25 Pa. Code § 129.127 - Fugitive emissions components
(a)
Applicability. This section applies to the owner or operator
of a fugitive emissions component subject to §
129.121(a)(5)
(relating to general provisions and applicability), located at one or more of
the following:
(1) An unconventional well
site.
(2) A natural gas gathering
and boosting station.
(3) A natural
gas processing plant.
(b)
Average production calculation procedure for a well site.
Beginning on or before January 9, 2023:
(1)
The owner or operator of a well site subject to subsection (a)(1) shall
calculate the average production in barrels of oil equivalent per day of the
well site using the previous 12 calendar months of operation as reported to the
Department and thereafter as specified in subsection (c)(4) for the previous
calendar year. The owner or operator shall do the following:
(i) For each well at the well site with
production reported to the Department:
(A)
Record the barrels of oil produced for each active well.
(B) Convert the natural gas production for
each active well to equivalent barrels of oil by dividing the standard cubic
feet of natural gas produced by 6,000 standard cubic feet per barrel of oil
equivalent.
(C) Convert the
condensate production for each active well to equivalent barrels of oil by
multiplying the barrels of condensate by 0.9 barrels of oil equivalent per
barrel of condensate.
(ii) Calculate the total production for each
active well, in barrels of oil equivalent, by adding the results of
subparagraph (i)(A)- (C) for each active well.
(iii) Sum the results of subparagraph (ii)
for all active wells at the well site and divide by 365 or 366 days for the
previous 12 calendar months or the previous calendar year, as
applicable.
(2) If the
owner or operator does not know the production of an individual well at the
well site, the owner or operator shall comply with subsection (c)(2).
(c)
Requirements for an
unconventional well site.
(1) For a
well site consisting of only oil wells, the owner or operator shall:
(i) Determine the GOR of the oil well site
using generally accepted methods.
(ii) If the GOR of the oil well site is less
than 300 standard cubic feet of gas per barrel of oil produced, maintain the
records under §
129.130(g)(1)
(relating to recordkeeping and reporting).
(iii) If the GOR of the oil well site is
equal to or greater than 300 standard cubic feet of gas per barrel of oil
produced, meet the requirements of paragraph (2) or paragraph (3) based on the
results of subsection (b)(1).
(2) For a well site producing, on average,
equal to or greater than 15 barrels of oil equivalent per day, with at least
one well producing, on average, equal to or greater than 15 barrels of oil
equivalent per day, the owner or operator shall:
(i) Conduct an initial AVO inspection on or
before February 8, 2023, with monthly inspections thereafter separated by at
least 15 calendar days but not more than 45 calendar days.
(ii) Conduct an initial LDAR inspection
program on or before February 8, 2023, with quarterly inspections thereafter
separated by at least 60 calendar days but not more than 120 calendar days
using one or more of the following:
(A) OGI
equipment.
(B) A gas leak detector
that meets the requirements of EPA Method 21.
(C) Another leak detection method approved by
the Department.
(3) For a well site producing, on average,
equal to or greater than 15 barrels of oil equivalent per day, and at least one
well producing, on average, equal to or greater than 5 barrels of oil
equivalent per day but less than 15 barrels of oil equivalent per day, the
owner or operator shall:
(i) Conduct an
initial AVO inspection on or before February 8, 2023, with monthly inspections
thereafter separated by at least 15 calendar days but not more than 45 calendar
days.
(ii) Conduct an initial LDAR
inspection program on or before May 9, 2023, with annual inspections thereafter
separated by at least 335 calendar days but not more than 395 calendar days
using one or more of the following:
(A) OGI
equipment.
(B) A gas leak detector
that meets the requirements of EPA Method 21.
(C) Another leak detection method approved by
the Department.
(4) The owner or operator of a producing well
site shall calculate the average production of the well site under subsection
(b) for the previous calendar year not later than February 15 and may adjust
the frequency of the required LDAR inspection as follows:
(i) If two consecutive calculations show
reduced production, the owner or operator may adopt the requirements applicable
to the reduced production level.
(ii) If a calculation shows higher
production, the owner or operator shall adopt the requirements applicable to
the higher production level immediately.
(5) The owner or operator of a well site
subject to paragraph (3) may submit to the appropriate Department Regional
Office a request, in writing, for an exemption from the requirements of
paragraph (3)(ii).
(i) The written request
must include the following:
(A) Name and
location of the well site.
(B) A
demonstration that the requirements of paragraph (3)(ii) are not technically or
economically feasible for the well site.
(C) Sufficient methods for demonstrating
compliance with all applicable standards or regulations promulgated under the
Clean Air Act or the Act.
(ii) The Department will review the complete
written request submitted in accordance with subparagraph (i) and approve or
deny the request in writing.
(iii)
The Department will submit each exemption determination approved under
subparagraph (ii) to the Administrator of the EPA for approval as a revision to
the SIP. The owner or operator shall bear the costs of public hearings and
notifications, including newspaper notices, required for the SIP
submittal.
(iv) The owner or
operator of the well site identified in subparagraph (i)(A) shall remain
subject to the requirements of paragraphs (1), (3)(i) and (4).
(d)
Requirements
for a shut-in unconventional well site. The owner or operator of an
unconventional well site that is temporarily shut-in is not required to perform
an LDAR inspection of the well site until one of the following occurs,
whichever is first:
(1) Sixty days after the
unconventional well site is put into production.
(2) The date of the next required LDAR
inspection after the unconventional well site is put into production.
(e)
Requirements for a
natural gas gathering and boosting station or a natural gas processing
plant. The owner or operator of a natural gas gathering and boosting
station or a natural gas processing plant shall conduct the following:
(1) An initial AVO inspection on or before
February 8, 2023, with monthly inspections thereafter separated by at least 15
calendar days but not more than 45 calendar days.
(2) An initial LDAR inspection program on or
before February 8, 2023, with quarterly inspections thereafter separated by at
least 60 calendar days but not more than 120 calendar days using one or more of
the following:
(i) OGI equipment.
(ii) A gas leak detector that meets the
requirements of EPA Method 21.
(iii) Another leak detection method approved
by the Department.
(f)
Requirements for extension of the
LDAR inspection interval. The owner or operator of an affected
facility may request, in writing, an extension of the LDAR inspection interval
from the Air Program Manager of the appropriate Department Regional
Office.
(g)
Fugitive
emissions monitoring plan. The owner or operator shall develop, in
writing, an emissions monitoring plan that covers the collection of fugitive
emissions components at the subject facility within each company-defined area.
The written plan must include the following elements:
(1) The technique used for determining
fugitive emissions.
(2) A list of
fugitive emissions detection equipment, including the manufacturer and model
number, that may be used at the facility.
(3) A list of personnel that may conduct the
monitoring surveys at the facility, including their training and
experience.
(4) The procedure and
timeframe for identifying and fixing a fugitive emissions component from which
fugitive emissions are detected, including for a component that is
unsafe-to-repair.
(5) The procedure
and timeframe for verifying fugitive emissions component repairs.
(6) The procedure and schedule for verifying
the fugitive emissions detection equipment is operating properly.
(i) For OGI equipment, the verification must
be completed as specified in subsection (h).
(ii) For gas leak detection equipment using
EPA Method 21, the verification must be completed as specified in subsection
(i).
(iii) For a
Department-approved method, a copy of the request for approval that shows the
method's equivalence to subsection (h) or subsection (i).
(7) A sitemap.
(8) If using OGI, a defined observation path
that meets the following:
(i) Ensures that all
fugitive emissions components are within sight of the path.
(ii) Accounts for interferences.
(9) If using EPA Method 21, a list
of the fugitive emissions components to be monitored and an identification
method to locate them in the field.
(10) A written plan for each fugitive
emissions component designated as difficult-to-monitor or unsafe-to-monitor
which includes the following:
(i) A method to
identify a difficult-to-monitor or unsafe-to-monitor component in the
field.
(ii) The reason each
component was identified as difficult-to-monitor or
unsafe-to-monitor.
(iii) The
monitoring schedule for each component identified as difficult-to-monitor or
unsafe-to-monitor. The monitoring schedule for difficult-to-monitor components
must include at least one survey per year no more than 13 months apart.
(h)
Verification procedures for OGI equipment. An owner or
operator that identifies OGI equipment in the fugitive emissions monitoring
plan in subsection (g)(6)(i) shall complete the verification by doing the
following:
(1) Demonstrating that the OGI
equipment is capable of imaging a gas:
(i) In
the spectral range for the compound of highest concentration in the potential
fugitive emissions.
(ii) That is
half methane, half propane at a concentration of 10,000 ppm at a flow rate of
less than or equal to 60 grams per hour (2.115 ounces per hour) from a 1/4-inch
diameter orifice.
(2)
Performing a verification check each day prior to use.
(3) Determining the equipment operator's
maximum viewing distance from the fugitive emissions component and how the
equipment operator will ensure that this distance is maintained.
(4) Determining the maximum wind speed during
which monitoring can be performed and how the equipment operator will ensure
monitoring occurs only at wind speeds below this threshold.
(5) Conducting the survey by using the
following procedures:
(i) Ensuring an
adequate thermal background is present to view potential fugitive
emissions.
(ii) Dealing with
adverse monitoring conditions, such as wind.
(iii) Dealing with interferences, such as
steam.
(6) Following the
manufacturer's recommended calibration and maintenance
procedures.
(i)
Verification procedures for gas leak detection equipment using EPA
Method 21. An owner or operator that identifies gas leak detection
equipment using EPA Method 21 in the fugitive emissions monitoring plan in
subsection (g)(6)(ii) shall complete the verification by doing the following:
(1) Verifying that the gas leak detection
equipment meets:
(i) The requirements of
Section 6.0 of EPA Method 21 with a fugitive emissions definition of 500 ppm or
greater calibrated as methane using an FID-based instrument.
(ii) A site-specific fugitive emission
definition that would be equivalent to subparagraph (i) for other equipment
approved for use in EPA Method 21 by the Department.
(2) Using the average composition of the
fluid, not the individual organic compounds in the stream, when performing the
instrument response factor of Section 8.1.1 of EPA Method 21.
(3) Calculating the average stream response
factor on an inert-free basis for process streams that contain nitrogen, air or
other inert gases that are not organic hazardous air pollutants or
VOCs.
(4) Calibrating the gas leak
detection instrument in accordance with Section 10.1 of EPA Method 21 on each
day of its use using zero air, defined as a calibration gas with less than 10
ppm by volume of hydrocarbon in air, and a mixture of methane in air at a
concentration less than 10,000 ppm by volume as the calibration
gases.
(5) Conducting the surveys
which, at a minimum, must comply with the relevant sections of EPA Method 21,
including Section 8.3.1.
(j)
Fugitive emissions detection
devices. Fugitive emissions detection devices must be operated and
maintained in accordance with manufacturer-recommended procedures and as
required by the test method or a Department-approved method.
(k)
Background adjustment.
For LDAR inspections using a gas leak detector in accordance with EPA Method
21, the owner or operator may choose to adjust the gas leak detection
instrument readings to account for the background organic concentration level
as determined by the procedures of Section 8.3.2 of EPA Method 21.
(l)
Repair and resurvey
provisions. The owner or operator shall repair a leak detected from a
fugitive emissions component as follows:
(1) A
first attempt at repair must be made within 5 calendar days of detection, and
repair must be completed no later than 15 calendar days after the leak is
detected unless:
(i) The purchase of a part is
required. The repair must be completed no later than 10 calendar days after the
receipt of the purchased part.
(ii)
The repair is technically infeasible because of one of the following reasons:
(A) It requires vent blowdown.
(B) It requires facility shutdown.
(C) It requires a well shut-in.
(D) It is unsafe to repair during operation
of the unit.
(iii) A
repair that is technically infeasible under subparagraph (ii) must be completed
at the earliest of the following:
(A) After a
planned vent blowdown.
(B) The next
facility shutdown.
(C) Within 2
years.
(2) The
owner or operator shall resurvey the fugitive emissions component no later than
30 calendar days after the leak is repaired.
(3) For a repair that cannot be made during
the monitoring survey when the leak is initially found, the owner or operator
shall do one of the following:
(i) Take a
digital photograph of the fugitive emissions component which includes:
(A) The date the photo was taken.
(B) Clear identification of the component by
location, such as by latitude and longitude or other descriptive landmarks
visible in the picture.
(ii) Tag the component for identification
purposes.
(4) A gas leak
is considered repaired if:
(i) There is no
visible leak image when using OGI equipment calibrated according to subsection
(h).
(ii) A leak concentration of
less than 500 ppm as methane is detected when the gas leak detector probe inlet
is placed at the surface of the fugitive emissions component for a gas leak
detector calibrated according to subsection (i).
(iii) There are no detectable emissions
consistent with Section 8.3.2 of EPA Method 21.
(iv) There is no bubbling at the leak
interface using the soap solution bubble test specified in Section 8.3.3 of EPA
Method 21.
Notes
The provisions of this § 129.127 added under section 5(a)(1) and (8) of the Air Pollution Act (35 P.S. § 4005(a)(1) and (8)).
This section cited in 25 Pa. Code § 129.121 (relating to general provisions and applicability); 25 Pa. Code § 129.122 (relating to definitions, acronyms and EPA methods); 25 Pa. Code § 129.128 (relating to covers and closed vent systems); and 25 Pa. Code § 129.130 (relating to recordkeeping and reporting).
State regulations are updated quarterly; we currently have two versions available. Below is a comparison between our most recent version and the prior quarterly release. More comparison features will be added as we have more versions to compare.
No prior version found.