Addressing Oil & Gas Environmental Regulatory Requirements

Upstream Storage Tank Non-Compliance and EPA's Newly Finalized Audit Policy

When EPA proposed New Source Performance Standard (NSPS) OOOO on August 23, 2011, not many operators had a solid handle on emissions from oil field storage tanks. A lot has been learned since then. Oilfield operators and agencies alike have since learned that storage tanks - particularly those associated with newer facilities, and with high production rates or producing from shale oil formations with high volatility oil - can be significant emitters of Volatile Organic Compounds (VOCs). As a result, oil and gas operators have become accustomed to securing air quality permits for these types of facilities. Indeed, there are more permitted upstream facilities today than ever before - many of which are claiming a 95% reduction (or more) in emissions from storage tanks, thanks to the installation of closed vent systems which collect vapors from tanks and either recycle them, or combust them.

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 Join us for an upcoming events covering Tank emissions:

Oil and Gas Potential Targets For the Regional Haze Second Planning Period

Is your oil and gas facility, e.g., compressor station, anywhere close to a Class I area (National Park, Wilderness Area, or Forest Service Area)? And by close we mean several hundred kilometers (km)? If so, depending on the location of your facility to a Class I area and emissions, there is the potential that your facility could be a target for evaluation under the 2nd Planning Period for Regional Haze.

Since EPA redefined visibility impairment in its Technical Guidance for the 2nd Planning Period with no de minimis threshold of impact, each Regional Planning Organization (RPO) and/or state must develop its own methodology of screening potential industrial sources into the program. If a source is screened in, a four-factor analysis would be required to determine if there are “reasonable” controls available for reducing visibility impairing emissions. With no defined methodology for this process by EPA, sites need to be aware of the evaluations being conducted in their regions, and be involved in the stakeholder processes for the 2nd Planning Period.

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Join us for a complimentary webinar to learn what this means for your facility:

The Benefits and Risks of Optical Gas Imaging (OGI) to Oil & Gas Operators

Leak detection and repair (LDAR) rules under both state and federal programs allow the use of optical gas imaging (OGI) technology. This technology has benefits over traditional monitoring practices and can be very beneficial for optimizing industrial operations. This technology is also used by those outside of industry (including regulatory agencies and non-governmental organizations). Having a solid understanding of the technology and how to use it correctly is critical to avoid misinterpreting data for maximizing the benefits this technology has to offer.

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Trinity Can Help

Trinity can assist with OOOOa compliance in several areas:

LDAR Plan Training and Development. A one-day training session will educate staff on what goes into conducting surveys and how your company may need to modify existing programs to meet the requirements. This will help operators clearly understand the requirements, while also developing a monitoring plan that meets the requirements of the regulation.

OGI Survey Training and Support. Trinity has certified thermographers available to train internal or external resources on surveys and associated recordkeeping. We work with operators to understand the nuance of OGI surveys such as common vents that should not be monitored (or considered "leaking").

Join us for an upcoming events on these topics: