ESE was engaged by a major Exploration and Production (E&P) company to aid in the development and implementation of an Audio, Visual and Olfactory (AVO) Program. These programs abided by the conditions outlined in the TCEQ’s Non-Rule Standard Permit (NRSP) and New Source Performance Standard (NSPS OOOO or Quad O) for production operations in their Eagle Ford Business Unit.
Per 40 CFR Part 60, Subpart OOOO (Quad O), each storage vessel, centrifugal compressor and reciprocating compressor affected facilities are required to be inspected and records to be maintained once every calendar month for defects that could result in air emissions. These defects included: visible cracks, holes or gaps in piping/cover or between the cover and the separator wall, loose connections, liquid leaks or broken or missing caps broken, cracked or otherwise damaged seals or gaskets on closure devices, as well as broken or missing hatches, access covers or other closure devices. In addition, NRSP permit requires applicable facilities to install, check and properly maintain all of the seals and gaskets in VOC or H2S service to prevent leaking. The components are required to be physically inspected each for leaks on a quarterly basis.
Scope of Work
- ESE developed an inspection and monitoring checklist specific to the company’s production and maintenance operations, as well as environmental/regulatory needs.
- ESE conducted trainings and implemented a daily inspection process for multi-skilled operators (MSOs), field maintenance, production operations personnel and general AVO program requirements.
- Performed quarterly inspections to ensure compliance with state and federal leak detection requirements. (ie: NRSP and NSPS OOOO)
- ESE created a field based inspection application to communicate the findings with the corporate and field personnel on a daily basis.
- ESE compiled the results of the inspection reports to document each monitoring event, findings, timeline and corrective actions (as necessary) for tracking and record keeping purposes.
Key Benefits to Client
- Development of a robust inspection & maintenance program allowed for identification of the leaks during initial stages preventing future catastrophic spills and leaks.
- Inspection and Recordkeeping program ensured compliance with the applicable state and federal permits, rules and regulations.
- Leak descriptions and photo-logs included in the field inspection checklist ensured immediate and effective response by the maintenance personnel.
- Third-party inspections ensured transparency in the overall process.
- Leak detection by a MiniRae handheld VOC monitor facilitated the quantification of the overall emissions from a given emission source.