Compliance with the EPA 40 CFR 60, Subpart OOOO ruling undoubtedly suggests challenges for affected organizations, but ensuring your company is compatible with the required new standards should not be too difficult.
With the implementation of a detailed form of record keeping and on-time submittal of emission information, organizations wishing to be compliant with this EPA oil and gas ruling should be in the clear after the Quad O certified and approved control device has been installed. Just remember that all existing storage tanks must be compatible with Quad O by April 2014, while those being built must comply by April 2015.
Manufacturers such as MESSCO should be able to provide documentation, assuring those affected by Quad O, that their equipment has passed the required government tests and has proven to reduce site emissions with a destruction and removal efficiency (DRE) of 95 percent or better. These manufacturers should also be able to install the emission control device to meet with the EPA engineering requirements, ensuring full compliance. You can view our documentation by downloading our information packet.
Quad O Certified Equipment
To provide a 40 CFR 60, Subpart OOOO certified control device means to manufacture equipment that has undergone rigorous testing. A certified testing agency must come to the manufacturer’s location and test according to strict federal regulations. EPA Test Method 1, 2, 3A, 4, 10, 18, 22, 25A, and 205 all must be conducted using the EPA Certified Protocol gases. Performance testing Consists of three (3) one hour tests at each of the four firing rate settings: 90 to 100 percent, 70 – 100 – 70 percent, 30 – 70 – 30 percent and 0 – 30 – 0 percent. Download MESSCO’s test results here.
The EPA has indicated that DRE standards will be increasing to 98 percent in the near future, so it is recommended to purchase compliant equipment with a DRE rate exceeding or equal to 98 percent to protect your storage tanks from further EPA required adjustments.
Becoming 40 CFR 60, Subpart OOOO Compliant with MESSCO
MESSCO’s VOCinerator™ is a Quad O certified enclosed combustor, which has been tested and certified to a destruction efficiency of 99 percent. This smokeless, yet fully-automated emission control device functions effectively and efficiently in a variety of situations, even when liquid is introduced. Built with the user in mind, this patented design provides minimum downtime should a situation arise and lowers lifetime costs compared to other emission elimination equipment. It also is one of the few Quad O certified emission control devices that meets a standard of nearly 100 percent.
Tested and currently operating in live environments, the MESSCO VOCinerator is proven to produce results and can be found destroying BTEX and VOC emissions as well as help organizations become compliant with EPA regulations across the United States. Learn just how it works and how it can help your company by visiting our VOCinerator information page.
The EPA’s Quad O Regulations
The Environmental Protection Agency’s latest iteration of air pollution standards for the oil and natural gas industry is published as 40 CFR 60, Subpart OOOO, or in simpler terms, Quad O. This new standard is the first of its kind for federal air standards and places strict regulations on organizations that use oil and gas storage and production tanks, in an effort to decrease waste emissions. This pertains particularly to facilities with a Potential to Emit (PTE) 6+ tons of annual VOC (volatile organic compound).
The Quad O regulations state that storage tank facilities with a PTE of 6+ tons of annual VOC must install an approved control device to reduce site emissions with a removal and destruction efficiency of 95 percent.
Industries Affected by 40 CFR 60, Subpart OOOO
Several industries are affected by the Quad O ruling, also affectionately called the “Oil and Gas” rule. Each of these industries is provided with select timelines for compliance. The most affected industries include:
- Processing Plants: Natural gas processing plants with sulfur production of 6+ long tons per day must reduce SO2 emissions by at least 99 percent.
- Compressors: Centrifugal compressors with wet seal systems will be required to reduce VOC emissions, but natural gas transmission and storage segment compressors are not impacted by the 40 CFR 60, Subpart OOOO.
- Hydraulic Fracturing (Fracking): Recompleted or new gas wells are required to use a REC process to capture VOC emissions under the EPA Quad O ruling.
- Glycol Dehydrators: Quad O applies to Glycol Dehydrators with the potential to emit 10 TPY or more of a single HAP or 25 TPY or more of a combination of HAPs. (Abby to Send Verified Information)
- Storage Tanks: Facilities with a PTE of 6+ tons of annual VOC are required under this EPA law to install a Quad O certified control device in order to reduce site emissions with a removal and destruction efficiency of 95 percent.
While Hydraulic Fracturing feels the impact of the most publicized portion of 40 CFR 60, Subpart OOOO, those who are within the storage tank industry have the most pressing timelines for compliance.
Timeline for EPA Quad O Compliance
40 CFR 60, Subpart OOOO was implemented by the EPA, effective Oct.15, 2012. Quad O affects two groups in the storage tank industry.
- Group 1 is composed of facilities that were participating in storage construction, modification or reconstruction, which began after Aug. 23, 2011, and before official Quad O compliance of April 12, 2013.
- Group 2 relates to those who have begun storage construction, modification or reconstruction after April 12, 2013.
All facilities must have recorded and submitted storage tank locations and exact numbers to the EPA by Oct. 15, 2013. Any storage tank facilities constructed after the compliance start date (April 15, 2013) fall into Group 2 or have 60 days (if constructed after April 15, 2014) following startup to install the required Quad O certified control device.
Group 2 must be compliant with the EPA Quad O regulations by April 15, 2014. Group 1 is required to reach Quad O compliance by April 15, 2015.
The Effect of Quad O on the Gas and Oil Storage Tank Industry
Quad O is already affecting the industry with both long- and short-term impact. As your organization continues to produce upon existing storage tank facilities or undergoes construction on new production facilities, it is important to look to the future with 40 CFR 60, Subpart OOOO compliance in mind.
The short-term impact of Quad O may include:
- The need to implement a higher form of record keeping in order to meet new reporting and emission requirements.
- An installation of Quad O certified emission control equipment that meets the EPA engineering requirements.
Long-term effects may include:
- An increased cost of construction and production with the requirement of 40 CFR 60, Subpart OOOO certified control devices.
- Potential regulatory requirements in the future for greenhouse gases as well as non-attainment ozone areas.
- The need to develop an infrastructure that meets all industry EPA and Quad O requirements.
Clean Air and Quad O for the Years to come with MESSCO
At MESSCO We believe in clean air solutions and equipment that provide smart business investments for our clients. Our products are currently exceeding government regulations, which ensures your organization is appropriately prepared for years to come, while continuing to preserve the environment for future generations.
To learn more about our Quad O products, request a quote or to have your 40 CFR 60, Subpart OOOO compliance questions answered, please feel free to contact our friendly team of experts at (307) 382-2926.