of being repaired or replaced.
  • Submit an annual report summarizing results.

Fugitive Emissions Monitoring Plan

  • Composed of Three General Parts
  • Area-Wide Monitoring Plan
    • frequency of monitoring, records to be maintained and how long they will be maintained, information to be collected during monitoring, etc…
  • How Monitoring Will Be Conducted
    • equipment to be used, qualifications of person(s) doing the monitoring, etc…
  • Site-Specific Monitoring Information
    • Site lines for OGI, how impediments to site lines will be addressed, etc…

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