Body RP 50 Natural Gas Processing Plant Practices for Protection of the Environment API RECOMMENDED PRACTICE 50 SECOND EDITION, DECEMBER 1995 REAFFIRMED, JANUARY 2013 Copyright American Petroleum Inst[.]
Natural Gas Processing Plant Practices for Protection of the Environment API RECOMMENDED PRACTICE 50 SECOND EDITION, DECEMBER 1995 REAFFIRMED, JANUARY 2013 `,,```,,,,````-`-`,,`,,`,`,,` - Copyright American Petroleum Institute Provided by IHS under license with API No reproduction or networking permitted without license from IHS Not for Resale `,,```,,,,````-`-`,,`,,`,`,,` - Copyright American Petroleum Institute Provided by IHS under license with API No reproduction or networking permitted without license from IHS Not for Resale Natural Gas Processing Plant Practices for Protection of the Environment Exploration and Production Department API RECOMMENDED PRACTICE 50 SECOND EDITION, DECEMBER 1995 `,,```,,,,````-`-`,,`,,`,`,,` - REAFFIRMED, JANUARY 2013 Copyright American Petroleum Institute Provided by IHS under license with API No reproduction or networking permitted without license from IHS Not for Resale SPECIAL NOTES API publications necessarily address problems of a general nature With respect to particular circumstances, local, state, and federal laws and regulations should be reviewed API is not undertaking to meet the duties of employers, manufacturers, or suppliers to warn and properly train and equip their employees, and others exposed, concerning health and safety risks and precautions, nor undertaking their obligations under local, state, or federal laws Information concerning safety and health risks and proper precautions with respect to particular materials and conditions should be obtained from the employer, the manufacturer or supplier of that material, or the material safety data sheet Nothing contained in any API publication is to be construed as granting any right, by implication or otherwise, for the manufacture, sale, or use of any method, apparatus, or product covered by letters patent Neither should anything contained in the publication be construed as insuring anyone against liability for infringement of letters patent This document was produced under API standardization procedures that ensure appropriate notification and participation in the developmental process and is designed as an API standard Questions concerning the interpretation of the content of this standard or comments and questions concerning the procedures under which this standard was developed should be directed in writing to the Director, Exploration & Production Department, American Petroleum Institute, 1220 L Street, N.W., Washington, D.C 20005 Requests for permission to reproduce or translate all or any part of the material published herein should also be addressed to the Director API publications may be used by anyone desiring to so Every effort has been made by the Institute to assure the accuracy and reliability of the data contained in them; however, the Institute makes no representation, warranty, or guarantee in connection with this publication and hereby expressly disclaims any liability or responsibility for loss or damage resulting from its use or for the violation of any federal, state, or municipal regulation with which this publication may conflict API standards are published to facilitate the broad availability of proven, sound engineering and operating practices These standards are not intended to obviate the need for applying sound engineering judgment regarding when and where these standards should be utilized The formulation and publication of API standards is not intended in any way to inhibit anyone from using any other practices Any manufacturer marking equipment or materials in conformance with the marking requirements of an API standard is solely responsible for complying with all the applicable requirements of that standard API does not represent, warrant, or guarantee that such products in fact conform to the applicable API standard Copyright © 1995 American Petroleum Institute Copyright American Petroleum Institute Provided by IHS under license with API No reproduction or networking permitted without license from IHS Not for Resale `,,```,,,,````-`-`,,`,,`,`,,` - Generally, API standards are reviewed and revised, reaffirmed, or withdrawn at least every five years Sometimes a one-time extension of up to two years will be added to this review cycle This publication will no longer be in effect five years after its publication date as an operative API standard, or where an extension has been granted, upon republication Status of the publication can be ascertained from the API Exploration & Production Department, 1220 L Street, N.W., Washington, D.C 20005 A catalog of API publications and materials is published annually and updated quarterly by API, 1220 L Street, N.W., Washington, D.C 20005 CONTENTS Page INTRODUCTION 1 SCOPE REFERENCES 2.1 Standards 2.2 Other References DEFINITIONS REGULATORY COMPLIANCE 4.1 Introduction 4.2 Environmental Agencies 4.3 Environmental Laws and Regulations 4.4 Notification and Reporting 4.5 Environmental Training and Review 4 4 SURFACE AND GROUNDWATER 5.1 Introduction 5.2 NPDES Introduction 5.3 Subsurface Disposal 5.4 Spill Prevention 5.5 Sanitary Systems 9 10 11 13 AIR EMISSIONS 6.1 Introduction 6.2 General 6.3 Prevention of Significant Deterioration (PSD) 6.4 Ozone Nonattainment Area 6.5 Permitting, NSPS Requirements, and Standard Exemptions 6.6 Air Toxics 6.7 National Emissions Standards for Hazardous Air Pollutants (NESHAPS) 6.8 Emission Units 13 13 13 13 14 14 15 15 15 SOLID WASTE MANAGEMENT 7.1 Introduction 7.2 General Waste Management Guidance 7.3 RCRA Waste Characterization 7.4 Disposal Topics 16 16 17 17 18 RELEASE REPORTING 8.1 Introduction 8.2 Scope 8.3 Clean Water Act 8.4 The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) 8.5 EPCRA (SARA Title III) 8.6 Exempted/Permitted Releases 8.7 Process Upsets 8.8 Material Safety Data Sheet (MSDS) 19 19 19 19 `,,```,,,,````-`-`,,`,,`,`,,` - Copyright American Petroleum Institute Provided by IHS under license with API No reproduction or networking permitted without license from IHS iii Not for Resale 20 21 21 21 21 SITE CLOSURE AND RESTORATION 9.1 Introduction 9.2 Preplanning 9.3 Site Restoration 9.4 Property Transfer 21 21 21 22 23 Tables 1—Ozone Nonattainment Criteria 14 2—Common Hazardous Pollutants for Gas Plants 15 `,,```,,,,````-`-`,,`,,`,`,,` - iv Copyright American Petroleum Institute Provided by IHS under license with API No reproduction or networking permitted without license from IHS Not for Resale FOREWORD `,,```,,,,````-`-`,,`,,`,`,,` - RP 50, First Edition was issued January 1975 (Reissued May 1982) These recommended practices were prepared by the API Subcommittee on Gas Plant Practices for Protection of the Environment This standard is under administration of the American Petroleum Institute Exploration & Production Department’s Executive Committee on Drilling and Production Practices It is intended that these voluntary recommended practices serve as a guide to promote protection of the environment in gas processing plant operations Users of this publication are reminded that constantly developing technology, specific company requirements and policy, and specialized or limited operations not permit coverage of all possible operations, practices, or alternatives This standard is not so comprehensive as to present all possible practices for protecting the environment in gas processing plant operations Alternative operating procedures and/or equipment are available and routinely used to meet or exceed recommended practices or performance levels set forth herein Recommendations presented in this publication are not intended to inhibit developing technology and equipment improvements or improved operating procedures This publication, or portions thereof, cannot be substituted for qualified technical/operations analysis and judgment to fit a specific situation There may be federal, state, or local statutes, rules, or regulations requiring gas processing plant operations to be conducted in a certain manner Organizations or individuals using this standard are cautioned that requirements of federal, state, or local environmental laws and regulations are constantly evolving and should be reviewed to determine whether or not the practices recommended herein are consistent with current laws and regulations Gas processing plant operations must comply with the applicable requirements of federal, state, or local regulations API publications may be used by anyone desiring to so Every effort has been made by the Institute to assure the accuracy and reliability of the data contained in them; however, the Institute makes no representation, warranty, or guarantee in connection with this publication and hereby expressly disclaims any liability or responsibility for loss or damage resulting from its use or for the violation of any federal, state, or municipal regulation with which this publication may conflict Suggested revisions are invited and should be submitted to the director of the Exploration and Production Department, American Petroleum Institute, 1220 L Street, N.W., Washington, D.C 20005 v Copyright American Petroleum Institute Provided by IHS under license with API No reproduction or networking permitted without license from IHS Not for Resale `,,```,,,,````-`-`,,`,,`,`,,` - Copyright American Petroleum Institute Provided by IHS under license with API No reproduction or networking permitted without license from IHS Not for Resale Introduction API Environmental Guidance Document: Onshore Solid Waste Management in Exploration and Production Operations Bull D16 Suggested Procedure for Development of Spill Prevention, Control, and Countermeasure Plans Bull E1 Generic Hazardous Chemical Category List and Inventory for the Oil and Gas Exploration and Production Industry Bull E2 Bulletin on Management of Naturally Occurring Radioactive Materials (NORM) in Oil and Gas Production Bull E4 Environmental Guidance Document: Release Reporting for the Oil and Gas Exploration and Production Industry as Required by the CWA, CERCLA, and SARA Title III GPA1 It is important that environmental issues relating to processes and equipment be given high priority in the initial planning or modification of natural gas processing plants The selection of certain processes or equipment can have a significant impact on emissions and waste generation, thereby affecting permitting, regulatory compliance, monitoring, and disposal This publication is intended to assist gas plant operators in understanding their environmental responsibilities It is intended to be used primarily by environmental, engineering, and operations personnel and management involved in building, maintaining, modifying, and operating gas processing plants There are numerous federal, state, and local environmental statutes, rules, and regulations that deal directly or indirectly with environmental issues that may impact gas processing plant operations Site-specific permits, notification, and documentation may be required 8162-70 8166-70 Scope 2.2 2.1 2.2.1 Regulations EPA2 40 Code of Federal Regulations Part 51 40 Code of Federal Regulations Part 52 40 Code of Federal Regulations Part 60 40 Code of Federal Regulations Subchapter C, Part 61 40 Code of Federal Regulations Part 110 40 Code of Federal Regulations Part 112 40 Code of Federal Regulations Part 116.4 40 Code of Federal Regulations Part 122 40 Code of Federal Regulations Part 144 40 Code of Federal Regulations Part 146.5 40 Code of Federal Regulations Part 147 References STANDARDS The following standards contain provisions which, through reference in this text, constitute provisions of this standard All standards are subject to revision, and users are encouraged to investigate the possibility of applying the most recent editions of the standards indicated below 1Gas Processors Association, 6526 East 60th Street, Tulsa, Oklahoma 74145 2Environmental Protection Agency The Code of Federal Regulations and Federal Register are available from U.S Government Printing Office, Washington, D.C 20402 Copyright American Petroleum Institute Provided by IHS under license with API No reproduction or networking permitted without license from IHS OTHER REFERENCES There are numerous federal regulations and laws that may be applicable to gas processing plant operations These regulations and laws should be carefully studied to determine their impact on and applicability to specific operations The following are some of the major regulations and laws that apply Operations within the scope of this standard include natural gas processing and associated gas compression facilities The publication coverage begins with initial plant planning, permitting, and construction and ends with plant closure and site restoration procedures General guidelines are provided to be used at gas plant locations to develop sitespecific environmental programs This standard does not address safety or operational issues except where environmental, safety, and operational issues are intertwined Process design and equipment selection are not addressed in detail This publication does not specifically address requirements of process safety management (refer to 29 CFR Part 1910.119) that must be considered in gas plant design and operations LP-Gas Loading Practices Manual Manual for Driver-Attended Loading of LPGas Not for Resale `,,```,,,,````-`-`,,`,,`,`,,` - Natural Gas Processing Plant Practices for Protection of the Environment API RECOMMENDED PRACTICE 50 40 Code of Federal Regulations Subpart C, Parts 261.20 through 261.24 40 Code of Federal Regulations Part 302 40 Code of Federal Regulations Part 302.4 40 Code of Federal Regulations Part 355 53 Federal Register 25446, July 6, 1988 DOT3 44 Code of Federal Regulations Part 192 OSHA4 29 Code of Federal Regulations Part 1910.119 29 Code of Federal Regulations Part 1910.120 29 Code of Federal Regulations Part 1910.1000 29 Code of Federal Regulations Part 1910.1200 2.2.2 Legislative5 Clean Air Act (as amended) (CAA) Clean Air Act Amendments of 1990 (CAA-90) National Ambient Air Quality Standards (NAAQS) Clean Water Act (as amended) (CWA) Safe Drinking Water Act (as amended) (SDWA) Resource Conservation and Recovery Act (as amended) (RCRA) Comprehensive Environmental Response, Compensation, and Liability Act (as amended) (CERCLA) Emergency Planning and Community Right-To-Know Act (EPCRA) (SARA Title III) National Environmental Policy Act (NEPA) Oil Pollution Act of 1990 (OPA ’90) Toxic Substances Control Act (TSCA) Fishery Conservation and Management Act Migratory Bird Treaty Act Wild and Scenic Rivers Act Rivers and Harbors Act Endangered Species Act (ESA) Coastal Zone Management Act (CZM Act) 2.2.3 Other Regulatory References AOR API AST BACT BOD CAA CAS CERCLA CFR CO COD CWA CZM CZM Act DMR DOI DOT E&P EHS EIR EPA EPCRA ER ESA FWPCA GPA HAP HMTA HS H2S HSWA EPA AP-42 Manuals 2.2.4 Compilation of Air Pollutant Emission Factors (Volumes & 2) LAER LEPC MACT Acronyms and Abbreviations The following acronyms and abbreviations are used in this publication: 3U.S Department of Transportation The Code of Federal Regulations is available from U.S Government Printing Office, Washington, D.C 20402 4Occupational Safety and Health Administration, U.S Department of Labor The Code of Federal Regulations is available from U.S Government Printing Office, Washington, D.C 20402 5Available from Supt of Documents, U.S Government Printing Office, Washington, D.C 20402 MMS MSDS NAAQS NEPA NESHAPS NOx NORM `,,```,,,,````-`-`,,`,,`,`,,` - Copyright American Petroleum Institute Provided by IHS under license with API No reproduction or networking permitted without license from IHS Not for Resale Area of Review American Petroleum Institute Aboveground Storage Tank Best Available Control Technology Biological Oxygen Demand Clean Air Act Chemical Abstract Service Comprehensive Environmental Response, Compensation, and Liability Act (Superfund) Code of Federal Regulations Carbon Monoxide Chemical Oxygen Demand Clean Water Act Coastal Zone Management Coastal Zone Management Act Discharge Monitoring Report U.S Department of Interior U.S Department of Transportation Exploration and Production Extremely Hazardous Substance Environmental Impact Review (Environmental Impact Assessment) U.S Environmental Protection Agency Emergency Planning and Community Right-To-Know Act (Title III of SARA, commonly called Right-To-Know or SARA Title III) Enhanced Recovery Endangered Species Act Federal Water Pollution Control Act Gas Processors Association Hazardous Air Pollutant Hazardous Materials Transportation Act Hazardous Substance Hydrogen Sulfide Hazardous and Solid Waste Amendments (1984 RCRA Amendments) Lowest Achievable Emission Rate Local Emergency Planning Committee Maximum Achievable Control Technologies Minerals Management Service (U.S Department of Interior) Material Safety Data Sheet National Ambient Air Quality Standards National Environmental Policy Act National Emissions Standard for Hazardous Air Pollutants One or more compounds of nitrogen oxides Naturally Occurring Radioactive Material NATURAL GAS PROCESSING PLANT PRACTICES FOR PROTECTION OF THE ENVIRONMENT d Monitoring and reporting requirements (including recordkeeping requirements) e Schedule for demonstrating mechanical integrity of the well at least every five years, or per regulatory agency requirements f Plans for plugging and abandoning the well g Area of Review (AOR) to evaluate nearby wells Requirements for Class I wells are more restrictive, and additional information is required 5.4 5.4.1 SPILL PREVENTION Spill Prevention Regulations—Oil Spills The objective of the Spill Prevention, Control, and Countermeasure (SPCC) regulations is to prevent the discharge of oil in harmful quantities into navigable waters of the United States or adjoining shorelines or wetlands To accomplish this objective, EPA regulations require the preparation and implementation of an SPCC Plan for all nontransportation related facilities that have discharged or could reasonably be expected to discharge oil into navigable waters of the United States EPA’s SPCC regulations are contained in 40 CFR, Part 112 API has published Bulletin D16 to assist with conformance to the requirements of these regulations Bulletin D16 discusses details of the regulations as well as providing suggested forms for use in preparing SPCC plans All gas processing and associated facilities must be evaluated with respect to location and storage capacity to determine whether or not provisions of the SPCC regulations apply If SPCC regulations apply, the operator must prepare and implement an SPCC Plan All facilities having a total aboveground storage of 1320 gallons or more of oil are subject to SPCC regulations if they have the potential for discharging into navigable waters of the United States Single containers with 660 gallons of oil or more would also be subject to the regulations Each SPCC plan must be reviewed and certified by a registered professional engineer The SPCC plan must be maintained onsite if the facility is manned at least eight hours a day or at the nearest office if the facility is unmanned The SPCC plan must be made available to EPA personnel for onsite review anytime during normal working hours All SPCC Plans must be reviewed at least once every three years An amendment may be required if a review indicates more effective control and prevention technology will significantly reduce the likelihood of a spill event SPCC Plans must also be amended within six months whenever there is a significant change in facility design, construction, operations, or maintenance procedures that materially affects the potential for an oil spill All amendments must be certified by a registered professional engineer Personnel changes not require recertification `,,```,,,,````-`-`,,`,,`,`,,` Copyright American Petroleum Institute Provided by IHS under license with API No reproduction or networking permitted without license from IHS 11 In addition to the SPCC regulations, the Oil Pollution Act of 1990 (OPA ’90) was signed into law on August 18, 1990 This Act created a comprehensive prevention, response, liability, and compensation regime for dealing with vessels and facilities that may cause oil pollution from spills into navigable waters of the United States The Act requires development of regulations that require owners or operators of tank vessels as well as offshore facilities and some onshore facilities (which can include gas plants) to prepare and submit plans for, among other things, responding, to the maximum extent practicable, to a worst-case discharge of oil Through Presidential Executive Orders, authority has been delegated to prepare regulations that establish procedures, methods, equipment, and other requirements to prevent/respond to discharges of oil into navigable waters This authority was delegated to: a Environmental Protection Agency b Department of Transportation (U.S Coast Guard and Research and Special Programs Administration) c Department of Interior (Minerals Management Service) The EPA has responsibility for all onshore nontransportation related facilities, such as terminals, tank batteries, and gas plants The general threshold criteria for applicability are: a Facility has a maximum storage capacity equal to or greater than 42,000 gallons and transfers oil over water b Facility has a maximum storage capacity equal to or greater than one million gallons Other criteria, such as spill history, proximity to sensitive areas, and so forth, and at the discretion of an EPA Region Administrator, can bring a facility under the requirements of the EPA The main emphasis of the SPCC Plan and the OPA ’90 regulations is the prevention of oil spills Companies are expected to minimize human errors and the accidental discharge of oil by putting into effect design and operations countermeasures Preventive measures discussed in 5.4.2 through 5.4.8 will reduce the risk of discharge into navigable waters of the United States 5.4.2 Plant Site Drainage Navigable waters of the United States should be protected from spills and releases via appropriate engineering design and techniques (for example, secondary containment) The containment should be large enough to hold all of the liquid from the largest tank or vessel that can drain into it plus allowance for precipitation (refer to API Bulletin D16) Remote impounding and other topics associated with storage of flammable liquids are addressed in Section Where regulations allow, diked storage areas should have manual valves, manually-activated pumps or ejectors, or Not for Resale 12 API RECOMMENDED PRACTICE 50 other acceptable alternatives to drain or empty retained stormwater The condition of the water should be checked before drainage to ensure that no oil is discharged Plant drainage systems for undiked areas should flow into either (a) ponds, lagoons, or catchment basins designed to retain oil or return it to the facility, or (b) a diversion system at the final discharge of all in-plant ditches that could contain an uncontrolled spill and return oil to the plant Drainage of stormwater from dikes into a storm drain or into an effluent discharge that empties into an open watercourse, lake, or pond may bypass the in-plant treatment system if the effluent is inspected (testing may be required) to ensure compliance with applicable water quality standards and that no harmful discharge will occur (refer to 5.2.3 for possible discharge permit requirements) Documentation may be required for discharges of rainwater from diked areas Aboveground Storage Aboveground storage tanks (ASTs) should be built to generally accepted industry standards, such as those established, that embody suitable safety factors to ensure that tanks will safely contain their contents under normal operating conditions ASTs may be subject to SPCC regulations (40 CFR Part 112 and refer to 5.4.1) Secondary containment should be provided to prevent offsite contamination Drainage trenches may be arranged so that a spill could be terminated and contained Dikes, curbs, and pits are also commonly used for containment Dikes should be sufficiently impervious to contain oil Diking is less desirable than remote impounding for flammable liquids because it could expose a leaking tank or adjacent tanks to a ground spill fire ASTs should be subjected to appropriate integrity tests, including hydrostatic testing, visual inspections, or nondestructive internal and external testing 5.4.4 Underground Storage Some underground storage tanks (USTs) storing oil may be subject to both the SPCC regulations (40 CFR Part 112 and refer to 5.4.1) and the UST regulations (40 CFR Part 280) The current SPCC regulations are applicable to facilities having underground storage tank capacity greater than 42,000 gallons of oil when a spill from the facility could possibly reach navigable waters of the United States The federal UST regulations pertain to any tank, including underground piping connected to the tank, that has at least 10 percent of its volume underground A number of states have been authorized to administer the UST program in place of EPA Some state and local authorities have regulations that are more stringent or broader in scope than the federal regulations The regulations apply only to USTs storing petroleum (such as fuel tanks), used oil, or hazardous substances other than RCRA hazardous waste Tanks used to Copyright American Petroleum Institute Provided by IHS under license with API No reproduction or networking permitted without license from IHS 5.4.5 Surface Pits Regulations for the installation and operation of surface pits are administered by the states The federal laws not apply to surface pits unless the pit contents are classified as hazardous waste (refer to Section for information on definition) The trend is away from having surface pits In many cases, it may be difficult to get a permit for a new pit A well-designed pit will be built with impermeable materials or will utilize a liner to prevent loss of contents In addition, provisions need to be made to ensure that birds, domestic animals, or wildlife will not be harmed by the contents of the pit by using netting, fencing, or other appropriate means of protection 5.4.6 Process Piping, Vessels, and Equipment Environmental regulations may dictate changes in original plant design, equipment installation, and operating and maintenance procedures Some will primarily affect the design of new facility construction as well as retrofitting current gas plants The number of flanges and valves installed should be minimized to reduce possible leakage points, and they should be accessible for monitoring Process drainage, sight glass blowdown, and sample point streams should be routed to the process sewer to avoid contamination of the stormwater sump Open-cup drain installation should be minimized to reduce the possibility of spillage Temporary piping or hose routed to the drain system should be used instead of open-cup drains when use is infrequent Process sewers should be routed to recovery facilities Installation of double pipe or sand-filled plastic encasement, in addition to a leak detection system, will provide secondary containment Sumps and foundations should be impermeable to enhance containment Not for Resale `,,```,,,,````-`-`,,`,,`,`,,` - 5.4.3 store RCRA hazardous waste must comply with RCRA Subtitle C tank regulations, regardless of whether the tank is aboveground or underground Some types of tanks not covered by the UST regulations are systems for collecting stormwater and wastewater and flow-through process tanks If any USTs are subject to all the UST program regulations, then these tanks are excluded from the SPCC requirements A useful guide to the UST regulation is available from the EPA in a publication entitled “Musts for USTs” and “Straight Talk on Tanks” (EPA/530/US T-90/12) An “existing UST” is one that was in operation prior to December 22, 1988 New and existing USTs must comply with significant construction or retrofit standards upon installation or by 1998, at the latest Aboveground equipment is much easier to inspect and repair and may be a preferred alternative