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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 p roposed Oil and Natural Gas Sector : Reconsideration of Cert ain Provisions of New Source Performance Standards was published in the Federal Register on April 12, 2013 (7 8 FR 22126 ).
E ditorial (e.g., typographical

, grammatical errors , and incorrect references) and simple
clarifications made to the rule since propos al (that are not addressed in the final rule preamble or
the Oil and Natural Gas Sector: Reconsideration of Certain Provisions of N e w 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 a re presented in Table 1 of this
memorandum.

501 Eastowne Drive, Suite 250  Chapel Hill, North Carolina 27514 Telephone: (919) 484

- 0222  Fax: (919) 484

- 0122Table 1. Editori al and/or Simple Clarification Revisions Made to the Proposed Rule 

### Section Cit ation Edits and Basis

§6 0

. 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, includi ng 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 reco rds 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 c ontrollers (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). [Res erved]

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 grea ter within 60 days after startup or by April 15, 2014, whichever is later in accordance with §60.5395(d). (3) If you use a control device to reduce emissions, or if you route emissions to a process flowline , you must demonstrate initial compliance by meeting the requirements in paragraphs (h)(3)(i) and (ii) of this

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### Section Cit ation 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 co mpliance 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, whichev er 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 s pecified 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 vess el 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 Cit ation 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

compre ssor 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
device designed 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 Cit ation 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 non

diverting position using a car

- seal or a lock

- and

- key type configuration, visually inspe ct 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 Cit ation 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
meth odology 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 si te 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 da ys. §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 you r 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.

6

### Section Cit ation 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 centrifuga l 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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