Overview of EPA’s Quad O Standard

The Environmental Protection Agency (EPA) estimates that the upstream and midstream segments of the oil and gas industry account for nearly 40 percent of volatile organic compound (VOC) emissions in the United States. As a result, the agency has proposed strict regulations on facilities that use storage vessels.

Air pollution is a serious issue for oil and gas industry professionals, so the monitoring of emissions regulations is a priority and a constant concern.

Due to a lack of regulations regarding storage vessels, the EPA proposed new standards, commonly referred to as 40 CFR 60, Subpart OOOO (Quad O), which took effect on Oct. 15, 2012, and have a one-year compliance phase.

Facilities with a Potential to Emit (PTE) of greater than six tons of VOCs yearly must install one of three approved control devices: a standard flare, an enclosed combustor, or a vapor recovery device. The standard flare must meet both 40 CFR 60.18 and Method 22A (producing no smoke from the device). The New Source Performance Standard (NSPS) in 40 CFR Part 60, Subpart Quad O, requires all combustion control devices to reduce emissions to less than six tons yearly with a 95 percent destruction and removal efficiency (DRE).

The standard also includes testing requirements. Facilities must have devices tested and retested by a third party at regular intervals, which are commonly interpreted as 180 days upon installation and startup, and within five-year intervals thereafter, or, the manufacturer provides third-party testing. Continue reading “Overview of EPA’s Quad O Standard”