NSPS OOOO & Fracking Air Quality 

Rule Updates 

Oil & Gas Environmental Compliance Conference –

Appalachian Basin

May 13-14, 2014

Robert Keatley, PE

Senior Engineer/Supervisor

DEP – Division of Air Quality
∗ New Source Performance Standard (“NSPS”) OOOO -

Standards of Performance for Crude Oil and Natural Gas 

Production, Transmission and Distribution

∗ Published August 16, 2012

∗ Amended September 23, 2013

∗ Compliance Date - Flowback October 15, 2012

∗ Compliance Date - Pneumatic Controllers October 15, 2013

∗ Compliance Date- Storage Vessels April 15, 2014 and April 

15, 2015

NSPS OOOO
∗ Natural gas wells (“not oil wells”) – hydraulically fractured 

∗ Centrifugal Compressor – using wet seals

∗ Reciprocating Compressor 

∗ Pneumatic Controllers - continuous bleed 

∗ Each Storage Vessel (PTE 6 tpy VOCs) – crude oil, 

condensate, produced “water”, & intermediates

∗ Natural Gas Processing Plants – LDAR

∗ Sweetening Plants

NSPS OOOO Affected Facilities
∗ Applies to each hydraulically fractured/refractured

gas well drilled (commenced construction, 

modification, or reconstruction) after August 23, 2011

∗ Hydraulically fractured/refractured includes wells 

fractured w/ Water, Nitrogen, and/or Carbon Dioxide

Well Completions
∗ Each well drilled after 8/23/11 and before 1/1/2015 must:

∗ Flowback Operations - reduce VOC emissions with a 

completion combustion device (typically a flare) on or after 

October 15, 2012

∗ Completion Combustion Devices must be equipped with a 

“reliable continuous ignition source”

∗ Sources have a general duty to safely maximize resource 

recovery and minimize releases to the atmosphere

Well Completions
Completion Combustion 

Devices

(aka Flares)
∗ Gas Wells drilled on or after January 1, 2015

∗ “Green Completions” - route recovered liquids into 

storage vessels or re-inject the liquids into the well or 

another well and route recovered gas into a gas flow line, 

collection system, re-inject into the well or another well, or 

use as fuel, “with no direct release to the atmosphere”

∗ Salable quality gas must be routed to the flow line

Well Completions
∗ Two (2) day Notification - prior to commencement of 

each gas well completion beginning October 15, 2012

∗ Electronically Notify DEP and EPA by using 

DEPOilandGasSector@wv.gov and 

r3wellcompletion@epa.gov

∗ Instructions and form available on DAQ’s website 

www.dep.wv.gov/daq

Well Completions
∗ Must maintain a daily log for each gas well completion operation (digital photo alternative)

∗ Records of duration of flow into a line; duration of 

combustion; duration of venting (digital photo alternative)

∗ Specific reasons for venting in lieu of capture or 

combustion

∗ Digital photographs w/ Lat. & Lon. of all the equipment 

used during flowback with specific location (alternative)

Well Completions
∗ Annual report - for each gas well and equipment the 

report must provide a list of all well completions and any 

deviations where well completion operations or 

equipment (storage vessels, etc) were not performed in 

compliance

∗ Must be certified by the responsible official

∗ Must submit initial report within 90 days may arrange a 

common schedule for annual reporting

Well Completions
∗ Group 1 Storage Vessels - installed after 8/23/11 and on or before 4/12/2013 with potential VOC emissions 

of six (6) tons/year or greater (each vessel) determined by 10/15/2013 and that are located at the well 

site more than 180 consecutive days

∗ Group 2 Storage Vessels – installed after 4/12/2013 with potential VOC emissions of six (6) tons/year or greater (each vessel) determined by April 15, 2014 or within 30 days of startup (whichever is later) and 

that are located at the well site more than 180 consecutive days

∗ Vapor Recovery Units (VRUs) can be used to limit PTE provided they comply with the cover and closed 

vent system design requirements of NSPS OOOO “vented to the process” 

∗ DAQ’s permitting threshold is 6 lbs VOC/hr (144 lbs/day) for the entire well site “Potential Emissions Not 

Actual Emissions”

∗ Exemption less than 4 tpy VOC “Actuals” without controls (12 consecutive months, then monthly) – VRUs not considered control devices for NSPS OOOO

∗ VRUs “do not” count toward reduction in PTE for Rule 13 permitting

Storage Vessels
∗ Group 1 & 2 Storage Vessels shall reduce VOC emissions by 95%

∗ Group 2 must achieve emission reductions by April 15, 2014

∗ Group 1 must achieve emission reductions by April 15, 2015

∗ May install “practically enforceable” controls to reduce PTE

∗ “Once In Always In”, but may remove controls if actuals below 

4 tpy VOC

Storage Vessels Cont’d
∗ Enclosed Combustion Devices (aka flares) must operate with no 

visible emissions for periods not to exceed a total of 1 minute 

during any 15 minute period – Monthly Method 22 VE checks for 

a minimum of 15 minutes

∗ Enclosed Combustion Devices must have continuous burning 

pilot flame installed and operated and maintain the device to be 

leak free

∗ Annual visual/smell LDAR of closed vent systems

∗ Must operate control device at all times vapors are vented

Storage Vessels Cont’d

“Non-Manufacture” Tested Controls
∗ Combustion Controls “Enclosed Combustors” must 

be operated with no visible emissions (VE), except a 

total of 2 minutes during any hour

∗ Method 22 VE must be performed each calendar 

quarter for 1 hour

∗ Continuously monitor the inlet gas flow rate to 

demonstrate the flow is equal to or less than the max. 

specified by manufacturer

∗ Continuously monitor for pilot flame at all times

Storage Vessels Cont’d

“Manufacturer” Tested Controls
∗ Control Device “exempted” from performance testing, if 

performance test conducted by manufacturer in 

accordance with NSPS OOOO

∗ Boiler or process heater vent stream introduced with the 

primary fuel is exempt from performance testing

∗ Performance testing required for non-manufacturer tested 

controls to demonstrate compliance with 95% reduction 

within 180 days

Storage Vessels Cont’d

Performance Testing Controls


Storage Vessel –

Combustor Control Device 

“Thermal Vapor 

Incinerator”

(aka Enclosed Flare)
∗ Pneumatic controllers - installed after 8/23/2011 (extraction) & 

10/15/2013 (wellhead to extraction) – each pneumatic controller 

must be tagged with month & year of installation

∗ Reduce VOC emissions at wells to extraction plants (6 scf/hr or 

less bleed rate) and at extraction plants (zero bleed rate) by 

using a low bleed or no bleed design by October 15, 2013 

∗ Exemptions for less than or equal to 6 scfh continuous bleed 

and based on functional needs, including but not limited to 

response time, safety and positive actuation

Pneumatic Controllers

∗ Reciprocating compressors before extraction - reduce 

emissions by the replacement of rod packing (every 

26,000 hours of operation or 3 years) *well site 

engines are exempt

∗ Centrifugal compressors (Wet Seal) - required to 

install air pollution control equipment to reduce 

emissions by 95% and to monitor this equipment *well 

site engines are exempt

Compressor Engines

after 8/23/2011

∗ MACT Subpart HH – Dehydration Unit Updates

*Annually update Wet Gas Analysis and GLYCalc

determination ; if the station’s actual emissions are 

greater than 50% of major source thresholds (storage 

vessels included, not engines)

*Updated samples and GLYCalc determinations by 

October 12, 2012 or within one year prior

*Must use the maximum designed glycol pump

recirculation rate when determining major source status

*Must include storage vessels in determining major 

source status of HAPs (excludes surge control vessels and 

knockout vessels)

Other Big Changes
∗ NSPS KKK Replaced with NSPS OOOO

∗ LDAR requirements at Extraction Plants that 

commenced construction, modification, or 

reconstruction after August 23, 2011

∗ Requires LDAR in accordance with NSPS VVa, which has 

lower leak definitions

Other Big Changes
∗ Compliance dates have changed

∗ Non-road Engines are not subject to this rule

∗ New exemption for existing area source engines defined as “Remote” 

stationary RICE

∗ Remote RICE exempt from emission testing requirements

∗ Must evaluate the status of their “Remote” stationary RICE every 12 months

∗ Non-remote 4SLB & 4SRB engines > 500 HP must have a catalyst installed by Oct. 19, 2013 (unless granted an extension)

MACT ZZZZ RICE Engines

Rule Updated
Robert Keatley, PE

Division of Air Quality

601 57th Street, SE

Charleston, WV 25304

Phone: 304-926-0499 ext. 1695

E-mail: Robert.L.Keatley@wv.gov

Questions?