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# NSPS Subpart OOOO Lessons Learned... and a Look Ahead

Andy Woerner andrew.woerner@erm.com
May 13, 20142 The world’s leading sustainability consultancy 

# 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

 E 

### ven higher bar for ongoing demonstration of compliance for affected sources under the rule3 The world’s leading sustainability consultancy 

# Subpart OOOO

– Records and Reporting

 13 Jan 2014

– 1 st 

### 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 data4 The world’s leading sustainability consultancy 

# 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...5 The world’s leading sustainability consultancy 

# 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)]6 The world’s leading sustainability consultancy 

# 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...7 The world’s leading sustainability consultancy 

# 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 requirements8 The world’s leading sustainability consultancy 

# 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 devices9 The world’s leading sustainability consultancy 

# 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

 R esolve further issues in petitions for reconsideration

 Expect interplay with white papers, current focus on methane...10 The world’s leading sustainability consultancy 

# 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 Source11 The world’s leading sustainability consultancy 

# 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 YE201612 The world’s leading sustainability consultancy 

# 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 15 th**  **at 2 pm EDT to hear more about Methane Initiative, Flaring, and other hot topics... (Contact: andrew.woerner@erm.com)** 13 The world’s leading sustainability consultancy 

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