Learn More About Recent Air Regulatory Changes

With first quarter behind us, Oklahoma and the EPA have wasted no time in rolling out a few changes that will affect us moving forward.

1. Effective March 15, 2021, the Oklahoma Department of Environmental Quality (DEQ) requires a new form for ALL oil and gas applications (PBR, OGF, TV, etc.) to document the representative samples.

• The move it is to encourage the use of more recent and local representative samples when actual samples are not available.
• In some cases, actual samples from the location may be required for operating applications.
• To learn more, visit the DEQ website

2. Effective April 15, 2021, the DEQ will no longer accept working and breathing calculations for water that use 1% (1% may still be applied to water flash and loading).

• Updates to AP-42 in November 2019 (and subsequent updates in March and June 2020), note that if water tanks are allowed to settle, and oil to separate on top, the calculations must be based on 100% oil.
• If you feel you have an exception to this (SWD, high production, constant turnover) you can request a site-specific exception from the DEQ.
• To learn more, visit the EPA website and the DEQ website

3. The EPA has finalized the OOOOa reporting template. This means that as of July 7, 2021, annual OOOOa reports must be reported through CEDRI using this template (due October 31st).

• There are a few changes from the previous workbook, including reporting of BOE for each well.
• OOOOa Annual Report Template
• To learn more, visit the EPA website

In Case You Missed It:

1. EPA updated NSPS OOOOa in September 2020.

• Operators now have 90 days for initial fugitive leak inspections.
• Some low producing wells can become exempt from fugitive leak inspections if production is below 15 BOE average for 12 months. If production increase, it will need to be resumed.
• Compressor stations now only are required to have semi-annual fugitive leak inspections, instead of the previous quarterly inspections.
• Clarifying language in the supporting documents noted that if you are requesting Federally Enforceable Limits (FELs) on storage tanks, you should show 100% capture efficiency at the tanks and at least 95% destruction at the control.
• PE certifications have been relaxed to allow an engineer in the company to approve closed vent systems.
• To learn more, visit the EPA website

If you have any questions, or need any assistance, we are always here to help! Contact us at info@altamira-us.com to learn more.