NSPS OOOO Standards of Performance for Crude Oil and Natural Gas Production, Transmission, and Distribution

Annette MaxwellLiaisonTCEQ Office of Compliance and EnforcementProgram Support Section

New Source Performance Standards, Subpart OOOO 40 CFR Part 60, Sections 60.5360 - 60.5430

Updates finalized September 23, 2013

Rule addresses affected facility VOC and SO2 emissions

The rule includes (but is not limited to) Notification, reporting, and recordkeeping requirements ▪ 40 CFR 60.5420

Additional recordkeeping and reporting requirements▪ Natural Gas Processing Plants 40 CFR 60.5421 & 60.5422▪ Sweetening Units 40 CFR 60.5423

Note: This presentation is brief and focuses on notification and reporting. Additional requirements beyond those shown here may apply!

Reporting & Notification

Notifications: Well Completion / Flowback

Submit online http://www.texasoilandgashelp.org/ http://www.tceq.texas.gov/assets/public/permitting/air/For

ms/20640.pdf Through STEERS

https://www3.tceq.texas.gov/steers/index.cfm By fax – (512) 239-2101 By mail

Air Permits Division MC-163Texas Commission on Environmental QualityPO Box 13087Austin, TX 78711-3087

Well Completion/Flowback Notification

Annual Report

Annual report requirements are outlined in 40 CFR 60.5420(1) – (6)

Due annually beginning January 15, 2014 Previously submitted annual reports must be updated to

comply with September 23, 2013 rule updates, if applicable. Must include

Information for the following: gas wells, centrifugal compressors, reciprocating compressors, pneumatic controllers, and storage vessels

Note on the term “affected facility”: for the purposes of this rule, this includes specific pieces of equipment, not the entire site

Note on sweetening units: annual report requirements found in 40 CFR 60.5423

Annual Reports – Where to Submit

http://www.tceq.texas.gov/about/directory/region

Annual Report General Information

General Information Company name Address of the affected facility Beginning and ending dates of reporting period A certification by the responsible official▪ Truth▪ Accuracy▪ Completeness▪ Include the words: “Based on information and belief formed

after reasonable inquiry, the statements and information in the document are true, accurate, and complete.”

Requested but not required: if an RN (site ID number) already exists, please note it in the report

Annual Report Gas Wells

Gas wells Include records of well completion as

specified in 40 CFR 60.5420(c)(1)(i) through (iv) for reporting period

OR A list of well completions with hydraulic

fracturing and records specified in 40 CFR 60.5420(c)(1)(v) for reporting period

And (for both choices above) Records of deviations pursuant to 40 CFR

60.5420(c)(1)(ii)

Annual Report Centrifugal Compressors

Centrifugal compressors Identification of each centrifugal compressor

using a wet seal system and was constructed, modified, or reconstructed during the reporting period

Records of deviations specified in 40 CFR 60.5420(c)(2)

If 40 CFR 60.4380(a)(1) (regarding turbine excess emissions) applies, records of closed vent system and cover inspections specified in 40 CFR 60.5420(c)(6)

Annual Report Reciprocating Compressors

Reciprocating compressors▪ Cumulative number of hours of operation

Or ▪ The number of months since:▪ Initial startup,▪ October 15, 2012,

Or▪ Most recent rod packing replacement(whichever is later)

Records of deviations specified in 40 CFR 60.5420(c)(3)(iii)

Annual Report Pneumatic Controllers

Pneumatic Controllers Identification of each pneumatic controller

constructed, modified, or reconstructed during the reporting period including information specified in 60.5390(b)(2) or (c)(2).

If applicable, document that use of pneumatic controller with bleed rate >6 scf/hr is required and why

Records of deviations specified in 40 CFR 60.5420(c)(4)(v) (operated not in compliance with 40 CFR 60.5390)

Annual Report Storage Vessels

Include notification for Group 1 (8/23/11-4/12/13) Identity and location of storage vessel

(lat/long) Include notification for storage

vessels (all Groups) that are removed from or returned to service

Documentation of VOC emission rate [60.5365(e)]

Annual ReportStorage Vessels, continued

Records of deviations as specified in 60.5420(c)(5)(iii)

A statement that requirements of 40 CFR 60.5410(h)(2) [VOC emissions, 60.5395(d)] and 60.5410(h)(3) [control requirements, 60.5395(e)] have been met

Annual ReportSweetening Units 40 CFR 60.5423

Recordkeeping and Reporting requirements for sweetening units at natural gas processing plants Excess emissions as specified in

60.5423(b)▪ Looks at sulfur emission reduction efficiency

Performance Tests

Submit performance test records directly to EPA

1. Generate file using electronic reporting tool (ERT) http://www.epa.gov/ttn/chief/ert/index.html

2. Submit file to EPA through the Compliance and Emissions Data Reporting Interface accessed through the Central Data Exchange located at www.epa.gov/cdx

or by mail to WebFIRE Administrator, MD C404-02, 4930 Old Page Rd., Durham, NC 27703

TCEQ will not be a recipient for performance test documentation at this time

Natural Gas Processing Plants Semiannual Reports Required 40 CFR

60.5422 Due 6 months after startup All semiannual reports must include

information required in 60.487a(a), (b), (c)(2)(i) – (iv), and (c)(2)(vii) – (viii)

This includes information regarding ▪ Valves, pumps, compressors, and connectors▪ Monthly leak numbers for▪ Leaking valve, pump, and connector detection▪ Leaking valve, pump, and connectors that were not repaired

as required

Natural Gas Processing Plants, continued (40 CFR 60.5422)

Initial semiannual report▪ Number of pressure relief devices (see

60.5401(b)) that have detectable emissions (see 40 CFR 60.482-4a(a)) unless they comply with 40 CFR 60.487a(c)(2)(i) – (vi)▪ Additional requirements outlined in Subpart

VVa (40 CFR 60.487a (a), (b), and (c)(2)(i) – (vi))

Subsequent annual reports must include pressure relief device leak detection and repair required in 40 CFR 60.5401(b)(2) and (3)

Things to Remember

Recordkeeping requirements are generally five years (including all records required under 60.5420(c)) Some are less – when in doubt, double

check or keep for five years Location requirements usually

specify lat/longs in decimal degrees to five decimal places using NAD83

To conclude

This review is not all inclusive Details, alternatives, and exclusions have

been omitted for brevity Additional recordkeeping requirements

apply Some of those records are referenced in

the reporting requirements and must be included in the annual reports

Take the time to read the applicable parts carefully.

My Contact Information

My request to you: Email me questions that we can use to

help us draft guidance for this rule.

Annette Maxwellannette.maxwell@tceq.texas.gov