In an effort to further reduce volatile organic compounds (VOCs) and methane (C3), from new and modified sources in the oil and gas sector, EPA finalized the Quad Oa rule on May 12, 2016. The updates to Quad O or Quad Oa (as the revisions are called), add methane to the pollutants covered by the rule. In addition, requirements were added for detecting and repairing leaks at various sources within well site or compressor station. Detailed record keeping and reporting requirements were also implemented within the new rule. OTA/Kimark will simplify and automate the reporting and recordkeeping that is required within the rule saving operators time and money. In addition, we have superior logic control on our vapor recovery units, burner management systems, combustors, and flow meters that interface with accessory equipment via Modbus communication.
Quad Oa regulates the fugitive emissions from new, modified, and reconstructed compressor stations. Operators must create a leak detection and repair (LDAR) program in order to identify and repair gas leaks. A fugitive emission is any emission that is visible using optical gas imaging (OGI) or a reading of 500 ppm or greater using EPA’s method 21. Operators must conduct an initial LDAR survey within 60 days of start-up or modification and semi-annually (well sites) or quarterly (compressor stations) thereafter separated by at least 120 days (well sites) or 60 days (compressor stations).
The initial compliance period is concluded one year after the finalization of the rule, which is June 3, 2017 in this case. This means that the initial surveys are to be conducted within this time frame.
Optical Gas Imaging (OGI) cameras are used for gas leak detection in Leak Monitoring Surveys (LMS) and site surveys. Many chemical compounds and gases are invisible to the naked eye. The FLIR GF-Series infrared cameras are able to visualize gas by utilizing the physics of fugitive gas leaks. The camera produces a full picture of the scanned area and the fugitive gas appears as smoke. The image is viewed in real time and can be recorded and stored, and used in reporting EPA Compliance.
If leaks are found during a survey, then operators must replace or repair the sources of any detected fugitive emissions “as soon as practicable, but no later than 30 days after detection” (60.5397(a) (H)(1)). Once the leaks are repaired, then the location must be resurveyed within 30 days to ensure that the leak has been corrected. Operators are required to develop and implement monitoring plans to comply with the fugitive emission requirements and must meet the recordkeeping and reporting rules that are outlined within the EPA guidelines. Operators can place all of their stations into a single monitoring plan or create multiple plans based on how they internally organize their facilities.
Do you need a monitoring plan? No worries! OTA has you covered with a comprehensive plan that is just right for you. Contact us for more information.
