New Environmental Reg Affects Oil & Gas Sites:
What You Need to Know About Subpart OOOO(a)

A regulation went into effect September 18, 2015 and affects oil and gas facilities that were modified, reconstructed or constructed after that date.   Any equipment including pneumatic controllers, centrifugal compressors, reciprocating compressors, tanks, fittings and valves will require leak testing for methane and other VOC emissions.

What is Subpart OOOO (a)?

The EPA has determined the best system of emissions reduction for reducing greenhouse gas (GHG) emissions, including methane, and volatile organic compounds (VOC) from fugitive emission sources within oil and natural gas production, processing, transmission, and storage facilities.

What Are the Requirements?

Oil and gas facilities will need to

• Develop a Monitoring Plan that specifies and includes
  • site diagrams,
  • list of devices and components to be tested,
  • components must be tagged to match diagram,
  • outlines the requirements and procedures.
• Conduct semi-annual monitoring and equipment leak testing at well sites.
• Conduct quarterly monitoring  at compressor stations.
• Submit an annual monitoring report to applicable state agencies.

The regulation states that the leak testing and monitoring threshold level is 500 parts per million (ppm) .  There are two accepted methods of performing a leak test and monitoring components.  Monitoring can be performed using optical gas imaging technology to determine if any visible emissions are present.  Monitoring can also be conducted using EPA Method 21 and an FID-like device.  Note that repairs must be made within 30 days of finding fugitive emissions and a resurvey of the repaired component must be made within 30 days of the repair using OGI or Method 21 at the stated threshold level.

Oil and gas facilities must conduct initial fugitive emissions monitoring surveys for well sites and compressor stations by June 3, 2017 or 60 days from start-up (whichever is later).

Have more questions?  Contact an SRP Environmental Consultant for more information regarding Subpart OOOO (a).  SRP provides leak testing services, monitoring plan development, and environmental site audits for oil and gas sites across the US to ensure environmental and safety compliance.  Call SRP today at (866) 222-4927.