Quad-O Epa Compliance

Quad-O Summary

Quad-O, known as NSPS 40 C.F.R. Part 60, Subpart OOOO, has been a dynamic force in environmental regulations. Since its introduction by the U.S. Environmental Protection Agency (EPA) on May 12, 2016, it continually evolves to combat methane and Volatile Organic Compounds (VOC) emissions from oil and gas sources. This rule extends and enhances the 2012 NSPS OOOO requirements, now encompassing previously untouched equipment and establishing emission limits for methane. Recognizing the significance of Quad-O for business owners, we provide an array of products, including our Dual Pressure Flare, to meet the evolving demands of compliance and environmental responsibility.

Some major highlights of the 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.
  • You must install and operate a continuous burning pilot flame. §60.5412(b)(3)(iv)
  • Continuous monitoring requirements for flares, such as continuous monitoring for pilot light flames, to ensure compliance with the requirements for good flare performance at 40 C.F.R. § 60.18.

Equipment & Activities

Control Device Requirements

Onshore Oil & Natural Gas

Oil & Gas Company Emissions

Equipment & Activities

EPA requirements & updates

Equipment & Activity Quad-O Compliance

The listed equipment and activities potentially require control using a flare or enclosed combustors under EPA Quad-Oa, Quad-O, also known as Quad00, Quad-0000, and Quad-OOOOa:

EPA updates for equipment & activities:

  • 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.

Control Devices

EPA requirements & updates

Control Device Quad-O Compliance

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:

EPA updates that affect Control Devices:

  • 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.

On-shore Oil & Natural Gas

EPA requirements & updates

On-shore Oil and Gas Compliance

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.

EPA Updates affecting Onshore Oil & Gas:

  • 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.

Emissions Compliance

In the USA, we flare more gases than any other nation. In order to operate in the USA, oil and gas drilling companies must now meet Quad-O standards. It is the companies’ responsibility to know and comply with these regulations. Reaching above emission limits can be a serious issue. This is because failure to comply with the regulations can result in substantial penalties and EPA may revoke or suspend your certificates that are needed to operate legally. If you are having trouble with compliance, Vaprox can help you meet and exceed these standards.