YOUR VAPOR RECOVERY SOLUTIONS COMPANIES

Transcription

1 YOUR VAPOR RECOVERY SOLUTIONS COMPANIES

2 PRESENTER INTRODUCTIONS

3 SERVICE MATTERS Are you compliant? DEPENDABLE SERVICE Rather the manufacturer come to you and make the repairs? Need reliable service technicians trained on the equipment they are servicing? NO WORRIES! OTA s/kimark s HIGHLY QUALIFIED FIELD TECHNICIANS ARE AVAILABLE 24/7!

4 SERVICE MATTERS RELIABLE SERVICE OTA provides preventative maintenance on VRUs, VRTs, VCUs, Wellhead Compressors, and Flares (including 3 rd party units!). This matters too: - Vapor Recovery System Consulting - Emissions Testing - Provide SERVICE LOGS! - Field Technicians - Competent, Dependable, and Local Wide Service Coverage

5 TABLE OF CONTENTS INTRODUCTION FUGITIVE EMISSIONS COMPONENT APPLICABILITY SURVEY PROCEDURE RECORDKEEPING / REPORTING OVERVIEW

6 FUGITIVE EMISSIONS COMPONENT WHAT TO SURVEY Fugitive Emissions Component: Any component that has the potential to emit fugitive emissions of methane or VOC at a well site or compressor station, including and not limited to: Valves, connectors, PSVs, open-ended lines, flanges, CVS (not subject to a), thief hatches, vent valves, compressors, instruments, and meters

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9 TABLE OF CONTENTS INTRODUCTION FUGITIVE EMISSIONS COMPONENT APPLICABILITY SURVEY PROCEDURE RECORDKEEPING / REPORTING OVERVIEW

10 APPLICABILITY Well Sites One or more surface sites that are constructed for the drilling and subsequent operation of any oil well, natural gas well, or injection well. Tank Batteries Satellite Batteries Surveyed Bi-Annually Well Sites Standalone wellhead Non-affected satellite site w/or w/out separation equipment Compressor Stations Any permanent combination of one or more compressors that move natural gas at increased pressure through gathering or transmission pipelines, or into or out of storage. Surveyed Quarterly Compressor Stations One or more compressors at a wellsite or natural gas processing plant

11 APPLICABILITY Construction Commenced construction after Sept 18, 2015 Well Site A well (crude oil / natural gas / produced water) is drilled and or hydraulically fractured Compressor Station A greenfield station Order date of compressor > 9/18/15 Modification Well Site A new well is drilled, hydraulically fractured, or hydraulically refractured at an existing site Compressor Station An additional compressor is installed (which increases the total HP) OR, one or more compressors are replaced by one or more compressors of > Total Horse Power

12 APPLICABILITY EXEMPTIONS 100,000 gal storage vessel used to recycle produced water that has passed through two (2) stage separation Addition / replacement of equipment for the purpose of process improvement accomplished without capital expenditure

13 APPLICABILITY EXEMPTIONS CONTINUED Well Site Containing only one or more wellheads, One (1) or more compressors replaced by one or more compressors of equal or lesser Total HP A compressor located at a well site, or an adjacent well site AND servicing more than one well site

14 APPLICABILITY EXEMPTIONS CONTINUED CVS subject to a Other storage vessel openings subject to a Well Site Drilled before 9/15/2015, yet completed/recompleted after the fact and NOT hydraulically frac d/re-frac d Refer to a(a)(1)(4)

15 APPLICABILITY EXEMPTIONS CONTINUED Natural Gas-Driven Pneumatic controllers/pumps that are designed to vent Natural Gas-Driven Pneumatic Piston Pumps used to inject chemicals to limit production problems and protect equipment Limited-Use Pneumatic Pumps Lean Glycol Circulation Pumps insofar as the natural gas discharged from the device's vent is not considered a fugitive emission.

16 NAT GAS PNEUMATIC APPLICABILITY CONTROLLER DIGITAL IMAGE HSM VIDEO

17 APPLICABILITY EXEMPTIONS CONTINUED Storage Vessel Vent Valves (PRVs) An Activated PSV refer to EPA-HQ- OAR

18 VENT APPLICABILITY VALVE (PSV) HSM VIDEO #1 HSM VIDEO #2

19 TABLE OF CONTENTS INTRODUCTION FUGITIVE EMISSIONS COMPONENT APPLICABILITY SURVEY PROCEDURE RECORDKEEPING / REPORTING OVERVIEW

20 SURVEY PROCEDURE TECHNIQUE(S) 500 ppm Visible Emissions FID/PID Equipment Calibrations FLIR GF3XX Area Scanning METHOD 21 OGI Single Point Measurement Fugitives Inventory Very Accurate Pinpoint Leaks Labor Intensive Remote Monitoring

21 SURVEY PROCEDURE PROCESS Initial Survey Repair Follow-Up Survey Follow observation path and look at all applicable components for fugitives Repair or replace any fugitive source leaks Confirm fugitive leak source has been fixed; verification Survey within 60 days of startup Repair all leaks within 30 days Resurvey fixed leaks within 30 days

22 TABLE OF CONTENTS INTRODUCTION FUGITIVE EMISSIONS COMPONENT APPLICABILITY SURVEY PROCEDURE RECORDKEEPING / REPORTING OVERVIEW

23 RECORDKEEPING WHAT IS RECORDABLE DAILY CALIBRATION MONITORING INSTRUMENT DATE OF SURVEY SURVEY DURATION SURVEYOR CONTACT INFO TRAINING EXPERIENCE

24 RECORDKEEPING CONTINUED # OF FUGITIVES FUGITIVES TYPE DATE OF REPAIR DATE OF RESURVEY DOR SOURCES DTM/UTM SOURCES

25 RECORDKEEPING MONITORING PLAN DAILY CALIBRATION Weather conditions, Max wind speed/direction, Max viewing distance RECORD RETENTION Minimum of 5 years SURVEY TECHNIQUE(s) OGI, Method 21, Alternative Screening Method STANDARD OPERATING PROCEDURES How to conduct oneself during a survey; specific-fugitive source monitoring duration; DOR; DTM/UTM OBSERVATION PATH Designated path of survey; site-specific TRAINING/EXPERIENCE OGI certification; 2 years of surveying experience; thermographer II training

26 REPORTING WHAT WE KNOW THUS FAR Initial report is due 90 days after initial compliance period or October 31, 2017 Subsequent annual reports are due no later than same date each year Submit reports DIRECTLY to EPA via CEDRI

27 TABLE OF CONTENTS INTRODUCTION FUGITIVE EMISSIONS COMPONENT APPLICABILITY SURVEY PROCEDURE RECORDKEEPING / REPORTING OVERVIEW

28 CONTACT OTA North Texas Office Granbury, TX Office: (817) Permian Basin Office Midland, TX Office: (432) South Texas Office Houston, TX Office: (210) Oklahoma Office Okemah, OK Office: (918) Arkansas Office Ozark, AR Office: (479)

29 SERVICE COVERAGE