NSPS OOOO Updates

February 5, 2015
Robert Keatley, PE
Senior Engineer/Supervisor
DEP – Division of Air Quality
 NSPS OOOO

 New Source Performance Standard (“NSPS”) OOOO -

Standards of Performance for Crude Oil and Natural
Gas Production, Transmission and Distribution
 Published Final Rule August 16, 2012
 Amended September 23, 2013
 Amended Final Rule December 31, 2014 (Published)
 Compliance Date – Green Completions January 1, 2015
 Well Completion Updates

 Natural gas wells (“not oil wells”) – hydraulically fractured

 EPA’s interpretation of natural gas well “We expect that

the final rule will result in control of hydraulically fractured
gas wells drilled in the four formation types generally
accepted as gas-producing formations: (1) High-
permeability gas, (2) shale gas, (emphasis added) (3) other
tight reservoir rock or (4) coal seam.”

 Does not create a minimum Gas-Oil Ratio (GOR) ex. 6,000

scf gas/barrel of oil
 Well Completions Updates

 Applies to each hydraulically fractured/refractured

gas well drilled (commenced construction,
modification, or reconstruction) after August 23, 2011

 Hydraulically fractured/refractured includes wells

fractured w/ Water, Nitrogen, and/or Carbon Dioxide
Completion Combustion
Devices
(aka Flares)
 Well Completions Updates

 Gas Wells drilled on or after January 1, 2015 must comply with

Green Completions

 Defines Flowback, Initial Flowback Stage, Separation Flowback

Stage - which clarifies “Green Completions”

 Salable quality gas must be routed to the flow line “as soon as
practicable”; if cannot be directed to flow line, then completion
combustion device is required

 Sources have a general duty to safely maximize resource

recovery and minimize releases to the atmosphere
 Well Completion Updates

 Initial Flowback Stage – “Any gas present in the initial

flowback stage is not subject to control under this
section” (unless it is technically feasible to operate
separator)

 Separation Flowback Stage – Route recovered gas to

the flow line or collection system, fuel, etc
 Storage Vessel Updates

 Verifies DAQ’s previous interpretation to limit the PTE of

the 6 tpy VOC storage vessel trigger with a “legally and
practically enforceable limit” for non-VRU emission
reduction devices

 Removing affected storage vessels from service “You must

completely empty and degas the storage vessel, such that
the storage vessel no longer contains crude oil,
condensate, produced water or intermediate hydrocarbon
liquids. A storage vessel where liquid is left on walls, as
bottom clingage or in pools due to floor irregularity is
considered to be completely empty.”
 Questions?

Robert Keatley, PE
Division of Air Quality
601 57th Street, SE
Charleston, WV 25304

Phone: 304-926-0499 ext. 1695

E-mail: Robert.L.Keatley@wv.gov