13 Reasons to Comply With NSPS OOOO NOW
April 15, 2015

NSPS OOOO (Quad O) compliance is important to all affected oil and gas producing operators. Operators wanting be ahead of the game will want to implement a NSPS OOOO compliance system. Below are 13 reasons to comply with NSPS OOOO and all air quality rules.

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 HY-BON servicing vapor recovery unit (VRU) 

 13 Reasons

  1. Complying with regulations can make your company money. Vapor recovery unit compressors (VRU) can be used for storage tank methane recovery and VOC recovery for injection into the sales pipeline. Using a leak detection and repair (LDAR) program (e.g. leaking thief hatches) can help send more product to sales.

  2. It is a cost of doing business and a cost to be “in the game.”

  3. Fines up to $37,500 per day per violation with a maximum of $320,000 possible for failure to comply. See Federal Register Notice from November 26, 2013.

  4. Noncompliance could result in shut-in of production.

  5. The cost of defense/response (e.g., attorneys, staff, and travel costs) associated with noncompliance often exceed the cost of the fine.

  6. Public opinion, especially social media and internet news stories, can taint the perception of all oil and gas operators and can fuel much more regulation. Example: oil spills, flaring of associated gas in shale plays.

  7. Compliance helps improve Sustainability

  8. Compliance helps reduce environmental liabilities that have to be disclosed to shareholder groups, SEC, investors. This could affect the value of the company’s stock.

  9. Compliance helps improve the image of the CEO of the company and helps the CEO keep the company profitable.

  10. Compliance reduces VOC emissions (precursor to smog/ozone formation).

  11. Compliance reduces methane emissions. Methane is a regulated greenhouse gas (GHG) emission that has a global warming potential of 25. Reducing 1000 tons of methane is the same as reducing 10,000 tons of CO2 emissions.

  12. A history of environmental noncompliance could limit the ability of a company to obtain permits to operate facilities – nationwide. Some states use noncompliance history (serial offenders) as criteria for granting/rejecting approval of air permits. Many state regulatory agencies (such as TCEQ) assign scores or ratings based on a facility or operator’s compliance history.

  13. “Hiding in the weeds strategy” hurts operators that do comply and increases costs for the compliant operator that does incur the expense to comply.

Let HY-BON help your company get into compliance and stay in compliance with NSPS OOOO and make your company money. HY-BON’s vent gas management (VGM) system is a cost effective way to take this issue off of your plate. We can assist by accurately quantifying emissions and use “best in class” vapor recovery units (VRU), Vapor Recovery Towers (VRT) and enclosed combustors (VCU) to comply with Quad O storage tank emission control requirements. 

 HY-BON VOC Calculator Spreadsheet - Giveaway

HY-BON's VOC calculator can make your job easier. The spreadsheet can be used to calculate the mass (pounds and tons) of methane, volatile organic compounds (VOCs) and hazardous air pollutants (HAPs) of a natural gas stream. The inputs needed include volume of natural gas in standard cubic feet (SCF = 60°F and 14.7 psia) and the mole percents of the natural gas components.