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

Sep 6, 2018

Air permits for oil and gas (O&G) production facilities include Federal EPA and State requirements for storage tanks for crude oil, condensate and produced water. The main EPA rules applying to O&G storage tanks are the New Source Performance Standards (NSPS) OOOO and OOOOa. Individual state environmental regulatory agencies may have their own storage tank regulations that might also apply.

Storage Tank Air Permitting Compliance Tips

Jul 25, 2018

The Ohio Environmental Protection Agency (Ohio EPA) is the environmental agency that administers air quality regulations and permitting programs in Ohio. Oil and gas (O&G) production facilities are required to obtain, from the Ohio EPA, an air permit prior to construction and operation. The exception to this is that for some counties, the Local Air Pollution Control Agency (LAPCA) is the air permitting agency in lieu of Ohio EPA. Contact the Ohio EPA to determine the correct air permitting agency for the county. The LAPCAs work with the Ohio EPA on air permitting for O&G operations. The following link has a listing of: OH Regional Offices and LAPCs.  

Air Permitting in Ohio

Jul 10, 2018

Compliance with air quality rules and permits require oil and gas (O&G) facilities to minimize leaks from components and equipment. Federal rules in NSPS OOOOa require certain oil and gas (O&G) well sites and compressor stations to periodically monitor for leaking components. State air permits require storage tanks with emissions controls (e.g., VRUs, VCUs) to operate without leaks. Additionally, operators have a general duty to minimize leaks for safety and environmental requirements.

Find It and Fix It

Jun 13, 2018

In early May 2018, the federal EPA published a DRAFT document entitled “New Owner Clean Air Act Audit Program for Oil and Natural Gas Exploration and Production Facilities.” This voluntary audit program offers certain protections from Clean Air Act compliance penalties for newly acquired oil and gas (O&G) facilities provided the issues are resolved in a satisfactory manner. The agreement would only cover civil violations; there would be no protection from criminal liabilities.

This audit program is in addition to other EPA and State voluntary audit programs that are not focused on oil and gas operation.

New Owner Clean Air Act Audit Program for Oil and Natural Gas Exploration and Production Facilities

May 22, 2018

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

Below is a summary of some key things to know about the LDEQ air permitting process for O&G operations. Consult the LDEQ rules or contact the LDEQ Office of Environmental Services - Air Quality section for details for O&G air permitting. The focus of this article is minor source air permitting rules for oil and gas operations.

Oil and Gas Air Permitting in Louisiana

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