Quad O EPA Compliance

NSPS OOOOa (Quad O, Quad OOOO, Quad 0) EPA OOOO Summary

NSPS OOOa – On May 12, 2016, the U.S. Environmental Protection Agency (EPA) issued the final New Source Performance Standards (NSPS) Subpart OOOOa also known as Quad O, Quad 0, and Quad 0000 in order to reduce methane and volatile organic compounds (VOCs) from new, reconstructed and modified oil and gas sources. The final NSPS OOOOa rule builds on the 2012 NSPS OOOO requirements by setting emission limits for methane and adding regulations for previously unaffected equipment. We understand how important Quad O is to business owners, which is why we offer a variety of products like our Dual Pressure Flare to our loyal customers.

Some major highlights of the new Quad O(NSPS OOOO) rules include the following requirements:

• Leak detection and repair (LDAR) requirements for well sites and compressor stations.
• Control requirements and emission limits for pneumatic pumps at well sites and natural gas processing plants.
• Reduced emission completion requirements at oil well sites with a gas-to-oil ratio greater than or equal to 300 standard cubic feet of gas per barrel.
• Centrifugal and reciprocating compressor requirements for natural gas transmission Compressor stations.
• Emission limits and control requirements for pneumatic controllers at natural gas transmission compressor stations.
• Professional engineer certification requirements for determining technical infeasibility for pneumatic pumps to be controlled and for verification of proper closed vent system design.

The following equipment and activities potentially require control using a flare or enclosed combustors under EPA Quad Oa, Quad O, also known as Quad 0, Quad 0000, and Quad OOOOa:

• Flowback emissions following hydraulic fracturing – These emissions must be routed to a “completion combustion device” for delineation, wildcat, and low-pressure wells. All other hydraulically fractured wells can only use combustion controls if a reduced emissions completion is infeasible.
• Centrifugal compressors with wet seals – The emissions from these seals must be captured and routed to a control device or process that achieves at least 95% reduction.
• Storage Vessels: These have the same general requirements as centrifugal compressors. Note that only tanks with a potential-to-emit greater than 6 tons per year are subject to the rule.
• Pneumatic Pumps: These have the same general requirements as centrifugal compressors. Note that emissions must only be captured and controlled if there is already an existing control or process at the facility.

EPA has also finalized proposed changes to NSPS OOOO/OOOOa also known as Quad O, Quad 0000 and Quad 0 that have resulted in significant changes to control device requirements:

• Initial (and every 60 months under NSPS OOOOa) performance testing is now required for any non-manufacturer tested enclosed combustor.
• Updated limit for total organic carbon (TOC) concentration in the control device exhaust gas to 275 ppmvw, as propane, at 3% oxygen.
• Monthly 15-minute EPA Method 22 tests are now required for both manufacturer tested and non-manufacturer tested enclosed combustors.
• Clarification that flares must comply with the 40 CFR 60.18 design and operation requirements.
• P.E. certification that routing pneumatic pump emissions to an existing control device is technically infeasible. The infeasibility assessment could potentially be based on safety.

The Environmental Protection Agency has finally completed its updates regarding onshore oil and natural gas production ranging from good completion to transmission. Our goal is to help you better understand these frequent updates and to better explain them to avoid any confusion surrounding the topic.

Quad-O(NSPS OOOO), is gaining popularity among onshore production. In January 2009 the EPA was sued for failing to review existing regulations, forcing the EPA to update old rules and regulations. Both the District of Columbia and The U.S. District Court agreed that this new type of drilling evokes an entirely new source of “volatile organic compounds”.

The start of the NSPS OOOO labeled what equipment and standards are influenced and detailed the specifically required emission reductions. These new regulations are required for all onshore oil and gas facilities reconstructed, modified, or constructed after Aug. 23, 2011. Quad-0 specifically states that each location that has been constructed or modified on August 23, 2011, must meet the published guidelines, and to allow producers to implement adjustments accordingly.