Annette Maxwell Liaison TCEQ Office of Compliance and Enforcement Program Support Section
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Transcript of Annette Maxwell Liaison TCEQ Office of Compliance and Enforcement Program Support Section
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
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 [email protected]