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

Jan 25, 2017

OVERVIEW: The below is BLM reasoning for the rule. HY-BON/EDI can help you through it.  The Bureau of Land Management (BLM) has updated its regulations to reduce the waste of natural gas from flaring, venting, and leaks from oil and gas production operations on public and Indian lands.  The final requirements, which will be phased in, will help curb waste of our nation’s natural gas supplies; reduce harmful air pollution, including greenhouse gases; and provide a fair return on public resources for federal taxpayers, Tribes, and States.

Jan 6, 2017

Vapor combustion units (VCU) also called enclosed combustion devices or enclosed flares are widely used in oil and gas operations to control vent gas VOC and methane emissions. VCUs are a good alternative control device when a vapor recovery unit (VRU) is not feasible for the application. Many operators prefer VCUs over candlestick (open tipped) flares since properly designed and sized VCUs do not have a visible flame, minimize or eliminate any smoke and have a far greater destruction efficiency.

Enclosed Vapor Combustors Units and Air Quality Regulations

Dec 12, 2016



Final Rule Limits Venting, Flaring and Leaking from Oil & Gas Operations to Reduce Waste and Harmful Emissions, Provide Fair Return to Taxpayers. The Mineral Leasing Act requires the BLM to ensure that operators “use all reasonable precautions to prevent waste of oil or gas.”  Important elements of the final rule include:

Dec 8, 2016

For storage tanks, NSPS OOOO and OOOOa have similar requirements in regards to applicability, emission limitations, recordkeeping and reporting requirements. Some exceptions for storage tanks are different applicability dates for the two rules and NSPS OOOOa added requirements for closed vent systems (piping) used to control NSPS OOOOa affected facility storage tanks.

Below is a summary of key parts of the rules. Unless specified, the requirements apply to NSPS OOOO and OOOOa. Consult the written rules for details.

NSPS OOOO and OOOOa and Storage Tank Requirements

Nov 4, 2016

The continued regulation of greenhouse gases (GHGs) in all sectors of the economy will continue in the future. Expect more direct regulatory command and control regulations (e.g., NSPS OOOOa), voluntary initiatives and other methods (e.g., taxes) to further reduce GHGs.

Based on this, it is prudent for all companies to quantify and track their GHG emissions to prepare for future governmental impacts. This issue not only affects traditional industries that emit GHGs but also affects all sectors of the economy that consume products and services that generate GHGs.

Oct 9, 2016

On September 29, 2016, the EPA published the Second Draft Information Collection Request (ICR) for the Oil and Natural Gas Industry. The ICR will collect emission inventory related data that will be used to develop emission standards (reductions) for existing facilities. Existing facilities that are exempt from NSPS OOOO and OOOOa are the target of this data request. The EPA is using its authority under Section 114 of the Clean Air Act to request the information.

This is a one-time survey that seems to be on track for a data submittal to the EPA before the end of 2016. See link: ICR 2nd Draft for details.

Second Draft EPA Mandatory Information Collection Request (ICR) for Oil and Gas Facilities

Aug 24, 2016

(Updated November 13, 2019)


1. What is a VRU?

A VRU, or Vapor Recovery Unit, is a compression system used to collect and compress low volume gas streams for injection into the suction of a larger compressor, a meter run, a local site fuel gas system or directly into a gas gathering line. Mechanical VRUs consist of a driver motor or engine that supplies the power to the compressor. They are often used by oil and gas operations to recover vent gas.

Frequently Asked Questions about Vapor Recovery Units (VRUs)

Aug 8, 2016

Existing federal and state air quality and permitting regulations require oil and gas (O&G) production facilities to control emissions from crude oil, condensate and produced water storage tanks. The primary federal EPA rules for storage tanks (and other O&G sources) are in NSPS OOOO and NSPS OOOOa. These NSPS rules affect facilities construction after August 23, 2011. State environmental regulatory agencies have their own standards and permitting regulations that require storage emission controls for existing and new facilities.

These federal and state air permitting rules require the storage tank vapor controls systems to be designed and operated such that emissions are continuously controlled. Inadequately designed storage tank emission control systems that result in venting of VOCs are a focus of the EPA.

Vent Gas Measurement and Storage Tank Emission Controls

Jul 1, 2016

The EPA intends to collect emission inventory related data from the oil and gas industry to gather information that will be used to develop emission standards (reductions) for existing facilities. 

The New Source Performance Standards in 40 CFR 60 Subpart OOOO and OOOOa exempt existing oil and gas facilities that were constructed on or prior to August 23, 2011 (and not modified or reconstructed after that date). These “existing” facilities are the target of this data collection.

The method that will be used to obtain the data is an Information Collection Request (ICR).  The EPA is not required to go through rulemaking to request this information. EPA has authority under Section 114 of the Clean Air Act to request the information provided the request is approved by the Office of Management and Budget (OMB). 

EPA Mandatory Information Collection Request (ICR) for Oil and Gas Facilities

Jun 24, 2016

The EPA’s amended and new regulations affecting methane (CH4) and VOC emissions from the oil and gas (O&G) sector have been finalized. The EPA published the new rules in the Federal Register on June 3, 2016, amending 40 CFR 60 Subpart OOOO. The final NSPS rules become effective August 3, 2016.

These rules revise NSPS OOOO and create the new NSPS OOOOa. NSPS OOOO affects O&G gas facilities constructed, modified or reconstructed after August 23, 2011, and on or before September 18, 2015. NSPS OOOOa affects facilities constructed, modified or reconstructed after September 18, 2015. NSPS OOOOa includes CH4 and VOC emission standards.