IPAA NSPS Subpart OOOO

Storage Tank Provision

TutorialRon Truelove, Director, Oil and

Gas Sector Services

Trinity Consultants, Inc.

Agenda

Introduction and Opening Remarks (~5

min)

Section 1: Overview of NSPS (~10 min)

Section 2: NSPS Subpart OOOO Final 2012 and 2013 Storage Tank Rules (~20

min)

Section 3: Storage Tank Emission

Calculations (~15 min)

Section 4: What Should I Be Doing Now

(~5 min)

Introduction &

Opening

Remarks

Introduction

Ron Truelove Director, Oil & Gas Sector Services, Trinity Consultants, Inc.

Chemical Engineer

10 years with Conoco working downstream

environmental issues (mainly air quality)

6 years as an air/environmental consultant

13 years with Devon Energy working

upstream and midstream environmental,

health, and safety issues

Trinity since December 31, 2012

Trinity U.S. Office Locations

What not to expect from the

tutorial Absolute answers to everything!

Disclaimer

This tutorial and instructor are not

providing legal advice;

The views expressed here do not represent

the views of Trinity Consultants clients (and may not represent the views of Trinity

Consultants).

Section 1

Overview of NSPS

NSPS vs. NESHAP

New Source Performance Standards

National Emission Standards for Hazardous Air Pollutants

Criteria Pollutants (e.g., VOC, NOx, CO, PM, SO2)

Hazardous Air Pollutants (e.g., Formaldehyde)

Affected facilities at all types of sites

Affected facilities at Major and/or Area Sources

New, Modified, or Reconstructed

New, Reconstructed, Existing

Proposal date Proposal date

Note: Neither regulates GHG emissions (e.g., CO2, CH4, N2O).

Construction/Affected Facility

Definitions Construction - fabrication, erection, or

installation of an affected facility Affected facility - with reference to a

stationary source, any apparatus to which a standard is applicable e.g., an engine vs a compressor e.g., a storage tank vs gas well completion

Relocating an affected facility is notconstruction, modification, or reconstruction under NSPS and does not trigger the rule Permitting may be required at the new site

Modification Definition

Any physical or operational change to an

existing facility (e.g., the engine) which

results in an increase in the emission rate

of any pollutant to which a standard

applies (40 CFR 60.14)

Modification Details

increases the amount of any air pollutant

HOURLY emissions rate change (40 CFR 60.14(b))

Interpreted as increase in short-term potential emissions

Increasing hours of operation alone without an increase in hourly emissions rate does not constitute a modification (40 CFR 60.14(e)(3))

Modification Details

to which a standard applies

An increase in emissions of a pollutant

not regulated by the NSPS Subpart is not

a modification

Applicability is pollutant-specific: The

only applicable sections of an NSPS

Subpart are those which regulate the

pollutant whose emissions increased due

to the modification. (40 CFR 60.14(a))

NSPS Modification Exemptions

Routine maintenance, repair and replacement

An increase in production rate without a capital

expenditure

Examples tanks, engines, etc.

An increase in hours of operation

Use of an alternative fuel or raw material if

source could accommodate it prior to the

standard

Addition of air pollution control device

Change in ownership

Capital Expenditure per

Subpart A Capital expenditure means an expenditure for a

physical or operational change to an existing facility

which exceeds the product of the applicable annual asset guideline repair allowance percentage specified in the latest edition of Internal Revenue Service (IRS)

Publication 534 and the existing facility's basis, as

defined by section 1012 of the Internal Revenue Code.

However, the total expenditure for a physical or

operational change to an existing facility must not be

reduced by any excluded additions as defined in IRS Publication 534, as would be done for tax purposes.

Annual Asset Guideline Repair

Allowance Percentage

Type of Equipment Percentage

Oil and gas E&P and gathering 4.5

Natural gas pipeline transportation 3.0

Natural gas production plants 4.5

Note: This is a percentage of the original cost

of the affected facility.

Reconstruction Definition

The replacement of components of an existing facility

to such an extent that the fixed capital cost of the new components exceeds 50% of the fixed

capital cost that would be required to construct a

comparable entirely new facility,

Fixed capital costs = capital needed to provide all the depreciable components

and it is technologically and economically feasible to meet applicable standards

Effects on emissions are not considered

Section 2

NSPS Subpart OOOO:

Final 2012 and 2013 Storage

Tank Rules

Subpart OOOO Affected Facilities

Each natural gas well that is hydraulically fractured

Each centrifugal compressor using wet seals

Each reciprocating compressor

Each continuous bleed natural-gas driven pneumatic

controller

Each storage vessel with PTE > or = 6 T/yr

VOC

Group of equipment (pump, pressure relief device,

open-ended valve or line, valve, and flange or other

connector in VOC or wet gas service), within a process

unit located at onshore natural gas processing plants

Sweetening units located at onshore natural gas

processing plants

Subpart OOOO ApplicabilityNSPS OOOO AffectedFacility

Production (Well Site) Gathering

Gas Processing Transmission

Gas Well X

Centrifugal Compressors

X X

ReciprocatingCompressors

X X

Pneumatic Controller

X X X

Storage Vessels

X X X X

Equipment Leaks

X

Sweetening Units

X

Final Rule Compliance Schedule

NSPS OOOO Affected Facility Standard Compliance Date

Hydraulically fractured wildcat and delineation wells Completion combustion October 15, 2012

Hydraulically fractured low pressure non-wildcat and non-delineation wells

Completion combustion October 15, 2012

Other hydraulically fractured wells Completion combustion Before 1/1/2015

Other hydraulically fractured wellsREC and completion

combustionAfter 1/1/2015

Centrifugal compressors with wet seals 95% reduction October 15, 2012

Reciprocating compressors Change rod packing October 15, 2012

Pneumatic controllers at NG processing plants Zero bleed rate October 15, 2012

Pneumatic controllers between wellhead and NGprocessing plants

6 scfh bleed rate October 15, 2013

Group 2 and 1 Storage Vessels 95% reduction April 15, 2014/2015

Equipment Leaks LDAR program October 15, 2012

Sweetening Units Reduce SO2 as calculated October 15, 2012

NSPS Subpart OOOO and Tanks

Storage tanks are separated into Group 1

and Group 2 tanks based on dates

Group 1 Constructed between 8/23/11 and 4/12/2013

Group 2 Constructed after 4/12/2013

Is My Storage Vessel Subject to OOOO?

NSPS OOOO applies to all storage vessels >6

T/yr VOC PTE that meet the following:

Were constructed, modified, or reconstructed

after August 23, 2011;

Are located in the:

Oil and natural gas production segment

Oil and natural gas gathering segment

Natural gas processing segment

Natural gas transmission and storage segment

April 12, 2013 drives compliance timing

Storage Vessel Definition

Storage vessel means a tank or other vessel

that contains an accumulation of crude oil,

condensate, intermediate hydrocarbon liquids,

or produced water, and that is constructed

primarily of nonearthen materials (such as

wood, concrete, steel, fiberglass, or plastic)

which provide structural support.

Definition Specifics

Crude oil

Condensate

Intermediate hydrocarbon liquids

Produced water

Fuel and chemical injection tanks

excluded

Storage Vessel Definition

For the purposes of this subpart, the following are NOT

considered storage vessels:

Vessels that are skid-mounted or permanently attached to

something that is mobile (such as trucks, railcars, barges or

ships), and are intended to be located at a site for less than 180

consecutive days. If you do not keep or are not able to produce

records, as required by 60.5420(c)(5)(iv), showing that the

vessel has been located at a site for less than 180 consecutive

days, the vessel described herein is considered to be a storage

vessel since the original vessel was first located at the site.

Process vessels such as surge control vessels, bottoms receivers or

knockout vessels.

Pressure vessels designed to operate in excess of 204.9

kilopascals (29.7 psi) and without emissions to the atmosphere.

Standards for Storage Vessels

Tanks with PTE >6 T/yr:

Reduce VOC emissions by 95.0 percent through use of a control device or floating

roof

If using a control device, equip with

specified cover and connect through a

closed vent system to a control device

Initial performance test required

Install and operate continuous parameter

monitoring system (CPMS)

Group 1 Storage Vessels

Controls required by April 15, 2015

PTE and applicability must be determined

by October 15, 2013 and reported in

January 2014 first annual report

Do not count vapors collected and re-

routed to a process toward PTE

Group 2 Storage Vessels

Determine emissions by April 15, 2014 or

within 30 days of startup, whichever is

later

Reduce VOC emissions by at least 95% by

April 15, 2014 or within 60 days of

startup, whichever is later

Do not count vapors collected and re-

routed to a process toward PTE

Storage Vessel Exit Ramp

There is now an exit ramp for storage vessels to account for declining production

Once uncontrolled emissions drop

Typical VRU

Tank VRU

VRU Capture Line

Tank Battery and Vent Line

A Closer Look

Storage Vessel Controls

Must reduce emissions by 95% (capture +

control)

Think about capture efficiency combined

with flare control efficiency

95% capture and 98% control = 93% overall

Must be covered, and have closed vent system

Must meet prescriptive performance testing

requirements

Must meet prescriptive continuous monitoring

requirements

Section 3

Storage Tank Emission

Calculations

Storage Tank Emissions

Flash

Working

Breathing

Calculating Tank Emissions Commonly Used Methods

Direct measurement

Pressurized sample flashed in the lab

(only flash)

Gas to oil ratio (only flash)

EPA TANKS 4.09d (no flash)

Process simulator such as ProMax

E&P TANKS

Vasquez-Beggs Equation (only flash)

EPA TANKS 4.09d

Freeavailable for download off of EPAs website:

http://www.epa.gov/ttnchie1/software/tanks/

Calculates working/breathing based on

AP-42 equations

Does not calculate flash

Output is a *.txt file not easily integrated with other software programs

Process Simulators - ProMax

ExpensiveFor more information about ProMax, please see the Bryan Research

and Engineering website at:

http://www.bre.com/

Calculates flash using site specific data

Also incorporates AP-42 equations for

working/breathing

Output is more modern and can be integrated more easily

E&P TANKS

Relatively low priced $548

API Publication 4697

http://global.ihs.com/search_res.cfm?MID=W0

97&input_doc_number=API%204697

Calculates working, breathing, and flash

Can utilize default libraries (may introduce

inaccuracies) or site-specific data

Output is a *.txt file not easily integrated with other software programs

Sales oil: 15-68 API gravity

Vasquez-Beggs Free on several state websites:

http://deq.state.wy.us/aqd/miscforms.asp

http://www.nmenv.state.nm.us/aqb/permit/aqb_pol.

html

www.deq.state.ok.us/AQDnew/resources/Calculations

11.xls

Calculates a GOR and flash only; must combine

with EPA Tanks 4.09d for working and breathing

There are ranges outside of which this method is

not appropriate; most appropriate for black oil

Some states will not accept this method, while

some states prefer this method

Vasquez-Beggs Limitations:

Tank Liquid Relative Density: 16-58 API

Separator Pressure: 50-5,250 psia

Separator Temperature: 70-295 F

Separator Gas SG: 0.56-1.18

Solution Gas Oil Ratio (GOR): 20-2,070

scf/bbl

Methodology Comparison

Permission provided by BRE.

Trinity Method Comparison

0

100

200

300

400

500

600

0.00 5.00 10.00 15.00 20.00 25.00 30.00 35.00

An

nu

al E

mis

sio

n R

ate

(t

py)

Daily Throughput (bbl/day)

ProMax (W & B & Flash) E&P Tanks v2

GRI-HAPCalc TANKS 4.09d (Condensate) + Promax (Flash Only)

TANKS 4.09d (Condensate) + ECR

Calculation Accuracy

Size control equipment based on the

most accurate method

Understand compliance risk

Data for Tank Calculations

Maximum tank throughput (maximum day

of 30-day period)

For tanks piped in parallel operations, must

assume that total tank battery flow can go

through each tank unless there is a federally

enforceable limitation

API gravity of the oil

TVP/RVP of the oil

Pressurized sample downstream of the last

separator (separator pressure and

temperature)

Data for Tank Emission

Calculations Tank parameters

(height & diameter)

Tank operating temperature

Thief hatch & relief valve pressure/ vacuum settings

Tank vapor molecular weight; VOC content

Tank color & condition

Maximum liquid

volume in the tank

Vapor density/

specific gravity

Liquid density/

specific gravity

Cone or dome roof &

height

Average liquid height

Section 4

What Should I Be Doing Now?

Preparing for NSPS Subpart

OOOO Tank Compliance Develop an inventory of storage tanks

installed, modified, or reconstructed

after August 23, 2011.

Preparing for NSPS Subpart

OOOO Tank Compliance Perform emission calculations for

applicable storage tanks

Accuracy

Parameters/inputs to be collected

Compliance margin (if any)

Evaluate control measures if PTE >6 T/yr

Group 1 storage tanks in first annual report

Install Group 2 storage tank controls by April

15, 2014 and Group 1 storage tank controls

by April 15, 2015

Preparing for NSPS Subpart

OOOO Tank Compliance Prior to calculation determination date

(October 15, 2013 for Group 1 and April

15, 2014 for Group 2), consider

Permitting out of NSPS Subpart OOOO for storage tanks by limiting PTE to

Upcoming NSPS Subpart OOOO

Deadlines October 15, 2013: Group 1 tanks PTE

January 13, 2014: First annual report

Include Group 1 storage tanks

April 15, 2014: PTE and compliance for

Group 2 storage tanks

April 15, 2015: Compliance for Group 1

storage tanks

Questions?

Ron Truelove405-848-3724

rtruelove@trinityconsultants.com