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### June 30, 2014 MEMORANDUM SUBJECT: Technical Corrections to the Final Oil and Natural Gas Sector: New Source

Performance Standards FROM: Bruce Moore

Senior Technical Advisor, Oil and Natural Gas Sector Sector Policies and Programs Division Office of Air Quality

Planning and Standards TO: Docket ID No. EPA

- HQ
- OAR
- 20 1 0
- 0 505

The Final Oil and Natural Gas Sector: New Source Performance Standards and National Emission Standards for Hazardous Air Pollutants Reviews was published in the Federa l Register on August 16, 2012 (7 7 FR 49490 ). The final rule, which became effective on October 13 , 20 12 , established standards for certain oil and gas operations not covered b y the existing standards and include volatile organic emissions from gas wells, c entrifugal compressors, reciprocating compressors, pneumatic controllers, and storage vessels (40 CFR part 60, subpart OOOO)

. On September 23, 2013 (78 FR 58416) , final amendments to subpart OOOO were published to make changes primarily

affecting implementation of the storage vessel provisions of the NSPS. The technical corrections in this memorandum do not change the basic requirements of the rule, but are intended to improve clarity and ensure consistency across the notification , monitoring, and reporti ng requirements. The technical corrections are made only to the final rule and are detailed in the following table

. **Technical Corrections**  **to the Final Rule**  There were two categorical sets of technical corrections that will be made to the above

referenced final rule

. The first set deals with the technical correction s to the rule to make the regulatory

text consistent with proposed amendments of the rule as discussed in the preamble and to correct inadvertent text errors and omissions in the 2012 and 2013 final actions . The second set of technical corrections covers a number of revisions that are editorial in nature, including , for example, ty pographical , grammatical errors , and incorrect references

. The sets of technical corrections described above translate into the following set of 29 specific changes that will be made to the above

- referenced f inal r ule

. T he attached table identif ies the citations and provides a summary

of the changes to the regulatory text
.

### 2 **Table 1. Summary of Revisions Made to 40 CFR Part 60 Subpart OOOO f**  **or the Oil and Natural Gas Sector.**  

### Section **Cit es**  **Revision Summary**

**40 CFR Part 60, Subpart**  **OOOO**

**– Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution**  **40 CFR Part 60, Subpart**  **OOOO**

**– Standards of Perform**  **ance for Crude Oil and Natural Gas Production,**  **Transmission and Distribution** Outline of the subpart  §60.5 411 of the subpart outline is revised to include the term “reciprocating compressors

. ”

 §60.5 416 of the subpart outline is revised to include the term “reciprocating compressor affected facility.” **§60.53 75**  **What standards apply to gas well**  **affected facilities?** ( a)  Paragraph s ( a)(2) and (3) are revised to replace the term “flowback emissions” with “recovered gas” to be consistent with proposed revisions to this section.  Paragraph ( a)(3) is revised to remove the phrase “for the duration of flow back” from the end of the sentence, because the phrase is not needed. (b)  Paragraph (b) is revised to replace the phrase “well completion operation” with “flow back period” to be consistent with proposed revisions to §60.5 375(a). (f)  Paragraphs (f)(1)(i) and (ii) are revised to remove the phrase “a gas well affected facility meeting the

criteria for,” because the phrase is not needed in those paragraphs.  Paragraph s ( f)(2) is revised to replace the term “flowback emissions” with “recovered gas” to be consistent with proposed revisions to this section  Paragraph ( f

)( 2 ) is revised to remove the phrase “for the duration of flow back , ” because the phrase is not needed.  Paragraph (f)(2) is revised to add the sentence, “(A}s soon as the rate of flowback has declined and stabilized enough to allow separation and recovery of any crude oil, condensate or produced water, route the recovered liquids to sto rage vessels.” This change is being made to clarify that proper handling of liquids is required for exploratory, delineation and low pressure gas well affected facilities. **§60.5390 What standards apply to**  **pneumatic controller affected**

**facilities?** (c)  This paragraph was revised by adding the phrase , “constructed, modified or reconstructed on or after October 15, 2013 ,” to clarify that there are no requirements for pneumatic controller affected facilities located in the oil and natural gas production segment s that were constructed, modified or reconstructed prior to October 15, 2013. **§60.5395 What standards apply to storage vessel affected facilities?**  ( d)  Paragraph ( d)(1 )( i) is revised by adding “ except as otherwise provided below in this paragraph. For storage vessels receiving liquids pursuant to the standards for gas well affected facilities in §60.5375, you must achieve the required emissions reductions within 60 days after the beginning of the production stage as defined in §60.5430. ” This revision is needed to correspond with the proposed clarification of provisions for liquids handling in §60. 5375
. ( f )  Revised introductory paragraph by adding “No other provision of this subpart applies to a storage vessel affected facility while that storage vessel affected facility is removed from service.” to clarify

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### Section **Cit es**  **Revision Summary** that there are no requirements , except for paragraphs (f)(1) and (2), that apply to storage vessel affected facilities during the period they are removed from service. **§60.5410 How do I dem onstrate**  **com pliance with the standards for**  **my gas well affected facility, my reciprocating com** **pressor affected facility, m** **y pneumatic controller affected facility, m** **y storage vessel affected facility, an**  **d m y equipment**  **leaks and sweetening unit affected facilities at onshore natural gas**  **processing plants?** (d)  This revision corrects a typographical error. A space is being inserted between the words “than” and “natural” in paragraph (d)(2).

**§60. 5411**  **What additional**  **requirements must I meet to determine initial compliance for m** **y covers and closed vent systems**  **routing m aterials from storage**  **vessels and centrifugal compressor wet seal degassing systems?**  Section heading  The heading of §60.5 411 is revised to in clude the term “reciprocating compressors.” (a)  The heading of paragraph (a) is revised to insert the phrase “reciprocating compressors and for” to

be consistent with revisions to §60. 5385.  Paragraph (a)(1) is revised to insert the phrase “the reciprocating compressor or” to be consistent with revisions to §60. 5385. (b)  The heading of paragraph (b) is revised to insert the phrase “reciprocating compressors” to be

consistent with revisions to §60. 5385. **§60.5412 What additional requirements must I meet for**  **determining initial compliance with control devices used to com** **ply with**  **the em ission standards for my**  **storage vessel or centrifugal com** **pressor affected facility?** (d)  The introductory paragraph is revised by inserting the phrase “ to paragraph (d)(1) of this section” to clarify applicability of an alternative provided in th e 2013 storage vessel amendments

.

**§60.5413 What are the perform ance**  **testing procedures for control devices used to demonstrate compliance at**  **my storage vessel or centrifugal com** **pressor affected facility?** (e)  Introductory paragraph is revised to replace “(e)(1) through (6)” with “(e)(1) through (7).  Paragraph (e)(7) is added to correct an omission in the 2013 storage vessel amendments to read “(7) ( E)nsure that each enclosed combustion device is maintained in a leak free condition. ”

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### Section **Cit es**  **Revision Summary §60.5415 How do I dem**  **onstrate continuous compliance with the**  **standards for m y gas well affected**  **facility, m y centrifugal compressor**  **affected facility, m y stationary**  **reciprocating com pressor affected**  **facility, m y pneumatic controller**  **affected facility, m y**  **storage vessel affected facility, and m** **y affected facilities at onshore natural gas**  **processing plants?** (c)  The introductory text is revised to be consistent with proposed amendments to §60.5385 by inserting the phrase “complying with §60.5385(a)(1) or (2) ” in the first sentence and adding the second sentence , “( F ) or each reciprocating compressor affected facility complying with §60.5385(a)(3), you must demonstrate continuous compliance according to paragraph (c)(4) .”  Paragraph (c)(4) is added as follow s: “ (4) ( Y ) ou must continuously comply with the closed vent and cover requirements in §60.5411(a) and (b).

**§60.5416 What are the initial and continuous cover and closed vent**  **system inspection and monitoring requirements for m** **y storage vessel and centrifugal**  **com pressor affected** 

**facility?** Section heading  The section heading is revised by adding “ and reciprocating compressor affected facili ties” to be consistent with proposed amendments to §60.5385
. (a)  Introductory paragraph is revised by adding “ or reciprocating compressor affected facility” to be

consistent with proposed amendments to §60.5385
. (b)  Introductory paragraph is revised by adding “ or reciprocating compressor” to be consistent with

proposed amendments to §60.5385
. **§60.5420 What are my** **notification, reporting, and recordkeeping**  **requirements?** (b )  Paragraph (b) (6)(ii) is revised to clarify that determination of a storage vessel’s potential to emit VOC must be reported only in the first annual report by adding the phrase , “ for each stora ge vessel that became an affected facility during the reporting period.”  Paragraph (b) (6)(vi) is revised by adding the phrase, “, including the date the storage vessel affected facility was removed from service,” to be consistent with proposed amendments to §60.5395(f).  Paragraph (b) (6)(vii) is revised by adding the phrase, “, including the date the storage vessel affected facility was returned to service,” to be consistent with proposed amendments to §60.5395(f). (c)  Paragraph (c) (3)(ii) is revised by adding the phrase, “ or date of installation of a closed vent system

as specified in §60.5385(a)(3),” to be consistent with proposed amendments to §60.5385.