Spring is knocking on our door...which means before we know it, it’ll be summer. Soon, we’ll all be at the pool, the neighbor’s barbeque, and on fun trips with the family. Don’t let upcoming compliance deadlines ruin your summer plans – develop your New Source Performance Standards (NSPS) Subpart OOOOa monitoring plans now so that when June rolls around you aren’t stuck at the office pushing paperwork.
As you’ll recall…
NSPS OOOOa became effective last fall on August 2, 2016. The NSPS includes both volatile organic compounds (VOC) and greenhouse gas (GHG) (methane) emission standards for certain equipment, processes, and activities that were new, modified, or reconstructed after September 18, 2015 across the oil and natural gas source category.
The nitty gritty
Basically, what you need to know is that initial surveys for affected (i.e., new, modified or reconstructed) facilities need to take place by June 3, 2017 or within 60 days of startup, whichever is later. Compressor stations will require quarterly monitoring and well sites will require semiannual monitoring using optical gas imaging (OGI). These quarterly or semiannual inspections will also require follow-up monitoring if fugitive emission leaks are detected and not repaired during the initial inspection. Owners/operators have thirty (30) days after detection to repair leaks identified and an additional thirty (30) days from repair to re-monitor to verify repair. If you want to refresh your memory further, Trihydro published a summary with details on the final rule here.
NSPS Subpart OOOOa also requires owners/operators to develop monitoring plans for an owner/operator defined area of well sites and separately for an owner/operator defined area of compressor stations. No fun, we know.
A new tool to make it all easier
The requirements for OOOOa are extensive and will challenge the way you track, manage, and report your leak data. Trihydro recommends using LeakTracker Pro, a software solution that combines efficient field data collection with easy access to data, updates, recordkeeping, repair and remonitor timeframes, as well as annual report submission through EPA’s CEDRI website. Your most important data, including GIS mapping, scheduling, and trend analysis, is made readily available on an intuitive dashboard.
LeakTracker Pro may be right for you if you are interested in streamlining your processes for:
- Securely collecting and aggregating survey data, including OGI video
- Performing automatic calculations
- Providing access to and categorization of data
- Providing visual analysis (i.e. a dashboard of regional and business unit assets)
- Automating report generation
- Proactively alerting stakeholders
Implementing your NSPS OOOOa program
We’re happy to help you get a start on your compliance program now so you can enjoy your summer. Contact our senior air experts, Calvin Niss or Jay Christopher or call us at 800-359-0251 for additional information or a free demonstration of the Leak Tracker Pro software solution.