Discussion regarding the 2011 proposed NSPS Subpart OOOOa methane rules, and how they apply to the oil and natural gas sectors.

1. EPA Proposed Methane Rules
November 11, 2015
Oil and Natural Gas Sector:
Emission Standards for New and Modified Sources
(aka Quad O v2.0 or Quad Oa)

2. CLIMATE ACTION PLAN
STRATEGY TO REDUCE METHANE EMISSIONS (MARCH 2014)
 Landfills
 Coal Mines
 Agriculture
 Oil and Gas
 EPA: New Standards/Regulations
 Natural Gas STAR voluntary efforts
 BLM: Venting and Flaring Standards
 On Federal Lands and Indian Lands

3. EPA Proposal:
40 CFR 60, Subpart
OOOO
80 FR 56593
September 17, 2015
Extension to
December 4th
Note: The data and information in the presentation are general in
nature.

4. The Proposal
Types of Requirements:
 FIP for Indian Country Minor NSR Program
 Nation-wide permitting requirements and control measures.
 Oil Wells & Completions
 Green Completions - gas capture, control, beneficial use:
95% emissions reduction
 Control Techniques Guidelines
 To reduce VOCs in ozone nonattainment areas and states in
ozone transport regions

5. The Proposal
Types of Requirements Continued:
 Newly Regulated Sources
 Transmission compressor stations & pneumatic
pumps/controllers
 Leak Detection and Repair of Fugitives (LDAR)
 AVO, Method 21, Optical Gas Imaging (FLIR Camera)
 Source Determination Rule
 Aggregation! (1/4 mile, daisy-chaining, definition of
“adjacent”)

6. FIP for Indian Country Minor NSR
Program
 Modeled after FBIR FIP lessons learned
 True Minor Registrations (deadline 10/3/16)
 General permits or permits by rule (PBR)
 Replaces site-specific NSR “preconstruction” permitting
 Registration form due 30 days prior to construction (being
challenged)
 True Minor Sources Apply
 Greater than 10 tpy, but less than 250 tpy
 No synthetic limits to reduce PTE (being challenged)

7. Oil Wells and Completions
 Completions of Hydraulically Fractured Wells
 Mirrors current green completions of HF gas wells
 Comment required:
 Request exemptions for gas capture if gas sales infrastructure is
not available.
 Leak Detection and Repair of Fugitives (LDAR)
 Also will apply to gas wells
 Pneumatics
 Also will apply to gas wells

8. Control Technique Guidelines
CTGs applicable only to sources in ozone non-
attaiment areas and transport regions
 Not a concern in Montana (at the moment)
 Guideline document over 300 pages….
 Additional Stringent Requirements
 Reasonably Available Control Measures/Technologies
 Pneumatics, controls, LDAR, monitoring, recordkeeping,
and reporting

9. Newly Regulated Sources
 Transmission compressor stations
 LDAR
 Centrifugal & reciprocating engine emissions reductions
 Wet seal systems require 95% VOC reduction (dry seals change-out)
 Replacement schedule for rod packing
 Flaring or routing gas to compressor intake
 Pneumatic pumps/controllers
 Controllers must be tagged throughout a basin
 95% control for pumps
 Stringent recordkeeping and reporting requirements

10. Leak Detection and Repair of
Fugitives (LDAR)
 Exemption threshold of 15 boed, 1st 30 days
 Stringent recordkeeping and reporting
 Types of detection:
 Optical Gas Imagining (such as FLIR camera)
 Method 21 (“sniffer” instrument, calibrated to 500 ppm)
 Schedules for inspections and repairs
 Initial inspection within 30 days, then semiannually, could be
quarterly (based on percentage of leaking components)
 Repair or replace leaking component within 15 days

11. Source Determination Rule
Aggregation based on defining the term
“adjacent” - two definitions proposed:
Option 1: Define based on proximity
Equipment/activities located on same site or site within a “short”
distance (¼ mile) of each other (EPA’s preferred option)
Note: Previously struck down this interpretation in 6th Circuit Court Case: Summit Petroleum Corp. v. EPA (8/7/12)
Option 2: Define based on proximity or function
Equipment/activities located near each other or if they are related
by function “such as being connected by a pipeline”

12. Other “Hot Button” Issues
 Defining storage tanks as being operated with
“no visible emissions….”
 Thief hatches are designed as a pressure relief valve
 Operated with high back pressure = explosion hazard
 Modifications
 Could potentially drag in majority of older sites
 Individual sites vs. CTBs vs. RTBs reduces environmental
footprint…..
 Replacing equipment (such as engines, VRU install, etc.)
is considered a modification

13. Questions??
Bret Gallo, Project Engineer/Thermographer