HY-BON/EDI Blog: Quad O Compliance and Vent Gas Management

Mar 27, 2018

On March 1, 2018, the U. S. Environmental Protection Agency (EPA) announced changes to NSPS OOOOa regarding monitoring of fugitive equipment leaks (aka LDAR) for well sites and compressor stations. The March 1, 2018, announcement will be effective after the rule changes are published in the Federal Register.

Feb 15, 2018

Operators use enforceable limits in air permits to avoid triggering NSPS OOOOa applicability for crude oil, condensate and produced water storage tanks. To obtain an enforceable limit, the limits must be included in a legally and practically enforceable air permit or other authorization. Air permits granted by a federal, state, local or tribal authority typically meet these requirements. Consult your permitting agency to ensure that the permit or other authorization is enforceable.

Use Enforceable Limits to Avoid NSPS OOOOa for Storage Tanks

Jan 25, 2018

Oil and gas companies prepare air emission inventories for several reasons. These include compliance with regulatory requirements and company internal policies. Emission inventories for oil and gas operations are used to determine emissions from venting sources, fugitive sources and combustion sources. These can be based on potential to emit (PTE) emissions (as used for air permits) or for actual emissions based on operations during a selected period. Direct measurement, engine emission stack testing, emission factors and process simulators are used to quantify emissions.

Jan 8, 2018

Rules in 40 CFR 60 Subpart OOOO and OOOOa require routine visibility observation testing for enclosed combustion devices (e.g., VCU) and flares (open-tipped, candlestick flares).

Enclosed combustion devices and flares are required under NSPS OOOO and OOOOa to be operated with no visible smoke emissions, except for periods not to exceed a total of 1 minute during any 15-minute period. To demonstrate compliance, a visibility test known as EPA Method 22 is used.

NSPS OOOO/OOOOa EPA Method 22 Visible Emissions Testing (Enclosed Combustors and Flares)

Nov 28, 2017

Certain oil and gas production facilities with applicable requirements in 40 CFR 60 Subpart OOOO and OOOOa are required to submit an annual report to the USEPA and State environmental agency (if the State has delegation). Most states have EPA delegation to administer these two rules. 

NSPS OOOO and OOOOa Annual Reporting

Nov 13, 2017

The USEPA and many States allow operators to voluntarily disclose violations of environmental laws and regulations that are found during an audit. This can involve air, water, waste and other environmental laws and regulations. These programs can be used protect the confidentiality of audit findings and reduce or eliminate monetary penalties provided the company meets certain criteria. Application of these laws/policies are usually on a case-by-case basis.

Voluntary Disclosure of Environmental Violations

Sep 12, 2017

The Oklahoma Department of Environmental Quality (OKDEQ) is the environmental agency that administers air quality regulations and permitting programs in Oklahoma. Oil and gas (O&G) production facilities are required to obtain, from the OKDEQ, an air permit prior to construction with some exemptions available.

Oil and Gas Air Permitting in Oklahoma

Aug 22, 2017

Oil and gas production processes result in the venting of a portion of the produced natural gas. Vent gas management is a continuing issue for oil and gas operators. Companies must balance permitting requirements, regulatory compliance and corporate responsibility to minimize pollution, waste and liabilities.  Recovery of the vent gas increases revenue to the facility while releasing the gas to the atmosphere or combusting the gas results in air pollution. This makes an understanding of vent gas and a practical management strategy important.

Oil and Gas Venting Emissions

Jul 31, 2017

Oil and gas operators prepare air emission inventories for their facilities for a variety of reasons. Air emission inventories gather data from facilities so that air emissions can be quantified. These reasons for conduct an air emission inventory include the following:

  • Air permitting for new facilities and modifications to existing facilities
  • Annual criteria air pollutants and hazardous air pollutants (HAP) inventories for major sources
  • Greenhouse gas (GHG) inventories
Oil and Gas Air Emission Inventories

Jun 9, 2017

In a Federal Register Notice dated June 5, 2017, the EPA granted a reconsideration and partial stay of the Oil and Natural Gas New Source Performance Standards in NSPS OOOOa. Consult the Federal Notice EPA–HQ–OAR–2010–0505; FRL–9963–40–OAR for details.

NSPS OOOOa 90-Day Stay Finalized