Click here for he FINAL rule from EPA on the NSPS subpart OOOO.

Also available is the DRAFT GCP-6 document (expect a revised document to be released soon)

Handouts from the NMED open house on the GCP-6 issue held on Sept 23rd. Note the very short deadline under subpart OOOO for determining emissions for Group 1 sources.

Overview: Please note, this is based on my read of the new regulation.

1. This final rule affects all oil and gas producers under NAICS code 211111.

2. A facility under this rule is a single storage vessel located in the oil and gas production segment… that has the potential for VOC emissions equal to or greater than 6 tons per year (TPY) as determined by October 15, 2013. This rule only applies to vessels containing crude oil, condensate, intermediate hydrocarbon liquids or produced water.

3. The potential for VOC emissions must be calculated using a generally accepted model based on the maximum average daily throughput determined for a 30 day period of production prior to the applicable emissions determination deadline (October 15, 2013 for Group 1 wells – see below)

4. Note instead of modeling and implementing the 95% emissions reductions processes, an operator may comply with this provision if he can substantiate an uncontrolled actual VOC emission rate of less than 4 tpy based on records of 12 months immediately preceding the demonstration date. If the monthly testing requirement shows a rate of 4 tpy or more, the operator would have 30 days to meet the 95% control requirement unless the increase was associated with fracturing or refracturing of a well feeding the storage vessel affected facility. In that case, the 95% control would be required as soon as the liquids are routed from the fractured well to the storage vessel.

5. A storage vessel affected facility that subsequently has VOC emissions decrease below the 6 tpy threshold shall remain an affected facility under OOOO.

6. For storage vessels constructed, reconstucted or modified after August 23, 2011 and before April 12, 2013,(Group 1) the final rule requires that owner/operators estimate emissions from the storage vessels to determine if an affected facility no later than October 15, 2013, and a notification must be submitted with the facility annual report due by January 15, 2014. These same facilities must install equipment to comply with the 95% emissions reduction standards with a compliance deadline of April 15, 2014. Note that these facilities do not need to track emission increase events, as previously proposed.
7. For storage vessels constructed after April 12, 2013, the final compliance date for the 95% emissions reductions is April 15, 2014 (or 60 days after startup, whichever is later).

8. BUT see section 60.5365(h)(4) “A gas well facility initially constructed after August 23, 2011 is considered an affected facility”. This provision seems to ignore the 6tpy limitation… I will get clarification on this..

Please note that the General Construction Permit 6 (GCP-6) released by the New Mexico Environment on Sept. 20th for public comment, is trying to provide a viable alternative to meeting the requirements of OOOO. This permit was sent to you last friday by IPANM. Note that the NMED permit is not final and it is currently being revised to consider industry comments made last weekend and by industry members who attended the NMED meetings. I will inform our membership of any training opportunities and clarification of the document as soon as I get the information.

I have had long conversations with Secretary Flynn of the NMED regarding this issue. He assures me that NMED is working with industry on this issue. I have been assured by staff that training sessions particularly for smaller producers are being considered by the department.