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    West Virginia DAQ NSPS OOOO Presentation

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    jjarrett96
    This document summarizes updates to NSPS OOOO, including: 1) Hydraulically fractured natural gas wells must comply with green completion requirements as of January 1, 2015, which define flowback stages and require routing gas to flow lines. 2) Initial flowback gas is not subject to control, while separation flowback gas must be routed to flow lines or collection systems. 3) Storage vessel emission limits are confirmed to require legally enforceable limits to restrict potential-to-emit below thresholds. 4) Emptying and degassing affected storage vessels completely removes them from regulation.

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    West Virginia DAQ NSPS OOOO Presentation

    Uploaded by

    jjarrett96
    41 views11 pages
    This document summarizes updates to NSPS OOOO, including: 1) Hydraulically fractured natural gas wells must comply with green completion requirements as of January 1, 2015, which define flowback stages and require routing gas to flow lines. 2) Initial flowback gas is not subject to control, while separation flowback gas must be routed to flow lines or collection systems. 3) Storage vessel emission limits are confirmed to require legally enforceable limits to restrict potential-to-emit below thresholds. 4) Emptying and degassing affected storage vessels completely removes them from regulation.

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    Air quality presentation on oil and gas regulation 40CFR60 subpart OOOO.

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    This document summarizes updates to NSPS OOOO, including: 1) Hydraulically fractured natural gas wells must comply with green completion requirements as of January 1, 2015, which define flowback stages and require routing gas to flow lines. 2) Initial flowback gas is not subject to control, while separation flowback gas must be routed to flow lines or collection systems. 3) Storage vessel emission limits are confirmed to require legally enforceable limits to restrict potential-to-emit below thresholds. 4) Emptying and degassing affected storage vessels completely removes them from regulation.

    Copyright:

    © All Rights Reserved
    Download as PPTX, PDF, TXT or read online from Scribd
    Download as pptx, pdf, or txt
    41 views11 pages

    West Virginia DAQ NSPS OOOO Presentation

    Uploaded by

    jjarrett96
    This document summarizes updates to NSPS OOOO, including: 1) Hydraulically fractured natural gas wells must comply with green completion requirements as of January 1, 2015, which define flowback stages and require routing gas to flow lines. 2) Initial flowback gas is not subject to control, while separation flowback gas must be routed to flow lines or collection systems. 3) Storage vessel emission limits are confirmed to require legally enforceable limits to restrict potential-to-emit below thresholds. 4) Emptying and degassing affected storage vessels completely removes them from regulation.

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    You are on page 1of 11

    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

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