Roy Rakiewicz of ALL4 Inc, presents "General Applicability of NSPS Subpart OOOO: Applicability and Compliance Basics". The presentation provides detailed information on: affected facilities, rule structure, storage vessel affected facilities, and gas well affected facilities.
Value Proposition canvas- Customer needs and pains
NSPS Subpart OOOO: Applicability and Compliance Basics
1. NSPS Subpart OOOO:
Applicability and
Compliance Basics
Kentucky Oil & Gas Association
2013 Western Kentucky Meeting
September 12, 2013
Roy Rakiewicz – All4 Inc.
www.all4inc.com
Kimberton, PA | 610.933.5246
Kennesaw, GA | 678.460.0324
3. Presentation Overview
General Applicability
Affected Facilities
Rule Structure
Storage Vessel Affected Facilities
•
•
•
•
Gas Well Affected Facilities
•
•
•
•
•
3
Standards for storage vessel affected facilities
Recordkeeping for storage vessel affected facilities
Reporting for storage vessel affected facilities
Compliance for storage vessel affected facilities
Standards for gas well affected facilities
Recordkeeping for gas well affected facilities
Reporting for gas well affected facilities
Notification for gas well affected facilities
Compliance for gas well affected facilities
Your environmental compliance is clearly our business.
4. General Applicability
Commence construction, modification or
reconstruction after August 23, 2011
• Construction
• Modification
• Reconstruction
Presentation will address:
• Storage vessels
• Gas wells
4
Your environmental compliance is clearly our business.
5. Subpart OOOO Affected Facilities
5
Gas wells
Centrifugal compressors
Reciprocating compressors
Pneumatic controllers
Storage vessels
Leak standards at onshore processing plants
Sweetening units at onshore natural gas
processing plants
Your environmental compliance is clearly our business.
6. Subpart OOOO Structure
Determining applicability
• Effective date
• Construction, reconstruction, or modification
6
Deadlines
Standards
Compliance Demonstration
Monitoring
Testing
Notification, recordkeeping, and reporting
Your environmental compliance is clearly our business.
7. Storage Vessels
Storage vessel is a tank containing:
•
•
•
•
Crude oil,
Condensate,
Intermediate hydrocarbon liquids, or
Produced water
Storage vessels are not:
• Skid-mounted or permanently attached to something
that is mobile and on-site for < 180 consecutive days
• Process vessels
• Pressure vessels
7
Your environmental compliance is clearly our business.
8. Storage Vessels Affected Facility
Single storage vessel
• Oil and natural gas production segment
• Natural gas processing segment
• Natural gas transmission and storage segment
Potential to emit (PTE) of volatile organic
compound (VOC) emissions > than 6 tpy
• PTE determined using a generally accepted model or
calculation methodology
• Based on the maximum daily throughput
• Can rely on enforceable limitations to < 6 TPY VOC
• PTE based on VOC emissions after any vapor recovery unit
(VRU)
8
Your environmental compliance is clearly our business.
9. Storage Vessels
What is a “generally accepted model or
calculation methodology”
• Not specified by the rule, but examples provided by
U.S. EPA in response to comment document include:
API’s E&P TANK software
Vasquez-Beggs Equation (VBE)
Gas oil ratio (GOR) calculations
Process simulation software:
• HYSIM, HYSYS, WINSIM, and PROSIM
TANKS 4.0 Calculations from AP-42
• For working and breathing losses only
9
Your environmental compliance is clearly our business.
10. Storage Vessels
State-specific tank emission protocols:
• California Air Resource Board (CARB)
Draft Determination of Methane, Carbon Dioxide, and Volatile
Organic Compounds from Crude Oil and Natural Gas Separation
and Storage Tank Systems
http://www.arb.ca.gov/cc/oilgas/flash_test_procedure_apr24.pdf
• Wyoming:
http://deq.state.wy.us/aqd/Oil%20and%20Gas/March%202010%
20FINAL%20O&G%20GUIDANCE.pdf
• Texas
10
http://www.tceq.texas.gov/assets/public/permitting/air/Guidanc
e/NewSourceReview/guidance_flashemission.pdf
http://www.tceq.texas.gov/assets/public/permitting/air/NewSou
rceReview/oilgas/produced-water.pdf
Your environmental compliance is clearly our business.
11. Example Wyoming Protocol
Method
Emissions Calculated
Comments
1
Direct measurement
2
Process Simulator
Flash only
PROMAX, HYSIM, HYSIS, etc.
Software is expensive but results are accurate when
based on site-specific sampling and lab analysis.
3
AP E&P Tanks Software V 2.0
Working
Breathing
Flash
Requires site specific sampling. Not as accurate as
more expensive process simulators and no longer
supported by the software producer (American
Petroleum Institute).
4
Laboratory measurement of the
Gas-Oil-Ratio (GOR) from a
pressurized liquid sample
Flash only
This is a direct laboratory analysis of the flash vapors
emitted from a pressurized oil/condensate sample.
EPA Tanks 4.0.9d
Working
Breathing only
5
Working
Breathing
Flash
Sampling and lab analysis required. Results are
relatively accurate.
Program distributed by the EPA through
their website at:
http://www.epa.gov/ttn/chief/efpac/efsoftware.html
From Chapter 6, Section 2, page 22 of Wyoming Permitting Guidance for Oil and Gas Production Facilities:
http://deq.state.wy.us/aqd/Oil%20and%20Gas/March%202010%20FINAL%20O&G%20GUIDANCE.pdf
11
Your environmental compliance is clearly our business.
12. Storage Vessels
Group 1 storage vessels
• Storage vessel for which construction, modification, or
reconstruction commenced after August 23, 2011 and on or
before April 12, 2013
• Determine VOC PTE by October 15, 2013
• Comply (install capture and controls) by April 15, 2015
Group 2 storage vessels
• Storage vessel for which construction modification, or
reconstruction commenced after April 12, 2013
• Determine VOC PTE by the later of April 15, 2014 or 30 days
after start-up
• Comply (install capture and controls) by the later of April 15,
2014 or 60 days after start-up
12
Your environmental compliance is clearly our business.
13. Standards for Storage Vessel
Affected Facilities
Group 1 storage vessels
• Submit notification identifying location of each Group
1 vessel with initial annual report
• Reduce VOC emissions by 95% by April 15, 2015 or
• Maintain uncontrolled VOC to < 4 TPY after
demonstrating that uncontrolled VOC emissions have
been < 4 TPY for 12 consecutive months
• Uncontrolled VOC emissions determined on a monthly
basis thereafter using average throughput for the
month
13
Your environmental compliance is clearly our business.
14. Standards for Storage Vessel
Affected Facilities
Group 2 storage vessels
• Reduce VOC emissions by 95% by April 15, 2014 or
within 60 days after startup or
• Maintain uncontrolled VOC to < 4 TPY after
demonstrating that uncontrolled VOC emissions have
been < 4 TPY for 12 consecutive months
• Uncontrolled VOC emissions determined on a monthly
basis thereafter using average throughput for the
month
14
Your environmental compliance is clearly our business.
15. Standards for Storage Vessel
Affected Facilities
Conditions regarding uncontrolled 4 TPY VOC
compliance option if conditions at well change:
• If well undergoes fracturing or re-fracturing:
Reduce VOC emissions by 95% as soon as liquids from the
well are routed to the storage vessel
• If VOC emissions increase to > 4 TPY without
fracturing or re-fracturing
15
Reduce VOC emissions by 95% within 30 days of the
determination
Your environmental compliance is clearly our business.
16.
Standards for Storage Vessel
Affected Facilities
Storage vessels removed from service
• Submit notification in annual report identifying all
affected vessels that are removed from service during
the period
• If returning to service and associated with fracturing
Comply with control requirement options immediately
Submit notification in annual report
• If returning to service and not associated with
fracturing
16
Determine VOC emissions within 30 days
If uncontrolled VOC emissions > 4 TPY must comply with
control requirements within 60 days of return to service
Submit notification in annual report
Your environmental compliance is clearly our business.
17. Standards for Storage Vessel
Affected Facilities
Storage vessel control requirements
• Control device option
Storage vessel cover and all openings must form continuous
impermeable barrier over the entire surface area of the
liquid
Liquids, gases, and fumes must vent through a closed vent
system to a control device or process
• Floating roof option
Meet requirements of 40 CFR Part 60 Subpart Kb
• Vapor recovery units (VRU) must meet closed vent
system requirements and have an operational uptime
of 95%
17
Your environmental compliance is clearly our business.
18. Controls for Storage Vessel
Affected Facilities
Covers
• Cover and all openings on the cover shall form a continuous barrier over the
entire surface area of the liquid in the storage vessel
• Each cover opening shall be secured in a closed, sealed position (gasket lid
or cap) whenever material is in the unit…
• Each storage vessel thief hatch shall be weighted and properly seated…
Closed vent system (CVS)
• Design the CVS to route all gases, vapors, and fumes emitted from the
material in the storage vessel to a control device
• Design/operate a CVS with no detectable emissions, as determined using
olfactory, visual and auditory inspections
• Meet control system bypass requirements as applicable
18
Your environmental compliance is clearly our business.
19. Controls for Storage Vessel
Affected Facilities
Control device
• Enclosed combustion device (e.g., thermal vapor incinerator,
catalytic vapor incinerator, boiler, or process heater)
• Designed to reduce the mass content of VOC emissions by 95.0
percent or greater
Ensure that each enclosed combustion device is maintained in a leak
free condition
Install and operate a continuous burning pilot flame
Operate the enclosed combustion device with no visible emissions
• Operation of control devices at all times when gases, vapors,
and fumes are vented from the storage vessel affected facility
through the closed vent system
19
Your environmental compliance is clearly our business.
20. Monitoring for Storage Vessel
Affected Facilities
Closed Vents and Covers
• Conduct monthly olfactory, visual and auditory
inspections for defects that could result in air
emissions
Control devices
• Monthly visible emissions test (Method 22)
>14 days between tests
• All inspection, repair and maintenance activities for each unit
must be recorded in a maintenance and repair log and must be
available for inspection
• Continuous parametric monitoring system
20
Combustion zone temperature for thermal oxidizers
Your environmental compliance is clearly our business.
21. Testing for Storage Vessel
Affected Facilities
Control device
• Testing exemptions
Certain flares and boilers
Performance test conducted by the manufacturer
• Testing requirements
EPA Methods to determine sample port location and gas volumetric
flowrate
Collection of integrated bag samples or grab samples
EPA Method 25A at inlet and outlet of control device
Calculation of control device efficiency on a mass basis
• Test schedule
21
Initial compliance test 180 days after start-up
Testing every 60 months thereafter
Your environmental compliance is clearly our business.
22. Recordkeeping for Storage Vessel Affected
Facilities
VOC PTE determination for each storage vessel with
calculation methodology and/or calculation model
used
Deviations from requirements
Mobile vessel consecutive days on site
• If removed and returned or replaced within 30 days, entire
period will count as consecutive days
Closed vent system inspections and results
Control devices:
•
•
•
•
22
Minimum and maximum operating parameter values
Continuous parameter monitoring data
Results of all compliance calculations
Results of all inspections
Your environmental compliance is clearly our business.
23. Reporting for Storage Vessel
Affected Facilities
Initial annual report due January 15, 2014
Subsequent reports due 90 days following end of
reporting period
• General information
• Storage vessel information
23
Identification and location of each storage vessel affected facility
constructed, modified, or reconstructed during the period
Documentation of VOC emission rates
Records of deviations that occurred during the reporting period
Identification of each Group 1 storage vessel with location
coordinates
Compliance statement regarding initial compliance requirements
Storage vessel affected facilities removed from service
Storage vessel affected facilites returned to service
Your environmental compliance is clearly our business.
24. Compliance for Storage Vessel
Affected Facilities
Initial compliance
•
•
•
•
•
•
Determine potential VOC emission rate
Reduce VOC emissions as required
Meet control requirements
Submit required notification information
Maintain required records
Submit Group 1 notifications
Continuous Compliance
• Reduce VOC emissions as specified
• Demonstrate continuous compliance with performance
requirements
24
Cover and closed vent system
Control devices
Your environmental compliance is clearly our business.
25. Gas Wells
Gas well affected facility
• Gas well or natural gas well means an onshore well
drilled principally for production of natural gas
Key distinctions
• Delineation wells
• Low pressure gas wells
• Wildcat wells
25
Your environmental compliance is clearly our business.
26. Standards for Gas Wells
Completions with hydraulic fracturing begun
before January 1, 2015
• Capture/direct flowback to a completion combustion
device (with reliable continuous ignition source)
• Exceptions include fire/explosion hazards, or where
high heat may negatively impact tundra, permafrost
or waterways
• “General duty” to “safely maximize resource recovery
and minimize releases to the atmosphere during
flowback and subsequent recovery”
26
Your environmental compliance is clearly our business.
27. Standards for Gas Wells
Completions with hydraulic fracturing begun after
January 1, 2015:
• Route the recovered liquids into one or more storage
vessels or re-inject the recovered liquids into the well
or another well and;
• Route the recovered gas into a gas flow line or
collection system, re-inject the recovered gas into the
well or another well, use the recovered gas as an onsite fuel source, or use the recovered gas for another
useful purpose that a purchased fuel or raw material
would serve, with no direct release to the atmosphere
27
Your environmental compliance is clearly our business.
28. Standards for Gas Wells
Completions with hydraulic fracturing begun after
January 1, 2015 (cont.):
• All salable quality gas must be routed to the gas flow
line as soon as practicable
Flow line means a pipeline used to transport oil and/or gas
to a processing facility, a mainline pipeline, re-injection, or
routed to a process or other useful purpose
In cases where flowback emissions cannot be directed to the
flow line
• Capture/direct flowback to a completion combustion device (with
reliable continuous ignition source)
28
Your environmental compliance is clearly our business.
29. Recordkeeping for Gas Wells
All completions with hydraulic fracturing:
• Records of completions
• Records of deviations
• Daily log records for each completion:
Post-January 1, 2015 - location, API well No., duration
(hours) of flowback, duration of recovery to flow line,
duration of combustion, duration of venting, and reasons
for venting
Pre-January 1, 2015 – same as above, except for recovery to
flow line requirements
• Exemption records (e.g., fire, explosion, heat, etc.)
• Records of required digital photographs (for post
January 1, 2015 completions)
29
Your environmental compliance is clearly our business.
30. Reporting for Gas Wells
Annual reports
• Initial report due January 15, 2014
• Subsequent reports due 90 days following end of the
reporting period
• General information
Company name and address
Identification of each facility included
Beginning and end date of the report period
Certification of truth, accuracy, and completeness
• Gas well information
30
Records of each well completion operation for each gas well
affected facility conducted during the reporting period or a list of
completions with hydraulic fracturing and associated records
Records of deviations that occurred during the reporting period
Your environmental compliance is clearly our business.
31. Notifications for Gas Wells
Commencement of well completion
• Electronic or written notification two (2) days prior to
the commencement of each completion
The anticipated commencement date
Contact information of owner/operator
API well number
Latitude/longitude coordinates
Planned flowback date
• State advance notice requirements are acceptable
31
Your environmental compliance is clearly our business.
32. Compliance for Gas Wells
Initial compliance is demonstrated by:
• Submit required notifications/annual report
• Maintain completion logs
• Maintain records of digital photographs of completions
(for post January 1, 2015 completions):
Date and latitude/longitude imbedded or stored with the digital
file
Equipment for storing or re-injecting recovered liquid
Equipment for routing recovered gas to the gas flow line
The completion combustion device (if applicable) connected to
and operating at each gas well completion
Continuous compliance is demonstrated by:
• Submitting required reports
• Maintaining required records
32
Your environmental compliance is clearly our business.
33. Key Points to Take Away
Subpart OOOO is a complicated rule with many
“moving parts”
Broad applicability over entire oil and gas sector
Determining if a tank is a “storage vessel affected
facility” will likely require process/emissions
sampling
Time is of the essence
• Deadline for Group 1 tank VOC emissions
determination is October 15, 2013
• Annual report for initial compliance period is due
January 15, 2014
33
Your environmental compliance is clearly our business.
34. Contact Information
Roy Rakiewicz
Senior Consultant
All4 Inc.
2393 Kimberton Road
Kimberton, Pennsylvania 19442
rrakiewicz@all4inc.com
www.all4inc.com
(610) 933-5246 extension 127
(484) 269-6246 cell
34
Your environmental compliance is clearly our business.
Notas del editor
Section 111 of the Clean Air Act, "Standards of Performance of New Stationary Sources," requires EPA to establish federal emission standards for source categories which cause or contribute significantly to air pollution. These standards are intended to promote use of the best air pollution control technologies, taking into account the cost of such technology and any other non-air quality, health, and environmental impact and energy requirements. These standards apply to sources which have been constructed or modified since the proposal of the standardSubpart OOOO is one of 94 NSPS written since 1971
Construction means fabrication, erection, or installation of an affected facilityModification - Except as provided under paragraphs (e) and (f) of this section, any physical or operational change to an existing facility which results in an increase in the emission rate to the atmosphere of any pollutant to which a standard applies shall be considered a modification within the meaning of section 111 of the Act.Things that are not modifications:Routine maintenance repair, and replacementIncrease in production if the increase is achieved without a capital expenditureAddition of air pollution controlsRelocation or change in ownership of an existing facility“Reconstruction” means the replacement of components of an existing facility to such an extent that:The fixed capital cost of the new components exceeds 50 percent of the fixed capital cost that would be required to construct a comparable entirely new facility, andIt is technologically and economically feasible to meet the applicable standards set forth in this part
Rule applicability is very broad – covers a wide variety of related but divergent equipment and operationsNot written in a user friendly manner – need to all possible sections that could apply to ascertain full impact and compliance obligationShares basic structure with other NSPSGeneral provisions - Subpart A apply as well and impact OOOO applicability
Need to determine if your tank is a “storage vessel” as defined by Subpart OOOOProduced water means water that is extracted from the earth from an oil or natural gas production well, or that is separated from crude oil, condensate, or natural gas after extraction.Intermediate hydrocarbon liquid means any naturally occurring, unrefined petroleum liquid.Condensate means hydrocarbon liquid separated from natural gas that condenses due to changes in the temperature, pressure, or both, and remains liquid at standard conditions.Mobile storage vessels must be removed (and not replaced with a similar unit) for > 30 days. Process vessels not specifically defined, but examples include surge control vessels, bottoms receivers or knockout vesselsPressure vessel means a storage vessel that is used to store liquids or gases and is designed not to vent to the atmosphere as a result of compression of the vapor headspace in the pressure vessel during filling of the pressure vessel to its design capacity - Pressure vessels designed to operate in excess of 204.9kilopascals and without emissions to the atmosphere.
Need to determine if your tank is a “storage vessel” as defined by Subpart OOOO
Losses need to include flash, working, and breathing losses of VOCE & P TANK From 1997, no longer supported by API but used extensively. Based on a pressurized sample.Vazquez-Beggs from early 80’s based on empirical data, needs to be supported by sampling, and is not very accurateGas to Oil ratio based on sampling and analysis and is accurate, flash emissions onlyTanks (AP-42) is user input based, is for working and breathing losses, and is accurateFlash emissions are the emissions released when a liquid under higher pressure moves to a vessel or area with a lower pressure. Example: Soda Can
In general, state protocols to determine emissions from storage vessels include the collection of pressurized samples to accurately account for flash emissions. Direct measurement of tank emissions is also an acceptable method to determine tank emissions (flash, working, and breathing), but is expensive and labor intensive. States may have prescriptive requirements associated with emissions testing as well.For emission testing, most states require preparation and approval of a test protocol
Reconsideration resulted in division of storage vessels into Group 1 or Group 2 vessels
4 TPY must be determined using generally accepted model or calculation methodology
What happens if emissions increase to > 4TPY of VOC?Controls need to be in place before fluids are introduced into tank from a fractured or re-fractured well30 days to install controls if PTE increased without re-fracturing, example could be removal of tanks from a battery that results in more fluids through the remaining tanks as a result of parallel filling.
Pay attention to requirements associated with affected storage vessels removed and placed back into service – storage vessels are subject to the “once in – always in” rule even though vessels only serve to store crude oil, condensate, light hydrocarbons, and produced water. Return to service requirement similar to requirements associated changes at tanks complying with 4 TPY uncontrolled VOC limit except for 60 compliance requirement without fracking.
Design, installation, and operation of covers, closed vent systems, and control devices is very prescriptive.
Delineation wells, low pressure wells, and wildcat wells are not subject to the green completion requirements (i.e. post January 1 2015), but must capture and direct flowback emissions to a completion combustion device.Exceptions include fire or explosion hazard, or where heat from a combustion device may impact tundra, permafrost, or waterways.Compliance still required with other provisions (logs, compliance demonstration, continuous compliance, recordkeeping, notification and reporting)
Deviations are cases where well completion operations with hydraulic fracturing were not performed in compliance with § 60.5357