ESE was engaged by a major Exploration and Production (E&P) company with the development and implementation of an Audio, Visual and Olfactory (AVO) program with 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 Basin.
APPROACH
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; and broken or missing hatches, access covers, or other closure devices.
In addition, NRSP permit requires applicable facilities to install, check, and properly maintain all the seals and gaskets in VOC or H2S service to prevent leaking. The components are required to be physically inspected quarterly for leaks.
BENEFITS
Development of a robust inspection and maintenance program allowed the client to identify leaks during the initial stages, preventing future catastrophic spills and leaks.
An Inspection and Recordkeeping program ensured that the client was compliant 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.
