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NSPS Subpart OOOO

Lessons Learned... and a Look Ahead

Andy Woerner

andrew.woerner@erm.com

May 13, 2014
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Subpart OOOO – Subpart W Similarities...

 Subpart W 

 EPA issued rule relatively quickly

 Series of legal challenges

 Numerous rule updates

 Despite best efforts, there are always more compliance details 

to chase down or confirm

 Subpart OOOO

 All of the above

 Plus... 

 Some compliance deadline deferrals, but No BAMM

 Even higher bar for ongoing demonstration of compliance for 

affected sources under the rule
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Subpart OOOO – Records and Reporting

 13 Jan 2014 – 1st Annual Report

 Lessons Learned

 Defining end of flowback?

 Standard flowback data format? 

 PTE for Group 1 storage vessels

 Methodologies Used

 Enforceable Permit Limits

 Limited agency feedback to date...

 Looking to Next Annual Report

 Due same date next year

 Suggest ongoing / periodic review(s) of source data 
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Subpart OOOO – Storage Vessels

 If you cannot rely on permitting to limit PTE...

 Group 1 Tanks – Identified in Initial Annual Report

 Compliance Starting 15 April 2015

 Group 2 Tanks – Compliance Started 15 April 2014...
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Subpart OOOO – Storage Vessels

Compliance strategy for OOOO Tanks

 September 2013 updates replaced the continuous parameter 

monitoring system (CPMS) requirements with monthly inspections

 95% emission reduction (capture + control)

Starting with Group 2 Compliance Date (15 April 2014)...

 Monthly visual inspections of the pilot flame [§60.5417(h)(1)(i)]

 Monthly Method 22 [§60.5417(h)(1)(ii)]

 Monthly audible, visual, and olfactory (AVO) inspections 

 [§60.5417(h)(1)(iii)]
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NSPS OOOO – Storage Vessels

Method 22 (http://www.epa.gov/ttn/emc/promgate/m-22.pdf)

 Method is prescriptive – Use of stopwatch, taking of breaks, etc. 

 Record the following information on the field data sheet: Company 

name, industry, process unit, observer's name, observer's affiliation, 

and date. Record also the estimated wind speed, wind direction, and 

sky condition. 

 Sketch the process unit being observed, and note the observer 

location relative to the source and the sun. Indicate the potential 

and actual emission points on the sketch.

Ensuring consistency is not trivial for dispersed assets and personnel

Good News – still pretty early...
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NSPS OOOO – Storage Vessels

Addressing leaks found during OVA Inspections

 Repair the leak or defect as soon as practicable

 First attempt at repair < 5 calendar days after detection

 Repair < 30 calendar days after detection

 Apply grease to deteriorating gaskets while awaiting repair

 Delay of repair 

 If technically infeasible without a shutdown, or 

 If you determine that emissions resulting from immediate repair 

would be more than the fugitive emissions likely to result from delay

 Unsafe to inspect requirements

 Difficult to inspect requirements
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NSPS OOOO – Storage Vessels

http://www.epa.gov/airquality/oilandgas/pdfs/mantesteddevices.pdf

Exempt from monitoring if using 

an EPA approved control device

EPA Review of Control Devices

 EPA continues review to 

determine whether certain 

control devices are exempt from 

submitting test results pursuant 

to section 60.5413(a)(7).

 Max flow rate indicated for 

approved devices
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NSPS OOOO - Looking Ahead

2Q 2014 Proposal Expected 

 Guidance: upcoming “green completion” deadline in Jan 2015 

 Technical clarifications 

 e.g. tagging pneumatics < 10/15/13 not required

Addition rulemaking expected 

 Resolve further issues in petitions for reconsideration

 Expect interplay with white papers, current focus on methane...
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GHG Data – Driving Focus on Oil & Gas

http://www.epa.gov/ghgreporting/ghgdata/reported/index.html Note: CH4 estimates from the Inventory of U.S. 

Greenhouse Gas Emissions and Sinks: 1990-2012. 

U.S. Methane Emissions, By Source
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White House Methane Initiative

 March 28, 2014 - White House announced a new strategy to cut 

methane emissions for oil and natural gas systems 

 April 15, 2014 - Five white papers published by EPA

 Papers provide an overview of EPA’s understanding of emissions and 

mitigation options from potentially significant sources of methane and 

VOC emissions

 EPA is soliciting comments from industry on these source-specific white 

papers until June 16, 2014 

 In fall 2014, EPA will determine if additional regulations are needed

 Possible standards under section 111 of the Clean Air Act and/or 

 Possible Control Techniques Guidelines under section 182 of the Act. 

 If EPA decides to develop regulations... plan to complete by YE2016
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White House Methane Initiative

Summary of the white papers:

 Liquids unloading Plunger lift systems most common means of reducing 

emissions but emission reductions can vary considerably

 Reciprocating / centrifugal compressor venting Minimize emissions via rod 

packing replacement, use of dry seals, and vent gas capture and recovery

 Completions, recompletions and production from hydraulically fractured oil wells 

Reduced emission completions (RECs) 

 Pneumatic devices and pneumatic pumps Reduce with technology selection

 Equipment leaks Reduce with optical gas imaging (OGI) followed by leak repair

Join ERM’s webinar on May 15th at 2 pm EDT to hear more about Methane 

Initiative, Flaring, and other hot topics... (Contact: andrew.woerner@erm.com)
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