Professional Documents
Culture Documents
Source : Texas Commission on Environmental Quality Air Permit Reference Guide APDG 5942
10/25/2021 U.S. Environmental Protection Agency 19
Artificial Lift Engines
• “Pumpjack” engines
• Engines used to lift oil out of the well if there is
not enough bottom hole pressure for the oil to
flow to the surface
• Generally use casinghead gas
EPA photo.
60
NSPS Subpart LLL- SO2 Standards for Onshore Natural Gas
Processing
• Applicability
– Modified/constructed between 1/20/1984 and 8/23/2011
– Sweetening units and sulfur recovery units
• Requirements
– Establishes standards for SO2
– Achieve SO2 emissions reduction efficiency on a continuous basis
– Monitor sulfur production rate, H2S concentration in the acid gas, acid
gas flow rate, and sulfur dioxide emission reduction efficiency
– If compliance is achieved via oxidation or reduction control systems,
continuous monitoring of the sulfur emission rate is required
61
NSPS Subpart IIII – Stationary Compression Ignition Internal Combustion
Engines
• Applicability
– Modified/constructed after 7/11/2005 (earliest date)
– Stationary engines (not mobile)
– Diesel engines
• Requirements
– Manufacturer/owner requirements differ
– NOx, Hydrocarbons (HC), Carbon Monoxide (CO), Particulate
Matter (PM) limits
– Requirements depend on size, date, location, function
(emergency)
62
NSPS Subpart JJJJ – Stationary Spark Ignition Internal Combustion Engines
• Applicability
– Modified/constructed after 6/12/2006 (earliest date)
– Stationary engines (not mobile)
– Natural gas and gasoline-fired engines
• Requirements
– Manufacturer/owner requirements differ
– NOx, CO, VOC limits
– Fuel sulfur limits for gasoline
– Requirements depend on size, type, and date
63
NSPS Subpart OOOO - Crude Oil and Natural Gas Production, Transmission
and Distribution
• Applicability
– Modified/constructed between 8/23/2011 and
9/18/2015
– Gas well completions with hydraulic fracturing
– Compressor seals
– Pneumatic controllers
– Storage vessels
– Equipment leaks at natural gas processing plants
– Sweetening units located at onshore natural gas
processing plants
64
NSPS Subpart OOOO - Crude Oil and Natural Gas Production, Transmission and
Distribution (cont.)
• Requirements
– Gas well completion controls
– Centrifugal compressors using wet seals must reduce emissions by 95%
– Reciprocating compressors maintenance requirements
– Pneumatic controllers at natural gas processing plants must have a bleed rate
of zero
– Pneumatic controllers located elsewhere must have a bleed rate less than or
equal to 6 scf/hr
– Storage vessels: maintain actual VOC emissions < 4 tpy, or control VOC by
95%
– Equipment leak monitoring at natural gas processing units (replaces Subpart
KKK)
– Limits SO2 from onshore gas processing (replaces Subpart LLL)
65
NSPS Subpart OOOOa - Crude Oil and Natural Gas Production, Transmission
and Distribution
• Applicability
– Modified/constructed after 9/18/2015
– Gas and oil well completions with hydraulic fracturing
– Compressor seals
– Pneumatic controllers and pumps
– Storage vessels
– Equipment Leaks at natural gas processing plants, well
sites, and compressor stations
– Sweetening units located at onshore natural gas processing
plants
66
NSPS Subpart OOOOa - Crude Oil and Natural Gas Production, Transmission
and Distribution (cont.)
• Requirements
– Carries forward NSPS Subpart OOOO
requirements
– Additions
• Standards for CH4
• Oil well completion controls (green completions)
• Control requirement for pneumatic pumps at well sites
and processing plants
• LDAR requirements for well sites and compressor stations
67
NSPS Subpart OOOOa - Crude Oil and Natural Gas
Production, Transmission and Distribution (cont.)
68
NESHAP Subpart HH- Oil and Natural
Gas Production Facilities
• Applicability
–Covers major and area sources of HAP that process, upgrade, or store
hydrocarbon liquids or that process, upgrade, or store natural gas
• Major sources: Glycol dehydration units, storage vessels, and equipment in
volatile HAP service
• Area sources: Triethylene glycol (TEG) dehydration units
• Requirements
–Glycol dehydration units and storage vessels
• 95% control
• Inspect and monitor using Method 21
–Equipment in volatile HAP service must comply with Subpart V (LDAR)
–Area source TEG dehydration units
• In urban areas, use same control as for major sources
• In rural areas, operate at optimal glycol recirculation rate 69
NESHAP Subpart HHH - Natural Gas
Transmission and Storage Facilities
• Applicability
– Applies to major sources of HAP
– New and existing glycol dehydration units
• Requirements
– Large units must route emissions to a control device
• reduce TOC/HAP by 95%, or
• reduce outlet concentration of TOC/HAP to 20 ppmv, or
• reduce benzene emissions to less than 0.90 Mg/year (1 tpy).
– Small units must limit BTEX emissions
• route emissions to a control device, or
• meet an emissions limit through process modifications.
70
NESHAP Subpart ZZZZ - Stationary Reciprocating Internal
Combustion Engines
• Applicability
– Applies to major and minor sources of HAP
– Applies to new and existing reciprocating engines
– Tighter requirements for new engines
• Requirements
– Includes emissions standards and O&M requirements
• Oil and filter change, air filter, spark plugs
– Formaldehyde, CO limitations
– Oxidation catalysts
– Requirements complicated, dependent on major/minor
status, size, type, location, function (emergency, limited use)
71
BREAK
• Discussion/Future Plans
• HAPs:
o BTEX, formaldehyde, and Other HAPs**
• Other Pollutants:
o Hydrogen sulfide
* Filterable and condensable were added for the 2017 NEI
** Additional HAPs were added for the 2017 NEI
10/25/2021 U.S. Environmental Protection Agency 79
2017 Tool Data Sources
• Methodologies: EPA, CenSARA, and Texas calculation tools
• Q&A