NSPSOOOOStorageTankIPAAWebinar Slides10!10!13
description
Transcript of NSPSOOOOStorageTankIPAAWebinar Slides10!10!13
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IPAA NSPS Subpart OOOO
Storage Tank Provision
TutorialRon Truelove, Director, Oil and
Gas Sector Services
Trinity Consultants, Inc.
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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)
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Introduction &
Opening
Remarks
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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
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Trinity U.S. Office Locations
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What not to expect from the
tutorial Absolute answers to everything!
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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).
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Section 1
Overview of NSPS
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NSPS vs. NESHAP
New Source Performance Standards
National Emission Standards for Hazardous Air Pollutants
Criteria Pollutants (e.g., VOC, NOx, CO, PM, SO2)
Hazardous Air Pollutants (e.g., Formaldehyde)
Affected facilities at all types of sites
Affected facilities at Major and/or Area Sources
New, Modified, or Reconstructed
New, Reconstructed, Existing
Proposal date Proposal date
Note: Neither regulates GHG emissions (e.g., CO2, CH4, N2O).
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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 notconstruction, modification, or reconstruction under NSPS and does not trigger the rule Permitting may be required at the new site
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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)
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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))
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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))
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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
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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.
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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.
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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
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Section 2
NSPS Subpart OOOO:
Final 2012 and 2013 Storage
Tank Rules
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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
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Subpart OOOO ApplicabilityNSPS OOOO AffectedFacility
Production (Well Site) Gathering
Gas Processing Transmission
Gas Well X
Centrifugal Compressors
X X
ReciprocatingCompressors
X X
Pneumatic Controller
X X X
Storage Vessels
X X X X
Equipment Leaks
X
Sweetening Units
X
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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 wellsREC and completion
combustionAfter 1/1/2015
Centrifugal compressors with wet seals 95% reduction October 15, 2012
Reciprocating compressors Change rod packing October 15, 2012
Pneumatic controllers at NG processing plants Zero bleed rate October 15, 2012
Pneumatic controllers between wellhead and NGprocessing 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
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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
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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
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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.
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Definition Specifics
Crude oil
Condensate
Intermediate hydrocarbon liquids
Produced water
Fuel and chemical injection tanks
excluded
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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.
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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)
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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 re-
routed to a process toward PTE
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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 re-
routed to a process toward PTE
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Storage Vessel Exit Ramp
There is now an exit ramp for storage vessels to account for declining production
Once uncontrolled emissions drop
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Typical VRU
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Tank VRU
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VRU Capture Line
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Tank Battery and Vent Line
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A Closer Look
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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
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Section 3
Storage Tank Emission
Calculations
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Storage Tank Emissions
Flash
Working
Breathing
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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)
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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
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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
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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
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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
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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
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Methodology Comparison
Permission provided by BRE.
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Trinity Method Comparison
0
100
200
300
400
500
600
0.00 5.00 10.00 15.00 20.00 25.00 30.00 35.00
An
nu
al E
mis
sio
n R
ate
(t
py)
Daily Throughput (bbl/day)
ProMax (W & B & Flash) E&P Tanks v2
GRI-HAPCalc TANKS 4.09d (Condensate) + Promax (Flash Only)
TANKS 4.09d (Condensate) + ECR
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Calculation Accuracy
Size control equipment based on the
most accurate method
Understand compliance risk
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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)
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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
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Section 4
What Should I Be Doing Now?
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Preparing for NSPS Subpart
OOOO Tank Compliance Develop an inventory of storage tanks
installed, modified, or reconstructed
after August 23, 2011.
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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
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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
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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
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Questions?
Ron Truelove405-848-3724