# 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**  **D evices**  (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 e xempt from emission testing requirements

**∗** M ust 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 57 th 

### Street, SE Charleston, WV 25304

Phone: 304

- 926

- 0499 ext. 1695

E

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

# Questions?