New Year’s Resolutions for Compressor Stations

I recently found myself pulling my car over to the side of the road with a flat tire.  I remember thinking “Good thing I have that emergency kit in the trunk of my car”. Sadly, as I inspected the contents of the kit, I realized that what was actually in there was a lot different than what I had remembered being in there from several years ago, and of little help for a flat tire.  Something similar could happen to operators of compressor stations.  When was the last time you reviewed the equipment located at your compressor station?  A lot can happen in five years.  Don’t let yourself get stuck with a false sense of security.  Make it a part of your New Year’s resolutions to take an extra look at your facility’s equipment as it relates to your minor or major operating permit.  We will even offer you some “AAA roadside assistance”; here are a few things to get you started:

Perform A Detailed Site Inventory 

Equipment is often constructed, modified, or reconstructed over the course of five (5) years.  It is important to reconcile what you have listed in your facility’s permit, with what is actually located on-site.

Examine the Major/Minor Source Determination of Your Facility  

Just as was stated above, equipment is often constructed, modified, or reconstructed over the course of five (5) years.  Is your facility still considered a natural minor source? Or should it be redefined as a synthetic minor source?  Taking the time to look back over the definitions of natural and synthetic minor sources, and major source, is important.  Gather back-up information to continually support the classification of your facility.

Read Up On RICE MACT

More than likely when your facility’s original operating permit was issued, the most recent version of 40 CFR Part 63 Subpart  ZZZZ (National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines (RICE MACT)) was not finalized.  Look at the detailed site inventory that you’ve created and determine if you operate a RICE.  If you do, it’s time to get familiar with RICE MACT and determine what requirements you might be required to comply with.

Dive Into Subpart OOOO

40 CFR Part 60 Subpart OOOO (Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution) was finalized on August 2, 2013.  Have you installed new equipment since August 23, 2011?  If so, you may be subject to the requirements of this regulation.  

BONUS RESOLUTION: Keep Up With GHG Reporting

As long as you are checking the requirements in your facility’s operating permit, it may be worthwhile to take a look at your facility’s reporting requirements for greenhouse gases (GHG).  The methane (CH₄) Global Warming Potential (GWP) was recently increased from 21 to 25 and the nitrous oxide (N₂O) GWP was recently decreased from 310 to 298.  Calculations for your facility will need updating!

Consider these few steps for 2014 and avoid the pitfalls of being surprised by what your find at your compressor station.