The most recent compliance period for many facilities that are subject to NSPS Subpart OOOO ended on October 15. Except for operators with a custom reporting schedule, reports are due January 13, 2015. In order to meet this deadline, it is important to begin now compiling data needed for the reports.
NSPS OOOO reporting requirements are codified in 40 CFR Part 60.5420(b). Owners/operators can submit one report for all affected equipment covered during the reporting period. Some states have released forms to help streamline reporting; many, however, have not. The required elements for every report are:
Name and address of the “affected facility.” Under NSPS, the “affected facility” is the affected unit, not necessarily the parent company’s mailing address. Reports should include both the company’s mailing and contact address, as well as the location of the affected unit (if they are not the same).
Beginning and end dates of the reporting period. For most, this will be October 15, 2013 through October 15, 2014.
Certification by a responsible official of truth, accuracy and completeness. EPA has proposed to a change that would to allow more people to qualify, but as of the writing of this article, the definition of a “responsible official” aligns with the definition found in Title V.
For other sources included in the report, there are other required reporting elements such as the following:
Hydraulically fractured natural gas wellheads
- Completion logs or a list of affected wells and photographs containing the information required in 60.5420(c)(1)(v)
- A list of any instances leading to failure to meet the reduction requirements and whether those instances were deviations
- A list of any deviations from the VOC reduction standard
- Hours of operation since initial startup or October 15, 2012, or hours of operation since the previous replacement of the rod packing (whichever is later)
- Date and time of each rod packing replacement
- List of deviations (i.e., hours operated beyond the date by which the rod packing should have been replaced)
Continuous bleed pneumatic devices
- A list of each affected facility pneumatic device constructed, modified or reconstructed during the period (i.e., each affected facility “continuous bleed” pneumatic device)
- The month and year of installation
- Documentation of the need for a continuous bleed pneumatic device that emits more than 6 scf/hour and why it was deemed necessary
- A list of any continuous bleed pneumatic devices modified, constructed, or reconstructed during the period that failed to meet the emissions requirement in the rule (that do not have a justification as to why they were necessary as noted above)
Storage vessels with the potential to emit more than 6 tpy of VOC:
- Identification (including location) of each storage vessel for which construction, modification, or reconstruction commenced during the reporting period. The location must be in latitude and longitude using NAD 83.
- Documentation of emission rate (i.e., emission calculations)
- Records of any instances where tanks did not meet the 95% VOC reduction standard
- A statement regarding initial compliance demonstration by installing a closed vent system and controls or routing those vapors back into the process
- A list of any previously identified storage vessels that went “out of service” or “resumed service” during the reporting period
- If using a manufacturer certified combustor, an electronic copy of the performance test results unless the results for that model are listed here: http://www.epa.gov/airquality/oilandgas/
Sweetening units at natural gas processing facilities
- Report of any excess emissions that occurred during the reporting period
Once the NSPS OOOO recordkeeping books have closed on the month of October, environmental personnel should begin compiling the required data for reporting. With many other environmental reports due the first quarter of each year, the late fall/early winter is an excellent time to prepare for the January reporting deadline.