1 addressing air quality impacts from oil and gas development in colorado westar conference october...
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Addressing Air Quality Impacts from Oil and Gas Development in
Colorado
WESTAR ConferenceOctober 23, 2008
Rose WaldmanColorado Air Pollution Control Division
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Current Rule Requirements Condensate Tanks (VOCs) Ozone Control Area (OCA)
– System-wide control by company at 75% (from 5/1 to 9/30); at 70% (rest of year)
– Control device at 95%– Control not required at tank/batteries with ≤ 730 bbls/yr
(~ 5 tpy)– Exemption for companies with total operations of < 30
tpy (uncontrolled)
Statewide– Control at 95% required at tank/batteries with ≥ 20 tpy
(uncontrolled)
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Current Rule Requirements (cont.)
Gas Processing Plants in OCA (VOCs) – LDAR, NSPS Subpart KKK applies regardless of
construction date
– Condensate tanks must be controlled at 95% if not stabilized and if ≥ 1 tpy (uncontrolled)
Glycol Dehydrators in OCA & Statewide (VOCs) – Control vents at 90% ≥ 15 tpy (uncontrolled)
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Current Rule Requirements (cont.) RICE Statewide (NOx, CO, & VOCs)
Maximum Engine HP
Construction or Relocation
Date
Emission Standards (G/hp-hr)
NOx CO VOC
100<HP<500 1/1/081/1/11
2.01.0
4.02.0
1.00.7
500<HP 7/1/077/1/10
2.01.0
4.02.0
1.00.7
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Ozone Non-Attainment Status Denver Metro North Front Range 9-county area
became non-attainment on 11/20/07
APEN threshold reduced from 2 tpy to 1 tpy
Permit threshold reduced from 5 tpy to 2 tpy (VOCs), 10 tpy to 5 tpy (NOx)
SIP Development Proposing new rules/regulations Possible implementation date 2/1/09
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Proposed Rule Changes
Condensate Tanks (NAA) Move from system-wide to threshold approach New/modified tanks ≥ 2 tpy at 95% by 2/1/09 Existing tanks ≥ 10 tpy at 95% by 5/1/10 Existing tanks ≥ 5 tpy at 95% by 5/1/2011 Existing tanks ≥ 2 tpy at 95% by 5/1/2012 Control all tanks at 95% 1st 90 days (new/modified) Auto-ignitor and electronic surveillance at controlled
locations (new, modified, existing) Removing 30 tpy exemption Increase ozone season control from 75% to 80% (last
season of system-wide approach) Statewide rules may be proposed next spring
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Proposed Rule Changes (cont.)
Pneumatic Controllers (NAA) 1st time source being regulated Most controllers must be low-bleed
(new: 2/1/09, existing: 5/1/09) Enhanced maintenance, inspection, and
recordkeeping for remaining high-bleeds Statewide rules may be proposed next
spring
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Proposed Rule Changes (cont.)
Statewide RICE (existing) Install controls if >500 hp Rich burn: NSCR and air fuel controller by
5/12/2010 Lean burn: oxidation catalyst by 5/1/2010 Not required at ≥ $5,000 per ton reductions
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Potential future strategies
Leak detection/maintenance at E&P sites and compressor stations
Drill rigs (NOx)
Miscellaneous oil and gas equipment
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House Bill 1341 – Enforced by COGCC
Condensate/produced water/crude oil tanks - located in 3 counties within ¼ mile of affected buildings - control at 95% if source ≥ 5 tpy Glycol dehydrators
- located in 3 counties within ¼ mile of affected buildings - control at 90% if source ≥ 5 tpy Production Pits
- located in 3 counties within ¼ mile of affected buildings - control at 95% if source > 5 tpy Pneumatic devices shall be low-bleed if technically feasible
(new/modified Statewide) Green completions
- Statewide, unless exempt due to field conditions Control requirements will be reflected in an APCD-issued permit
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House Bill 1341 - continued
COGCC hearing: Dec. 9-11, 2008
Implementation date: Feb. 1, 2009 (pending)
Compliance date: Oct. 1, 2009, for most air related rules (pending)
COGCC and CDPHE interaction– Revises permitting process for COGCC and adds
a consultation component