implementing new state and federal air regulatory programs – a systematic approach to compliance

SPE-173558-MS

Implementing New State and Federal Air

Regulatory Programs – A Systematic Approach

To Compliance

Jay Christopher, Trihydro Corporation

OIL & GAS ENVIRONMENTAL COMPLIANCE IS BECOMING

INCREASINGLY COMPLEX

Slide 2

SPE-173588-MS • Implementing New State and Federal Air Regulatory Programs – A Systematic Approach to Compliance • Jay Christopher

Water

Waste

AirPermits, Controls, VOCs, Methane,

GHGs

NEPA

AIR REGULATIONS ARE EXPLODING!

Slide 3

HERE ARE A FEW OF THE MORE IMPORTANT AIR REGULATIONS

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Air Permitting ProgramsMinor Source New Source Review Applies to a majority of production facilities.

Prevention of Significant Deterioration (PSD) Applies to major emission source facilities in attainment areas.

Non-attainment New Source Review Applies to major emission source facilities in non-attainment areas.

New Source Performance Standards (NSPS)

Subparts K, Ka, and Kb Standards of Performance for Storage Vessels for Petroleum Liquids

Subpart GG Standards of Performance for Stationary Gas Turbines

Subpart KKK Standards of Performance for Equipment Leaks of VOC From Onshore Natural Gas Processing Plants for Which Construction, Reconstruction, or Modification Commenced After January 20, 1984, and on or Before August 23, 2011

Subpart LLL Standards of Performance for SO2 Emissions From Onshore Natural Gas Processing for Which Construction, Reconstruction, or Modification Commenced After January 20, 1984, and on or Before August 23, 2011

Subpart IIII Standards of Performance for Stationary Compression Ignition Internal Combustion Engines

Subpart JJJJ Standards of Performance for Stationary Spark Ignition Internal Combustion Engines

Subpart KKKK Standards of Performance for Stationary Combustion Turbines

Subpart OOOO Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution

National Emission Standards for Hazardous Air Pollutants, Maximum Achievable Control Standards (NESHAP, MACT)

Subpart H National Emission Standards for Organic Hazardous Air Pollutants for Equipment Leaks

Subpart HH National Emission Standards for Hazardous Air Pollutants From Oil and Natural Gas Production Facilities

Subpart VV National Emission Standards for Oil-Water Separators and Organic-Water Separators

Subpart HHH National Emission Standards for Hazardous Air Pollutants From Natural Gas Transmission and Storage Facilities

Subpart YYYY National Emission Standards for Hazardous Air Pollutants for Stationary Combustion Turbines

Subpart ZZZZ National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines

MORE AND MORE AIR PERMITS

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• Air Permits – Issued by state environmental agencies (not oil and

gas commissions), pre-construction, multiple requirements

Minor source New Source Review – most oil & gas wells

Prevention of Significant Deterioration – large facilities

Non-attainment New Source Review – poor air quality areas

such as Jonah/Pinedale, Barnett, San Joaquin; very tight

controls

• Pay attention to forthcoming ozone rules!

EPA has proposed a 65 – 70 ppb ambient ozone

requirement, and requested comment on 60 ppb.

Once finalized, this will have significant impact on

development

Source: USEPA; http://www.epa.gov/airquality/greenbook/map/map8hr_2008.pdfSource: National Association of Manufacturers;

http://www.nam.org/uploadedImages/NAM/Site_Content/Issues/Ozone%20Figure2%20New

%20Regulations.jpg

Projected 8-Hour Nonattainment (60 ppb)


http://www.epa.gov/airquality/greenbook/map/map8hr_2008.pdf

http://www.nam.org/uploadedImages/NAM/Site_Content/Issues/Ozone Figure2 New Regulations.jpg

MORE AND MORE AIR REGULATIONS

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• Federal Regulations

NSPS OOOO (“Quad O”)

Hydraulic fracturing completions

Storage tanks

Pneumatics

LDAR

MACT HH/HHH (Glycol dehydration processes)

BLM Onshore Order 9

GHG Mandatory Reporting Rule (Subpart W)

• State Regulations

Colorado Regulation No. 7

Others already in effect and more coming

HOW CAN YOU DEAL WITH IT ALL?

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MAGIC?

THE NEED TO DEMONSTRATE COMPLIANCE IS MORE

IMPORTANT NOW THAN EVER

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• Environmental agencies are just as critical to your operations as

oil and gas commissions

• The environmental regulations are complex, and often attempt to

encompass all operations on a “one size fits all” basis

• Some rules do not specify recordkeeping, but how do you

demonstrate compliance without records?

How do you deal with those situations …

SYSTEMATIC PROCEDURES AND PROTOCOLS

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… even if not required

• Infrared cameras

Train camera operators

Written monitoring protocols

Keep video records?

Manufacturer calibrations

Daily instrumentation checks

Work process to deal with

findings

OPERATOR-BASED INSPECTIONS

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… prove that the inspections are taking place

• Proof is not just a weekly check box

Consistent training program (explain the requirements)

Documented inspection procedures

Findings that demonstrate inspections are real

Complete records (these are legal documents!)

LOOK FOR OPPORTUNITIES TO GATHER DATA ONCE

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• Several regulatory programs may use the

same data for compliance demonstrations Emissions inventories and greenhouse gas

reporting

Greenhouse gas measurements and leak

detection and repair programs

• Take a comprehensive look at all data

needs, and capture the data one time Data historians

Environmental information management systems

Databases

Spreadsheets


COMPLEXITY OF YOUR APPROACH DEPENDS ON YOUR EXISTING

SYSTEMS, OPERATIONS, AND PHILOSOPHY

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• Some environmental data management systems are great

Do they fit with your existing systems?

Do they cover the breadth of your operations?

Can it store the records you need?

Most importantly – do you have a champion to drive

implementation and continuing use?

• Sometimes a less exotic approach works perfectly

The most critical point is that you establish a systematic

approach to compliance, and that you incorporate sustaining

that system in your plan


Acknowledgements / Thank You / Questions

Jay Christopher, Trihydro Corporation

[email protected]

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mailto:[email protected]

implementing new state and federal air regulatory programs – a systematic approach to compliance

Education

air permitsslide

natural gas transmission

ghgsnepa air regulations

important air regulationsslide

gas commissions

kbstandards of performance

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systematic approach