# E C 

# / R Incorporated Providing Environmental Technical Support Since 1989

1 MEMORANDUM

DATE: October 20, 2010

SUBJECT: Summary of the October 19, 2010 Teleconference with the Sean Mooney to

Discuss Leak Detection and Repair (LDAR) Programs at Natural Gas Processing

Plants

FROM: Bradley Nelson, EC/R, Inc.

TO: Bruce Moore, EPA/OAQPS/SPPD/CCG

1.0 INTRODUCTION

EPA is in the process of reviewing air regulations affecting the oil and natural gas industry. This review includes the leak detection and repair (LDAR) requirements for oil and natural gas production

, natural gas processing

, natural gas transmission

, and natural gas

distribution. These air regulations include the requirements in the following NSPS and

NESHAP: The NSPS for Equipment Leaks of VOC from Onshore Natural Gas Processing Plants (40 CFR part 60, subpart KKK) and the NESHAP From Oil and Natural Gas Production

Facilities (40 CFR part 63, subpart HH)

. Sean Mooney, Regional Operations Manager at EMS

, (a contractor LDAR monitoring company) was contacted to discuss the current LDAR practi ces that are currently being performed at gas processing plants.

2.0 SUMMARY OF MEETING

A meeting via teleconference was set up between Sean Mooney of EMS

, and Phil

Norwood and Bradley Nelson of EC/R Inc. The purpose of the meeting was to discuss the

LD AR progr ams that are currently being used in the natural gas processing industry. The primary topics that we re discussed in the teleconference were:

 Compressor requirements for subpart KKK and subpart HH ( which refers to §60.482

- 3, §61.242

- 3) ;

 D etection of leaks from high methane/low VOC streams ;

 Possible use of Method 21 to detect leaks from seals on “bleeding” pneumatic devices

.

Mr. Mooney stated that the 90 percent of the facilities that he works with are MACT

facilities and report using the requirem ents in 40 CFR part 60, subpart KKK. He stated that th at
the requirement s in subpart KKK are more stringent than 40 CFR part 60, subpart VV and2

requires repairing of leaks greater than 10,000 parts per million (ppmv). He also stated that the

facilities u se EPA Method 21 to determine equipment leaks. EC/R asked if additional equipment would need to be monitored if the leak definition was reduced to 500 ppm. Mr. Mooney responded that existing gas processing facilities do not have the technology to meet th e 500 ppm

standard. He stated that most of the existing gas processing facilities are old and replacing the older equipment with new technology would be very expensive. As an example , Mr. Mooney stated that many facilities use positive displacement (PD) pumps in gas processing, which leak a stream of the natural gas to allow the pump to cool. The cost of replacing these existing PD pumps with new vane pumps, which can meet the 500 ppm standard, would be approximately $70,000 per pump. This would primari ly be an issue for existing gas processing plants.

The next topic of discussion was the compressor leak requirements. Mr. Mooney stated that 90 percent of the compressors used in gas processing plants were installed before January 20, 1984 and a re “grand fathered,” and did not have to meet any requirements in 40 CFR part 63, subpart HH. The citation for this clause was found in §6 3

. 769(b) which states :

“ (b) This section does not apply to ancillary equipment and compressors for which the

owner or operator is meeting the requirements specified in subpart H of this part; or is meeting the requirements specified in 40 CFR part 60, subpart KKK. ”

The subpart KKK regulation only applies to facilities that commence construction, reconstruction, or modification a fter January 20, 1984. Mr. Mooney stated that most of the compressors that are not “grandfathered” either route the captured emissions from the stuffing box to a flare or capture the emissions using a vapor recovery device. He also stated that some of th e processing plants are replacing their older engine compressor with turbine c ompressors, which do not leak.

The next topic that was discussed was pneumatic devices. Mr. Mooney stated that field gas is used to operate the pneumatic devices in the field, which are used to alleviate natural gas processing pressure. He stated that it would be difficult to distinguish the difference between leaking of the processed gas and the field gas used to operate the pneumatic device. He also

stated that these device s are not currently regulated.