NSPS OOOOa Overview Photo from http://www.strainland.com/

NSPS Subpart OOOOa Overview Proposed 9/18/2015 Signed 5/12/2016 Not Yet in Federal Register Adds Greenhouse Gas Reductions to Sources in NSPS OOOO Adds Requirements For: Oil Wells Pneumatic Pumps at Production Sites and Gas Plants Fugitive Sources at Production Sites and Compressor Stations Compliance period starts 60 days after it is signed into Federal Register First compliance period ends 1 year after compliance period starts.

NSPS OOOOa Summary No Substantive Changes to Sources from NSPS OOOO: Centrifugal Compressors Reciprocating Compressors Pneumatic Controllers Storage Vessels Natural Gas Processing Plants Sweetening Units at Natural Gas Processing Plants

NSPS OOOOa Summary Changes from NSPS OOOO There are some additional monitoring and certification requirements for closed vent systems for storage vessels and centrifugal compressors Affects equipment subject to NSPS OOOO control requirements and VRUs used to exempt storage vessels from NSPS OOOO Flares used to comply subject to design and monitoring requirements of NSPS Subpart A

Pneumatic Pumps Any single natural gas-driven diaphragm pump manufactured, reconstructed or modified after 9/18/2015. Only applies for gas plants or well sites. Pumps that operate less than 90 days at well sites are exempted. Must maintain records of operation. If the pump operates at all during one day, then that day counts towards the calendar day threshold. Photo from http://www.slideshare.net/Trihydro/epas-nsps-ooooaquad-oa-rule

Pneumatic Pumps cont. Pumps at gas plants must have a natural gas bleed rate of zero within 180 days of FR date. Pumps at well sites required to have natural gas emissions reduced by 95% Not required to install a control device just for the pumps if at an existing site, but must certify that there is no control device available and submit annual report. If a control device is later installed, must control pump within 30 days of startup of the control device or within 30 days of ability to route to a process. If the control device wouldn't be able to achieve 95% reduction, must still route to control and certify that 95% is not achievable. Certification involves sign-off by RO and professional engineer

Production Site Fugitives Only applies to well sites that have emission sources - if it is just composed of wellheads, then it is not subject. Applies to new or modified well sites as of 9/18/2015. Modified if a new well is drilled at an existing well site. Modified if a well at an existing well site is hydraulically fractured or re-fractured. Can use OGI camera or Method 21 Must have emissions monitoring plan Photo from DataWing Aerial Analytics

Production Site Fugitives cont. Must conduct initial monitoring within 60 days of startup or 1 year of date of publication, whichever is later Conduct periodic monitoring semiannually. Repair any leaks within 30 days of finding the leak. Leaks that need to be repaired during a shutdown must be repaired during the next shutdown or within 2 years, whichever is earlier. Re-monitor leaking components within 30 days of being repaired or replaced. Submit an annual report summarizing results.

Compressor Station Fugitives Applies to new or modified compressor stations. Modified if a compressor is added. Modified if a compressor is replaced with a compressor of greater total horsepower. Can use OGI camera or Method 21 Must have emissions monitoring plan Must conduct initial monitoring within 60 days of startup or 1 year of date of publication, whichever is later Conduct periodic monitoring quarterly. Repair any leaks within 30 days of finding the leak. Leaks that need to be repaired during a shutdown must be repaired during the next shutdown or within 2 years, whichever is earlier. Re-monitor leaking components within 30 days of being repaired or replaced. Submit an annual report summarizing results.

Fugitive Emissions Monitoring Plan Composed of Three General Parts Area-Wide Monitoring Plan frequency of monitoring, records to be maintained and how long they will be maintained, information to be collected during monitoring, etc… How Monitoring Will Be Conducted equipment to be used, qualifications of person(s) doing the monitoring, etc… Site-Specific Monitoring Information Site lines for OGI, how impediments to site lines will be addressed, etc…