-----Original Message-----
From: Howard, Jodi 
Sent: Tuesday, January 26, 2016 3:39 PM
To: 'Cal Niss'
Cc: Jay Christopher; Moore, Bruce
Subject: RE: NSPS OOOOa - Proposed Rule

Calvin,

We proposed, in 40 CFR 60.5397a that the fugitive (VOC and methane) emissions standards are applicable to an affected facility, the collection of fugitive emissions components at a well site, as defined in 40 CFR 60.5365a(i), and the collection of fugitive emissions components at a compressor station, as defined in 40 CFR 60.5365a(j). See 40 CFR 60.5430a for the definitions of well site and compressor station.

The affected facilities, the group of all equipment (except compressors) within a process unit, at onshore natural gas processing plants are subject to the LDAR VOC and methane standards in 40 CFR 40.5400a, 40 CFR 40.5401a, and 40 CFR 40.5402a. See 40 CFR 60.5430a for process unit and equipment definitions.

Thanks.



-----Original Message-----
From: Cal Niss [mailto:cniss@trihydro.com] 
Sent: Tuesday, January 26, 2016 2:38 PM
To: Howard, Jodi
Cc: Jay Christopher
Subject: NSPS OOOOa - Proposed Rule

Jodi-

How are you ?  We are preparing presentation materials for upcoming conferences involving LDAR requirements under NSPS OOOOa.  As such, we wanted some clarification as to whether components  in methane service at natural gas processing plants that are either newly constructed or modified after 8/2015 would be subject to monitoring.  There is some confusion and disagreement in the industry.

Thanks-

Calvin Niss

Sent from my iPhone

