Monday, March 26, 2018
In the US market, there are over 20 companies aggressively marketing “Combustors” for the US Upstream market with various claims about performance, EPA NSPS 0000a “Compliant” designs and/or EPA NSPS 0000a “Certified” designs. With all of the mixed messages, what do you really need to know, and what do you need to consider so that you don’t place your company at risk or in violation of the environmental regulations?
As background, new NSPS OOOOa (QuadOa) regulations were announced on June 3, 2016 that affected Enclosed Combustion Devices (a.k.a Combustors) used as an air emissions control device in storage vessels/tanks for upstream and midstream Oil &Gas facilities. Some key issues that everyone should consider include:
- Optional testing of the Combustor can be done by the manufacturer following rules in NSPS 0000 (60.5413): Tested Combustors must be listed in the EPA list of tested devices. A “YES” in the EPA list means that the manufacturer has demonstrated that the specific model of control device listed achieves the combustion control device performance requirements in NSPS subpart 0000 or in other words is CERTIFIED. The direct link to the EPA site is:
- An operator who uses a device listed as “YES” is exempt from conducting performance/source emission tests under 40CFR 60.5413(a)(7), 63.772(e) and/or 63.1282(d), and from submitting test results under 40CFR 605413(e)(6), 63.775(d)(1)(ii) and/or 63.1285(d)(1)(ii), as applicable.
- VCUs not stack tested by the manufacturer and/or not approved by the EPA , even if they are marketed as “EPA Compliant Designs” must have in-field stack emission testing completed (approximately a $7,000 test) within 180 days of installation and test results filed with the EPA. After initial testing, these non-EPA Certified combustors must also have in-field emission/source testing completed every 60 months.
So, choosing an “EPA Certified” combustor can greatly reduce the emission testing requirements that you are liable to conduct after initial installation, and every 5 years there-after. But it’s not just the emission testing requirements that you can avoid by buying “EPA Certified”………It’s also the reduction of risk of a failed emission/source test in the field-- What happens when the field emission test does not pass and you have to replace or upgrade the combustor, and potentially re-test again?
In summary, buying “Certified” can greatly reduce your costs, workload and risks and it seems like a “No-brainer”. But the reality across the upstream market is that many operators may inadvertently try and save a few dollars by buying a non-certified combustor, and hope that a “Compliant design” will negate the need to do emission tests and EPA reporting. Is it really worth the risk?