          Control Device Requirements for Gas-Driven Pneumatic Pumps
                           Revised: October 8, 2015
                                       
Per 60.5360a(h)(2), only pneumatic pumps (not a natural gas processing plant) at a site where a control device is located are considered "affected facilities". Per 60.5360a(a)(3), refracturing of a well does not affect the modification status of pneumatic pumps.
Initial compliance demonstration for pumps in 60.5410a(e) requires that each pump affected facility be tagged, listed in the initial annual report, records maintained for 5 years, and if the pump is not routed to a control device you must certify to this to the EPA.  Additional initial compliance in 60.5411a(a) requires that the closed vent system be designed to route all gases to the control device or to a process, have no detectable emissions as determined by Method 21*, repair any leaks (first attempt w/in 5 days, repair completed w/in 15 days), and meet bypass device requirements (install meter and use an alarm or use a lock). 
                                Control Device
              Performance Specifications (60.5412a(a) & (b))
                  Performance Testing Requirements (60.5413a)
                    Compliance Demonstration (60.5415a(b))
                      Inspection Requirements (60.5416a)
                      Monitoring Requirements (60.5417a)
Flare meeting 40 CFR 60.18(b)
   *    Operate in accordance with 40 CFR 60.18(b)
   *    Operate at all times when gases, vapors, and fumes are vented from the pump(s) through a closed vent system.
   *    Exempt from performance testing requirements provided you use a flare that meets 40 CFR 60.18(b)
   *    However, must still verify that there are no visible emissions using Method 22*
   *    Reduce methane and VOC by >95%
   *    Monitoring system must be operating whenever the pumps are operating
   *    Submit an annual report and maintain records as specified in 60.5420a(b) and (c)

   *    Conduct initial Method 21* inspection of closed vent system connections that are welded or bolted & gasketed to ensure no leaks
   *    Conduct annual visual inspection of closed vent system connections that are welded or bolted & gasketed to verify integrity (i.e. no  cracks, holes, liquid leaks, etc.)
   *    Following any repairs, replacements, or if the connection is unsealed, must conduct a Method 21* inspection
   *    Conduct initial Method 21* inspection of all other closed vent system components (e.g. pressure or vacuum valves)
   *    Conduct annual Method 21* inspection of all other closed vent system components (e.g. pressure or vacuum valves)
   *    Conduct annual visual inspection of all other closed vent system components (e.g. pressure or vacuum valves) to verify integrity (i.e. no cracks, holes, liquid leaks, etc.)
   *    Conduct initial visual inspection of each cover to verify integrity (i.e. no  cracks, holes, liquid leaks, etc.), with annual inspection thereafter
   *    If cover or system has a bypass device with flowmeter  -   take readings at least once every 15 minutes
   *    If cover or system has a bypass device with car-seal or lock  -  visually inspect seal or lock once per month to ensure valve is in non-diverting position
   *    First attempt to repair leaks must be made in 5 calendar days, complete the repair w/in 15 days
   *    If install 60.18(b) flare, then exempt from calculating daily average value for each monitored parameter and exempt from establishing min & max operating parameter values, must still meet all other requirements below
   *    Monitoring system must measure & record values at least 1 per hour
   *    Prepare site-specific monitoring plan that covers system design, data collection, and QA/QC.
   *    Install, calibrate, operate & maintain the system in accordance with the plan 
   *    Conduct system equipment performance checks & accuracy audits per the plan at least every 12 months
   *    Conduct a performance evaluation of the system per the plan 
   *    Install, calibrate, operate & maintain one of the following:
         o    A heat sensing device with a continuous recorder that indicates continuous ignition of pilot flame.
                                         Or
         o       An organic monitoring device equipped with a continuous recorder that measures concentration of organic compounds in the exhaust.
                                         Or
         o       Request approval from EPA to monitor operating parameters other than those above.
Combustion Device (non-manu-facturer certified)
   

   *    Reduce the mass content of methane and VOC by weight >95.0%
                                      or
   Reduce concentration of TOC <=600 ppm
                                      or
   Operate at min temperature of 760°C for devices that can demonstrate a uniform combustion zone temp
                                      or
   If using boiler or process heater then introduce vent stream into the flame zone

   * Operate at all times when gases, vapors, and fumes are vented from the pump(s) through a closed vent system.
   * Conduct performance test within 180 days after initial startup
   * Conduct subsequent periodic performance tests no longer than 60 months from the last test; periodic performance tests are not required if you establish a correlation between combustion chamber temperature & emission reduction performance level
   * Select appropriate sampling sites at the inlet and outlet of the device per Method 1 or 1A of Appendix A
   * Use appropriate Method to determine stack gas velocity and volumetric flowrate per Method 2, 2A, 2C, or 2D of Appendix A
   * Use appropriate Method to determine percent emission reduction performance per Method 25A of Appendix A
   * Take at least 4 samples per hour

Boiler or process heater is exempt if:
                 *    Vent streams are introduced with the primary fuel or used as the primary fuel
                 *    Design heat input is > 44 MW
                 *    Reduce methane and VOC by >95%
                 *    Operate within established min & max operating parameters
                 *    Calculate daily average of monitored parameter (temperature only, do not have to average inlet gas flowrate)
                 *    Monitoring system must be operating whenever the pumps are operating
                 *    Pilot flame must be present at all times the pumps are operating
                 *    Conduct 15 minute visible emissions test using Method 22* once every calendar month
                 *    If fail visible emissions test, repair per manufacturer instructions or maintenance plan
                 *    Keep records of repairs & maintenance
                 *    Following return to operation conduct visible emissions test
                 *    Submit an annual report and maintain records as specified in 60.5420a(b) and (c)
   
   *    Conduct initial Method 21* inspection of closed vent system connections that are welded or bolted & gasketed to ensure no leaks
   *    Conduct annual visual inspection of closed vent system connections that are welded or bolted & gasketed to verify integrity (i.e. no  cracks, holes, liquid leaks, etc.)
   *    Following any repairs, replacements, or if the connection is unsealed, must conduct a Method 21* inspection
   *    Conduct initial Method 21* inspection of all other closed vent system components (e.g. pressure or vacuum valves)
   *    Conduct annual Method 21* inspection of all other closed vent system components (e.g. pressure or vacuum valves)
   *    Conduct annual visual inspection of all other closed vent system components (e.g. pressure or vacuum valves) to verify integrity (i.e. no cracks, holes, liquid leaks, etc.)
   *    Conduct initial visual inspection of each cover to verify integrity (i.e. no  cracks, holes, liquid leaks, etc.), with annual inspection thereafter
   *    If cover or system has a bypass device with flowmeter  -   take readings at least once every 15 minutes
   *    If cover or system has a bypass device with car-seal or lock  -  visually inspect seal or lock once per month to ensure valve is in non-diverting position
   *    First attempt to repair leaks must be made in 5 calendar days, complete the repair w/in 15 days
                 * Monitoring system must measure & record values at least 1 per hour
                 * Prepare site-specific monitoring plan that covers system design, data collection, and QA/QC
                 * Conduct system equipment performance checks & accuracy audits per the plan at least every 12 months
                 * Conduct a performance evaluation of the system per the plan 
                 * Install, calibrate, operate & maintain one of the following:
                       o       A temperature monitoring device with a continuous data recorder that has a minimum accuracy of +1 percent of the temperature being monitored in [o]C, or +2.5[o]C.  
                                         Or
                       o       An organic monitoring device equipped with a continuous recorder that measures concentration of organic compounds in the exhaust.
                                         Or
                       o       Request approval from EPA to monitor operator parameters other than those above. 
      
                 * Establish min and max operating parameters

Boiler or Process Heaters are exempt if:
                 * Vent streams are introduced with the primary fuel or used as the primary fuel
                 * Design heat input is > 44 MW
Manu-facturer Certified Combustion Device
   *    Exempt from initial compliance requirements in 60.5412a, but still have to meet certain performance testing requirements in 60.5413a
   *    Operate at all times when gases, vapors, and fumes are vented from the pump(s)

   * Exempt from performance testing & design analysis requirements
   * Inlet gas cannot exceed manufacturer recommended rates
   * Pilot flame must be present at all times of operation
   * Conduct 15 minute visible emissions test using Method 22* once every calendar month
   * If fail visible emissions test, repair per manufacturer instructions or maintenance plan
   * Keep records of repairs & maintenance
   * Following return to operation conduct visible emissions test
   * Maintain in a leak free condition

                 *    Reduce methane and VOC by >95%
                 *    Operate according to requirements in 60.5413a (see requirements in column to the left)
                 *    Calculate daily average of monitored parameter (temperature only, do not have to average inlet gas flowrate)
                 *    Monitoring system must be operating whenever the pumps are operating
                 *    Pilot flame must be present at all times the pumps are operating
                 *    Conduct 15 minute visible emissions test using Method 22* once every calendar month
                 *    If fail visible emissions test, repair per manufacturer instructions or maintenance plan
                 *    Keep records of repairs & maintenance
                 *    Following return to operation conduct visible emissions test
                 *    Submit an annual report and maintain records as specified in 60.5420a(b) and (c)
   
   *    Conduct initial Method 21* inspection of closed vent system connections that are welded or bolted & gasketed to ensure no leaks
   *    Conduct annual visual inspection of closed vent system connections that are welded or bolted & gasketed to verify integrity (i.e. no  cracks, holes, liquid leaks, etc.)
   *    Following any repairs, replacements, or if the connection is unsealed, must conduct a Method 21* inspection
   *    Conduct initial Method 21* inspection of all other closed vent system components (e.g. pressure or vacuum valves)
   *    Conduct annual Method 21* inspection of all other closed vent system components (e.g. pressure or vacuum valves)
   *    Conduct annual visual inspection of all other closed vent system components (e.g. pressure or vacuum valves) to verify integrity (i.e. no cracks, holes, liquid leaks, etc.)
   *    Conduct initial visual inspection of each cover to verify integrity (i.e. no  cracks, holes, liquid leaks, etc.), with annual inspection thereafter
   *    If cover or system has a bypass device with flowmeter  -   take readings at least once every 15 minutes
   *    If cover or system has a bypass device with car-seal or lock  -  visually inspect seal or lock once per month to ensure valve is in non-diverting position
   *    First attempt to repair leaks must be made in 5 calendar days, complete the repair w/in 15 days
                 * Monitoring system must measure & record values at least 1 per hour
                 * Prepare site-specific monitoring plan that covers system design, data collection, and QA/QC
                 * Conduct system equipment performance checks & accuracy audits per the plan at least every 12 months
                 * Conduct a performance evaluation of the system per the plan
                 * Install, calibrate, operate & maintain one of the following: 
         o       A continuous monitoring system that measures gas flow rate at inlet to control device (accuracy of +2% or better; flow rate cannot be outside manufacturer recommended rates); and indicate continuous operation of a pilot flame.
            Or
                       o       An organic monitoring device equipped with a continuous recorder that measures concentration of organic compounds in the exhaust.
                                         Or
                       o       Request approval from EPA to monitor operating parameters other than those above.
      
                 * Establish min and max operating parameters

Boiler or Process Heaters are exempt if:
                 *    Vent streams are introduced with the primary fuel or used as the primary fuel
                 *    Design heat input is > 44 MW

* Method 21 requires use of a detector that can determine gaseous leak concentrations, since FLIR cameras cannot determine leak concentrations they cannot meet Method 21 (http://www3.epa.gov/ttn/emc/promgate/m-21.pdf). Method 22 is used to determine visible fugitive leaks and smoke from flares, the observer does not have to be certified but must be trained and knowledgeable regarding the effects of background contrast, ambient lighting, observer position relative to lighting, wind, and the presence of uncombined water (condensing water vapor) on the visibility of emissions (http://www3.epa.gov/ttn/emc/promgate/m-22.pdf).
