Section R. 336.1642 - Emission of volatile organic compounds from existing pneumatic pumps in the oil and natural gas industry located in the 2015 ozone nonattainment areasRule 642.
(1) As used in this rule, "pneumatic pump" means a positive displacement reciprocating unit driven by natural gas used for injecting precise amounts of chemicals into a process stream or for freeze protection glycol circulation.(2) A person shall not cause or allow the emission of any volatile organic compound associated with oil and natural gas production and natural gas processing segments of the oil and natural gas industry in excess of the limitations of this rule from the use of existing single natural gas driven pneumatic pumps when the pumps are both of the following:(a) Located inside the 2015 ozone nonattainment area.(b) Utilized at a natural gas processing plant or well site.(3) Except as required in subrule (6), the provisions of this rule do not apply to a pneumatic pump that is either of the following:(a) If it is determined through an engineering assessment that routing a pneumatic pump to a control device or a process is technically infeasible due to insufficient gas pressure or control device capacity, including the event in which there is no control device or in which the control device or process is removed from the site, the following provisions must be met:(i) An assessment of technical infeasibility must be conducted and must include, but is not limited to, safety considerations, distance from the control device, pressure losses and differentials in the closed vent system, and the ability of the control device to handle the pneumatic pump emissions which are routed to them. This assessment must be prepared under supervision of a qualified professional engineer as approved in 40 CFR 60.5393a.(ii) The professional engineer shall sign and certify this prepared assessment.(b) In operation less than 90 days per calendar year. For purposes of this rule, any period of operation during a calendar day counts toward the 90-day annual threshold.(4) A person shall not cause or allow the emission of any volatile organic compound from pneumatic pumps, unless the following provisions are met:(a) At natural gas processing plants, zero emissions or 100% control from each diaphragm pump by use of a control device or instrument air system in place of the natural gas-driven pump.(b) At a well site, emissions from each existing diaphragm pump with control devices, must be reduced by 95% by weight or greater as determined by subrule (5) of this rule, or, if 95% control is not achievable, by the maximum control efficiency possible as described in subrule (6) of this rule.(c) At a well site that installs a control device after March 1, 2023, the emissions from the pneumatic pump must be captured and routed to the control device.(d) If reducing emissions by use of a control device or by routing to a process, the pneumatic pump must connect emissions through a closed vent system meeting the requirements of R 336.1640(4)(b)(ii).(5) Compliance with this rule must be determined as follows: (a) All pneumatic pumps must be tagged with an identifying marker to allow tracking for reporting as described in subrule (6) of this rule.(b) Initial performance and compliance testing must be conducted in accordance with a stack testing protocol, or alternative testing protocol, approved by the department.(c) All control devices must have an approvable operation and maintenance plan that contains, at a minimum, the following:(i) A schedule of maintenance for the control devices in use.(ii) An inspection schedule at least once every calendar month.(iii) Written instructions from the manufacturer.(6) A person operating a pneumatic pump subject to this rule shall obtain current information and maintain records for all requirements in sufficient detail to determine compliance. The records must be made available to the department upon request and must include the following, as appropriate:(a) Notes of all pumps with control, and the respective control efficiencies, as determined by the performance test used in subrule (5) of this rule, that may include a stack test, calibrated bag test, or engineering calculations.(b) For all pumps with a control efficiency less than the control efficiency required by subrule (4) of this rule, infeasibility of meeting applicable criteria for capture and control for any uncontrolled pump which may include factors such as safety, distance, pressure losses and differentials, and the capacity of any available existing control device, to show that subrule (4) of this rule is not attainable.(c) For all pumps at well sites without controls, a statement of confirmation that no control device has been installed.(d) Before March 1, 2023, an initial report must be submitted to the department describing initial compliance.(e) A report must be submitted to the department if a control device is installed on site after March 1, 2023.Mich. Admin. Code R. 336.1642
2023 MR 8, Eff. 4/18/2023