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EPA NSPS Updates for Oil & Gas - Session 1

Event Description and Agenda:

On Dec. 19th 2014, the U.S. Environmental Protection Agency finalized updates and clarifications to its 2012 New Source Performance Standards (NSPS) for the oil and natural gas industry sector (called Subpart OOOO or "Quad O" requirements). The final federal rules mandate the use of emission controls as well as work practices through two different air regulatory programs- New Source Performance Standards (NSPS) and National Emissions Standards for Hazardous Air Pollutants (NESHAP).

Several new updates are included in these rules. For example, one update provides additional details on well completion operations known as "flowback" with specific requirements for handling gas and liquids during each state, including clarifying when "green completion" equipment must be used. Beginning January 1, 2015, hydraulically fractured wells must use reduced emission completions (REC) to control flowback gas- rather than flaring completion devices. In addition to covering air emissions resulting from hydraulic fracturing at gas wells, these rules also regulate a variety of other new, modified, or reconstructed sources, including downstream compressors, pneumatic controllers, storage tanks, and fugitive leaks. For example, all Group 1 storage tanks must be fully compliant with Quad O by April 15, 2015 and some additional clarifications on these storage tank requirements were included in these latest updates.

This online webinar is designed to help busy oil and gas industry professionals, suppliers, and regulators stay abreast and informed of these updated requirements and develop a strategy for managing the impact of these regulations on their operations. The New Source Performance Standards under Subpart OOOO apply to affected facilities that commence construction, reconstruction, and modification after August 23, 2011. However, the compliance date for affected facilities depends on the type of emission source. The final NSPS and NESHAPs requirements and time lines are highlighted and possible compliance strategies are discussed.


  • History of EPA O&G rules
  • How does the EPA define the oil & gas sector?
  • Key terms and operational technology
  • Overall rule structure and timelines
Who's Affected?
  • NSPS Subpart OOOO: Affected facilities include the following:
    • Hydraulically fractured natural gas wells
    • Compressors
    • Continuous bleed pneumatic controllers
    • Storage vessels
    • Fugitive equipment components at onshore natural gas processing plants
    • Sweetening units at onshore natural gas processing plants
  • Subpart HH & HHH NESHAPs:
    • Rule amendments affect equipment not previously subject to NESHAP requirements, such as small dehydrators
    • A number of other updates to NESHAPs HH and HHH are related to compliance demonstration requirements
Key Implementation Issues
  • NSPS
    • Phased timeline for implementation of control measures for pneumatic controllers, storage vessels, and well completions
    • Exemptions for equipment meeting design or control standards (e.g., low pressure gas wells, dry seal centrifugal compressors, low bleed controllers)
    • Thresholds for volatile organic compound (VOC) emissions triggering control requirements on storage tanks
    • Exemptions: For example, certain equipment in transmission gas service is not subject to the final rule
    • Recordkeeping, monitoring, and reporting
      • Annual reports
      • Information about duration of well completion activities
      • Manufacturer's specifications for pneumatic controllers, and
      • Emission calculations for storage vessels
    • When advance notice of well completion is not required and when email notification is sufficient
    • Startup, shutdown, malfunction (SSM) requirements and affirmative defenses to civil penalties for exceedances of emission limits caused by malfunctions
    • Emission limits for small dehydrators in each amended NESHAP Subpart o EPA's benzene option
    • Control requirements for storage vessels without the potential for flash emissions
    • Alternative compliance option for non-flare combustion devices
    • Parametric monitoring provisions, including the site-specific monitoring plan
    • Addition of periodic performance testing where applicable
    • Design analysis for all control devices other than condensers
    • Minimum residence time for an enclosed combustion device
    • Recordkeeping and reporting requirements to document carbon replacement intervals
    • Leak detection limits for valves
    • SS&M Vacatur- effects on NESHAPs and compliance
Strategies and Future Directions
  • Reviewing and analyzing the final published rules & anticipating updates
  • Performing applicability inventory all existing facilities, equipment, and operational characteristics and impacts on facility planning
  • Developing avoidance strategies as applicable
  • Training staff on operational, monitoring, recordkeeping, and reporting requirements and anticipating compliance pitfalls
  • Budgeting for increased costs associated with installation of control equipment, more stringent maintenance and replacement schedules, and allocating resources to handle increased monitoring, recordkeeping, and reporting requirements
  • Acquiring and installing control equipment and conducting performance testing as applicable


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