OOOOa Compliance Required (Again)

August 7, 2017

“EPA’s decision to impose a stay…was ‘arbitrary, capricious, [and] excess of [its]…statutory…authority.’ 42 U.S.C. § 7607(d)(9)(A),(C). We shall therefore grant Environmental Petitioner’s motion to vacate the stay.”

-US Court of Appeals, DC Circuit

With those words from Clean Air Council vs. Scott Pruitt, a US Appeals Court resurrected 40 CFR Part 60, Subpart OOOOa, affectionately known as “Quad-Oh-A”.

For those unfamiliar with the rule, NSPS OOOOa is an amendment to the original OOOO (“Quad-Oh”) regulation governing air emissions from oil and gas production facilities. It affects well facilities constructed, modified, or reconstructed after September 18, 2015 and has a compliance deadline of August 31, 2017. This means every well drilled, fracked, or refracked after this date must be in compliance.

On June 5, 2017, Scott Pruitt’s EPA stayed the implementation of this rule for reconsideration. However, the Clean Air Act gives strict guidelines for both the creation and elimination of EPA rules, and the process is not quick to say the least. After the stay, a court challenge ensued with the courts overturning the stay some 30 days later, putting OOOOa right back where it was with its compliance deadline intact.

The rule has several parts; among them is a required certification by a licensed professional engineer (PE) of vent systems for atmospheric tanks. This part of the rule seeks to address uncontrolled emissions out of relief devices at storage tanks. One cause of these uncontrolled emissions could be excessive pressure drop in vent systems. Every facility constructed, modified, or reconstructed after September 18, 2015 must have the vent systems evaluated by a PE, and the current design must be stamped and certified.

At BR&E, our objective is to take arduous tasks and make them easy for our clients. In the case of OOOOa vent system certification, we have done so with our new OOOOa Vent Assessment Tool™. This tool steps engineers quickly and efficiently through the required calculations and helps determine whether vent systems are large enough to handle the amount of flash gas being produced. This is available free to all of our clients and can be downloaded at the following link:

As with anything else related to ProMax, our technical service and support staff are ready to assist you however possible at no charge. Give us a call at 1-979-776-5220 and let us help you!