IPAA NSPS Subpart OOOO

Storage Tank Provision

Tutorial
Ron 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
Criteria Pollutants (e.g., VOC,
NOx, CO, PM, SO2)
Affected facilities at all types
of sites
New, Modified, or
Reconstructed
Proposal date

National Emission Standards

for Hazardous Air Pollutants
Hazardous Air Pollutants
(e.g., Formaldehyde)
Affected facilities at Major
and/or Area Sources
New, Reconstructed, Existing
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 not

construction, 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 Applicability

NSPS OOOO
Affected
Facility

Gathering

Gas
Processing

Centrifugal
Compressors

Reciprocating
Compressors

Gas Well

Production
(Well Site)

Transmission

Pneumatic
Controller

Storage
Vessels

Equipment
Leaks

Sweetening
Units

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 wells

REC and completion

combustion

After 1/1/2015

95% reduction

October 15, 2012

Change rod packing

October 15, 2012

Pneumatic controllers at NG processing plants

Zero bleed rate

October 15, 2012

Pneumatic controllers between wellhead and NG

processing 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

Centrifugal compressors with wet seals

Reciprocating compressors

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 rerouted 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 rerouted 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 <4 T/yr, the
control device can be removed from the
storage vessel
Must be demonstrated through 12
consecutive month demonstration of
emissions less than 4 T/yr

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

600

Annual Emission Rate

(tpy)

500

400

300

200

100

0
0.00

5.00

10.00

15.00

20.00

25.00

30.00

35.00

Daily Throughput
(bbl/day)
ProMax (W & B & Flash)
GRI-HAPCalc
TANKS 4.09d (Condensate) + ECR

E&P Tanks v2
TANKS 4.09d (Condensate) + Promax (Flash Only)

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 <6 T/yr with
federally enforceable limits
Install VRUs and consider process equipment
as per NSPS Subpart OOOO

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 Truelove
405-848-3724
rtruelove@trinityconsultants.com