EC

/R Incorporated Providing Environmental Technical Support Since 1989

August 2, 2013

MEMORANDUM

SUBJECT: Oil and Natural Gas Sector: Reconsideration of Certain Provisions of New Source 

Performance Standards (78 FR 22126; April 12, 2013); Editorial and Simple 

Clarification Changes Made to the Proposed Rule

TO: Bruce Moore

Senior Technical Advisor, Oil and Natural Gas Sector

Sector Policies and Programs Division

Office of Air Quality Planning and Standards

FROM: EC/R Incorporated

The proposed Oil and Natural Gas Sector: Reconsideration of Certain Provisions of New Source 

Performance Standards was published in the Federal Register on April 12, 2013 (78 FR 22126). 

Editorial (e.g., typographical, grammatical errors, and incorrect references) and simple 

clarifications made to the rule since proposal (that are not addressed in the final rule preamble or 

the Oil and Natural Gas Sector: Reconsideration of Certain Provisions of New Source 

Performance Standards; Response to Public Comments on Proposed Rule document (see Docket 

ID No. EPA-HQ-OAR-2010-0505)) and the basis for the changes are presented in Table 1 of this 

memorandum.

501 Eastowne Drive, Suite 250  Chapel Hill, North Carolina 27514

Telephone: (919) 484-0222  Fax: (919) 484-0122
Table 1. Editorial and/or Simple Clarification Revisions Made to the Proposed Rule 

Section Citation Edits and Basis

§60.5390 What 

standards apply to 

pneumatic controller 

affected facilities?

(a) EDITS (bold text is new): 

§60.5390(a): The requirements of paragraph (b)(1) or (c)(1) of this section are not required if you determine that 

the use of a pneumatic controller affected facility with a bleed rate greater than the applicable standard is required 

based on functional needs, including but not limited to response time, safety and positive actuation. However, you 

must tag such pneumatic controller with the month and year of installation, reconstruction or modification, and 

identification information that allows traceability to the records for that pneumatic controller, as required in 

§60.5420(c)(4)(ii).

BASIS:

Clarification that, although the requirements of paragraph (b)(1) or (c)(1) may not apply, an owner or operator 

would still be subject to the requirement to tag such pneumatic controllers (as required in §60.5420(c)(4)(ii)).

§60.5410 How do I 

demonstrate compliance 

with the standards for 

my gas well affected 

facility, my 

reciprocating 

compressor affected 

facility, my pneumatic 

controller affected 

facility, my storage 

vessel affected facility, 

and my equipment leaks

and sweetening unit 

affected facilities at 

onshore natural gas 

processing plants?

(c)(2) EDITS (bold text is new): 

§60.5410(c)(2): You must submit the notifications required in §60.7(a)(1), (a)(3) and (a)(4). [Reserved]

BASIS: 

To remove notification requirements from reciprocating compressor affected facility initial compliance 

demonstration requirements (consistent with §60.5420(a)(1) of the rule).

(h) EDITS (bold language is new): 

§60.5410(h), (h)(1) through (4): (h) For each storage vessel affected facility that is subject to §60.5395(d), you must 

comply with paragraphs (h)(1) through (5) of this section. For a Group 1 storage vessel affected facility, you must 

demonstrate initial compliance by April 15, 2015, except as otherwise provided in paragraph (i) of this section. 

For a Group 2 storage vessel affected facility, you must demonstrate initial compliance by April 15, 2014, or 

within 60 days after startup, whichever is later.

(1) You must determine the potential VOC emission rate within 30 days after startup. You must used good 

engineering practices to minimize emissions during the 30-day period as specified in §60.5365(e).

(2) You must reduce VOC emissions by 95.0 percent or greater within 60 days after startup or by April 15, 

2014, whichever is laterin accordance with §60.5395(d).

(3) If you use a control device to reduce emissions, or if you route emissions to a processflowline, you must 

demonstrate initial compliance by meeting the requirements in paragraphs (h)(3)(i) and (ii) of this 

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Section Citation Edits and Basis

section§60.5395(e).paragraphs (h)(3)(i) and (ii) of this section. For a Group 1 storage vessel affected facility, you 

must demonstrate initial compliance within 30 days after an event (as provided in §60.5395(b)) or by April 15, 

2014, whichever is later. For a Group 2 storage vessel affected facility, you must demonstrate initial compliance 

within 60 days after startup or by April 15, 2014, whichever is later.

 (i) You must equip the storage vessel with a cover that meets the requirements of §60.5411(b) and is 

connected through a closed vent system that meets the requirements of §60.5411(c).

(ii) You must route the closed vent system to a control device that meets the conditions specified in 

§60.5412(c) and (d) or to a flow line, as defined in §60.5430.

(4) You must submit the information required for your storage vessel affected facility as specified in 

§60.5420(b) in paragraphs (h)(4)(i) through (iii) of this section in the initial annual report required in §60.5420(b). 

(i) The results of the emissions determination conducted under §60.5395(b) or (c), as applicable, and the 

methodology used to determine emissions.

(ii) A statement that you have met the requirements of paragraph (h)(2) of this section.

(iii) A statement that you have met the emissions standards in §60.5395(d).

(5) You must maintain the records required for your storage vessel affected facility, as specified in 

§60.5420(c)(5) through (8) and §60.5420(c)(12) and (13) for each storage vessel affected facility.

BASIS: 

To improve the clarity of Group 1 and Group 2 storage vessel affected facility requirements and to reduce 

redundancy by cross-referencing relevant requirements, as applicable.

(i) EDITS (bold language is new): 

§60.5410(i): For each Group 1 storage vessel affected facility, you must submit a the notification specified in 

§60.5395(b)(2) with the initial annual report specified in §60.5420(b)(6) identifying each storage vessel, including 

its location by October 15, 2013. If you have an event that results in VOC emissions from the Group 1 storage 

vessel equal to or greater than 6 tpy after April 12, 2013, as specified in §60.5395(b), you must comply with 

paragraph (h) of this section.

BASIS:

To clarify that the requirements apply to affected facilities and that the initial notification for Group 1 storage 

vessel affected facilities may be submitted with the facility’s annual report.

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Section Citation Edits and Basis

§60.5411 What 

additional requirements 

must I meet to 

determine initial 

compliance for my 

covers and closed vent 

systems routing 

materials from storage 

vessels and centrifugal 

compressor wet seal 

degassing systems?

(b)(2)(iv) EDITS (bold language is new): 

§60.5411 (b)(2)(iv): To vent liquids, gases, or fumes from the unit through a closed-vent system to a control 

devicedesigned and operated in accordance with the requirements of paragraph (a) or (c) of this section to a 

control device or to a process. or to a flow line, as defined in §60.5430.

BASIS: 

To more accurately describe the requirements that apply (paragraphs (a) or (c) of §60.5411).

(c)(2) EDITS (bold language is new): 

§60.5411(c)(2): You must design and operate a the closed vent system with no detectable emissions, as 

determined using olfactory, visual and auditory inspections. 

BASIS: 

Typographical error.

§60.5413 What are the 

performance testing 

procedures for control 

devices used to 

demonstrate compliance 

at my storage vessel or 

centrifugal compressor 

affected facility?

(d)(12) EDITS (bold language is new): 

§60.5413(d)(12): The owner or operator of a combustion control device model tested under this paragraph section

must submit the information listed in paragraphs (d)(12)(i) through (vi) in the test report required by this section in 

accordance with §60.5420(b)(8).

BASIS:

To correct an error (paragraph versus section) and to clarify the location of the applicable test report requirements 

that apply.

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Section Citation Edits and Basis

§60.5416 What are the 

initial and continuous 

cover and closed vent 

system inspection and 

monitoring 

requirements for my 

storage vessel and 

centrifugal compressor 

affected facility?

(c)(3) EDITS (bolded language is new): 

§60.5416(c)(3): For each bypass device, except as provided for in §60.5411(c)(3)(ii), you must meet the 

requirements of paragraphs (c)(3)(i) or (ii) of this section.

§60.5416(c)(3)(i): Set the flow indicator to sound an alarm at the inlet to the bypass device when the stream is 

being diverted away from the control device or process to the atmosphere. You must maintain records of each 

time the alarm is sounded according to §60.5420(c)(8).

§60.5416(c)(3)(ii): If the bypass device valve installed at the inlet to the bypass device is secured in the nondiverting position using a car-seal or a lock-and-key type configuration, visually inspect the seal or closure 

mechanism at least once every month to verify that the valve is maintained in the non-diverting position and the 

vent stream is not diverted through the bypass device. You must maintain records of the inspections and records 

of each time the key is checked out, if applicable, according to §60.5420(c)(8).

BASIS:

To clarify the applicable recordkeeping requirements.

§60.5420 What are my 

notification, reporting, 

and recordkeeping 

requirements?

(b)(3)(iii) EDITS (bold text is new): 

§60.5420(b)(3)(iii) If required to comply with §60.5380(a)(1), the records specified in paragraphs (c)(6) through 

(14)(11) of this section.

BASIS:

Typographical error.

(b)(4)(i) EDITS (bold text is new): 

§60.5420(b)(4)(i): The cumulative number of hours or of operation or the number of months since initial startup, 

since October 15, 2012, or since the previous reciprocating compressor rod packing replacement, whichever is 

later.

BASIS:

Typographical error/grammatical correction.

(c)(4)(ii) EDITS (bold text is new): 

§60.5420(c)(4)(ii): Records of the demonstration that the use of pneumatic controller affected facilities with a 

natural gas bleed rate greater than 6 standard cubic feet per hour the applicable standard are required and the 

reasons why.

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Section Citation Edits and Basis

BASIS:

Correction to make provision consistent with §60.5390(a).

(c)(5) EDITS: 

§60.5420(c)(5): Except as specified in paragraph (c)(5)(v) of this section, for each storage vessel affected facility, 

you must maintain records identified in paragraphs (c)(5)(i) through (iv) of this section.

§60.5420(c)(5)(i): If required to reduce emissions by complying with §60.5395(d)(1), the records specified in 

§60.5420(c)(6) through (8), §60.5416(c)(6)(ii), and §60.6516(c)(7)(ii)§60.5416 of this subpart.

§60.5420(c)(5)(ii): Records of each VOC emissions determination for each storage vessel affected facility made

under §60.5365(e)§60.5395(b), (c), and (d)(2), as applicable, including identification of the model or calculation 

methodology used to calculate the VOC emission rate.

§60.5420(c)(5)(iii): Records of deviations in cases where the storage vessel affected facility was not operated in 

compliance with the requirements specified in §60.5395, §60.5411, §60.5412, and §60.5413, as applicable.

§60.5420(c)(5)(iv): For storage vessels that are skid-mounted or permanently attached to something that is mobile 

(such as trucks, railcars, barges or ships), records indicating the number of consecutive days that the vessel is 

located at a site in the oil and natural gas production segment, natural gas processing segment or natural gas 

transmission and storage segment. If a storage vessel is removed from a site and, within 30 days, is either returned 

to or replaced by another storage vessel at the site to serve the same or similar function, then the entire period 

since the original storage vessel was first located at the site, including the days when the storage vessel was 

removed, will be added to the count towards the number of consecutive days.

§60.5420(c)(5)(v): You must maintain records of the identification and location of each Group 1 storage vessel 

affected facility. If you have an event, as specified in §60.5395(b)(2), that could reasonably be expected to increase 

VOC emissions from your Group 1 storage vessel, you must maintain records of the VOC emissions rate 

determination. 

BASIS:

Record requirements specificity (cross-referencing) added to add clarity to the rule. “Storage” was added before 

“vessel” to be consistent with other references to “storage vessel” in the rule (i.e., rule refers to “storage vessel” 

versus just “vessel” elsewhere in the rule). Last sentence of §60.5420(c)(5)(v) deleted because §60.5420(c)(5)(ii) 

already requires.

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Section Citation Edits and Basis

(c)(9) EDITS (bold text is new): §60.5420(c)(9): For each closed vent system used to comply with this subpart that must 

operate with no detectable emissions If you are subject to the closed vent system no detectable emissions 

requirements of §60.5416(b) for centrifugal compressors, a record of the monitoring conducted in accordance 

with §60.5416(b).

BASIS:

For clarity and consistency with the rest of §60.5420(c).

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