Oil and Gas Air R Oil and Gas Air Regulations gulations What Y - - PowerPoint PPT Presentation

Presented by: Calvin Niss Jay Christopher Chad Flynn

Oil and Gas Air R Oil and Gas Air Regulations gulations What Y What You Need t u Need to F Focus on No cus on Now! w!

Agenda

Intr Introductions

• ductions

Wo Workshop Objectiv Objectives es Wo Workshop A Agenda Saf Safety Moment ty Moment Wo Workshop M Materials

Thank You for Joining Us

Calvi Calvin Ni Niss ss

Senior Vice President cniss@trihydro.com

Ja Jay C y Christ ristopher

• pher

Senior Air Specialist jchristopher@trihydro.com

Cha Chad Flynn Flynn

Lead Project IT Professional cflynn@trihydro.com

• When you are in the

field at your sites, always expect the unexpected.

• What are some of the

most unexpected things you have run it to at your facilities?

Safety Moment

• Here is one of ours,

found on top of a production tank in

• Wyoming. Everyone was

pretty calm about this, including our new friend!

• I wonder about GHG

emissions?

Safety Moment

Workshop Objectives

At the end of this workshop you should have a general understanding of the environmental air compliance challenges confronting your upstream and midstream

• perations via a discussion of:
• Federal and other air regulatory programs
• VOC & methane LDAR monitoring and reporting
• Recordkeeping and reporting
• What happens next? Emerging issues

And hopefully have had a little fun and gotten to know some

• f your industry peers!

• Full workshop agenda/slide

deck

• List of acronyms
• Copy of EPA/BLM regulations

and support documents and some recent court cases

• Applicability determinations
• Consent decrees
• 114 Request templates
• Other information of interest

Workshop Materials (Link to be provided following 4C)

Oil & Gas Workshop Agenda

8:00 am – 8:30 am Introduction 8:30 am – 9:30 am Air Regulatory Overview 9:30 am – 9:45 am Break 9:45 am – 11:00 am Leak Detection and Repair (LDAR/OGI) 11:00 am – 11:30 am Breakout Session #1 11:30 am – Noon Equipment Specific Requirements Noon – 1:00 pm Lunch Break 1:00 pm – 1:30 pm Equipment‐Specific Requirements 1:30 pm – 2:00 pm Recordkeeping/Reporting 2:00 pm – 2:30 pm Breakout Session #2 2:30 pm – 3:15 pm What Happens Next? 3:15 pm – 3:30 pm Break 3:30 pm – 4:30 pm Jeopardy Contest 4:30 pm – 4:45 pm Wrap‐up

WHA WHAT WHY WHY WHERE WHERE WHEN WHEN WHO WHO HO HOW

Questions?

Presented by: Jay Christopher

Oil and Gas Air R Oil and Gas Air Regulations gulations Air Quality R Air Quality Regulation R gulation Revie view

Air Quality Regulations

• Federal
• NSPS OOOO, NSPS OOOOa
• NSPS LLL – Amine Units Jan 20, 1984 and Aug 23, 2011
• NESHAP HH and HHH – Glycol Dehydration Units
• Engine NSPS/MACT (IIII, JJJJ, ZZZZ)
• Bureau of Land Management’s (BLM) “Waste Prevention”

requirements (i.e., BLM Venting and Flaring rule)

Oil and Gas Air Regulations Air Quality Regulation Review

Additional Air Quality Regulatory Programs

• EPA’s Source Determination (aggregation) rule
• GHG Reporting – Subpart W
• Several important state programs
• Colorado
• Texas
• Wyoming
• North Dakota
• Pennsylvania

Oil and Gas Air Regulations Air Quality Regulation Review

NSPS OOOO Overview

• Primary oil and gas air regulation #1 – New Source

Performance Standard (NSPS) Subpart OOOO

• Covers new/modified operations between August

23, 2011 through Sept September 1 ember 18, 20 , 2015

• OOOO is a volatile organic compound (VOC) rule
• For gas venting during completions and workovers,

OOOO only regulates natural gas wells

Oil and Gas Air Regulations Air Quality Regulation Review

What is Covered in NSPS OOOO?

Oil and Gas Air Regulations Air Quality Regulation Review

Well site

• Completions
• Storage

Vessels

• Pneumatics

Gathering Booster Facilities

• Storage

Vessels

• Pneumatics
• Compressors

Gathering Booster Facilities

• Storage

Vessels

• Pneumatics
• Compressors

Natural Gas Plants

• Storage

Vessels

• Pneumatics
• Compressors
• LDAR
• SO2

Natural Gas Plants

• Storage

Vessels

• Pneumatics
• Compressors
• LDAR
• SO2

Natural Gas Transmission Compression

• Storage

Vessels

Underground Natural Gas Storage

• Storage Vessels

Underground Natural Gas Storage

• Storage Vessels

To Distribution

NSPS OOOOa Overview

• Primary oil & gas air regulation #2
• Covers new/modified operations after Sept

September 1 ember 18, 20 , 2015

• Think of OOOOa as OOOO plus
• Includes methane in addition to VOCs
• Oil well completions included, with similar requirements to

OOOO (i.e. “green” completions)

• Exemption for wells with Gas/Oil Ratio (GOR) less than 300

scf/bst (barrels of stock tank liquids)

• Inclusion of fugitive emissions at well sites and compressor

stations, preference to optical gas imaging

Oil and Gas Air Regulations Air Quality Regulation Review

• Modification
• Explicit definitions for some

scenarios (addition of a new compressor or increase in horsepower at a compressor station; drilling a new well at an existing well site; and more. The trigger does not specifically require an emissions increase.

• If accomplished without capital

expenditure, then not a modification, but

• EPA changed the General Provisions

calculation to determine capital expenditure very conservatively:

• Asset guideline repair allowance (“B”

value) set at 4.5

• Base year in calculation fixed at 2011

General Provisions

Oil and Gas Air Regulations Air Quality Regulation Review

NSPS LLL – Amine Units

• SO2 emissions from natural gas sweetening units
• Constructed, modified or reconstructed after January 20,

1984 and before August 23, 2011

• SO2 reduction requirements based on acid gas sulfur

content and facility size

• Performance testing, recordkeeping, and reporting
• < 2 long tons/day design capacity have lesser

requirements

Oil and Gas Air Regulations Air Quality Regulation Review

NESHAP HH and HHH

• HH – Production dehydrators and tanks
• HHH – Transmission pipeline dehydrators and tanks
• Focused on benzene

benzene as HAP of primary concern

• Must be MACT major (> 10 tons/year of any one HAP and

> 25 tons/year of combined HAPs

• 95% reduction or < 1 ton/year benzene
• Leak detection and repair provisions covered in Fugitive

Monitoring Section

Oil and Gas Air Regulations Air Quality Regulation Review

Engine Regulations (IIII, JJJJ, ZZZZ)

• EPA’s engine regulations are confusing and require great

care in evaluating and implementing a compliance program.

• NSPS: IIII - compression ignition (generally constructed,

modified, or reconstructed (CMR) after July 11, 2005) and JJJJ spark ignition (generally CMR after June 12, 2006, but important exceptions).

• MACT ZZZZ – reciprocating internal combustion (> 500

HP at MACT major sites, CMR after December 19, 2002 and 500 HP CMR after June 12, 2006.

Oil and Gas Air Regulations Air Quality Regulation Review

Bureau of Land Management (BLM)

• BLM’s “venting and flaring” rule has been:
• Finalized
• Failed a Congressional Review Act

cancellation

• Postponed by direct final rule
• Postponement overturned
• Final rule with a one-year compliance

extension

• Compliance extension rule overturned
• Proposed rule significantly reducing the

requirements is pending

• Ongoing legal actions.
• Today – the regulations are in force.

Oil and Gas Air Regulations Air Quality Regulation Review

BLM Venting/Flaring Rule

• “Waste Prevention, Production Subject to Royalties, and

Resource Conservation,” finalized on November 18, 2016 (https://www.regulations.gov/contentStreamer?documentId= BLM-2016-0001- 9126&disposition=attachment&contentType=pdf)

• Affects oil and natural gas production on onshore Federal and

Indian lands (leases administered by BLM)

• Intended result - reduce flaring of produced gas
• The BLM rule is premised on resource conservation, but with a

methane reduction focus that strongly overlaps NSPS OOOOa

• Applies to both new and existing sources

Oil and Gas Air Regulations Air Quality Regulation Review

Waste Minimization (gas e Minimization (gas cap capture) Plan ure) Plans s (WMPs) (WMPs) Submit WMPs with Applications for Permits to Drill (APDs) after January 17,

• 2017. Plans need to demonstrate:
• Reduction in percentage of flared

gases (i.e. capture at least 85 percent by January 2018, phasing in stages to 98 percent by 2026)

• Staged phase-down of monthly

allowable flaring volumes between 2018 (5,400 Mcf/well) and 2025 (750 Mcf/well) averaged across

• perations (lease-by-lease, county-

by-county, or within a state boundary

BLM Venting/Flaring Rule

Oil and Gas Air Regulations Air Quality Regulation Review

Leak Det Leak Detection (think OOOOa) ction (think OOOOa)

• LDAR (OGI) at well sites,

including onsite compressors;

• Reduces venting from

pneumatic controllers and pumps, storage vessels, well maintenance and liquids unloading

BLM Venting/Flaring Rule

Oil and Gas Air Regulations Air Quality Regulation Review

BLM Venting/Flaring Rule

Emergencies (t Emergencies (tem emporar porary, infreq , infrequent, una ent, unavoidable)

• idable)
• 24 hours per incident (unless extended by BLM), and no

more than three emergencies per 30 day period

• Exceptions (i.e., not an emergency)
• More than 3 failures of the same equipment in a 365-day period
• Failure from improperly sized, installed, or maintained equipment
• Failure to limit production when rate exceeds capacity of

equipment, pipeline, gas plant

• Scheduled maintenance
• Operator negligence

Oil and Gas Air Regulations Air Quality Regulation Review

Source Determination (Aggregation)

• Final rule June 3, 2016

(https://www.regulations.gov/contentStreamer?documentId= EPA-HQ-OAR-2013-0685- 0226&disposition=attachment&contentType=pdf)

• Specific to the oil and gas sector, not other industries
• What does “adjacent” mean
• Very important for project permitting
• Prevention of Significant Deterioration (PSD)
• Non-attainment New Source Review (NNSR)
• Title V operating permits

Oil and Gas Air Regulations Air Quality Regulation Review

• Three-part test
• Same industrial grouping

(standard industrial code (SIC))

• Located on contiguous or

adjacent properties

• Under common control of

single owner

• EPA added additional

considerations

• Operational dependence
• Functional interrelatedness

Aggregation – Historic Approach

Oil and Gas Air Regulations Air Quality Regulation Review

• Summit Petroleum Corporation –

Michigan

• EPA determined that oil/gas

sweetening plant and ~ 100 Summit

• il/gas wells were a single major

source under the Title V operating permit program

• The Summit wells were all within 8

miles of the plant, and EPA determined these were “adjacent”

• Summit appealed to 6th Circuit Court
• f Appeals in 2012; EPA decision
• verturned (using “interrelatedness” in

determining adjacency was unreasonable)

• EPA issued guidance to follow the 6th

Circuit ruling only in states subject to the 6th Circuit, and to continue to use functional interdependency elsewhere

Aggregation – Summit Petroleum

Oil and Gas Air Regulations Air Quality Regulation Review

Source Determination/Aggregation

• Adjacent – equipment and activities in the oil & gas

sector under common control are considered part of the same source if:

• They are located on the same site or on sites that share

equipment

AND

• They are located within ¼-mile of each other

Oil and Gas Air Regulations Air Quality Regulation Review

• Source Determination/Aggregation

Other Important Programs (Federal/State)

• Federal
• New Source Review permitting
• Ozone non-attainment areas
• Texas - Permit-by-rule
• Colorado - Regulation No. 7
• Wyoming – Presumptive BACT
• North Dakota - Flare minimization
• Pennsylvania – Pending changes to GP5 (midstream)

and GP5A (upstream and remote pigging)

Oil and Gas Air Regulations Air Quality Regulation Review

• Regulation has different

requirements for each the 10 industry segments

• Offshore natural gas and

natural gas production

• Onshore natural gas and

natural gas production

• Onshore natural gas

processing

• Onshore natural gas

transmission compression

• Underground natural gas

storage

GHG MRR Subpart W Petroleum & Natural Gas Systems

Oil and Gas Air Regulations Air Quality Regulation Review

• Liquefied NGL storage
• LNG import export

equipment

• Natural gas distribution
• Onshore petr

Onshore petroleum and

• leum and

natural gas gatheri natural gas gathering and g and boostin boosting*

• Onshore natural gas

Onshore natural gas transmission pipeline* transmission pipeline*

* Added for the 2016 Reporting year (reported by March of 2017)

GHG MRR Subpart W

Oil and Gas Air Regulations Air Quality Regulation Review

• Generally, deminimis level of

25,000 metric tons per facility

• Each segment has its own

definition of facility

• Can be based on basin, physical

facility or even aggregated for entire United States (pipelines)

• Basins can cover part of more

than one state

• No county is split between two

basins

• Requires annual GHG emission

inventories

GHG MRR Subpart W

Oil and Gas Air Regulations Air Quality Regulation Review

GHG MRR Subpart W

• All segments except the Production and Gathering and

Boosting segments report combustion emissions following Subpart C

• Production and Gathering/Boosting follow Subpart W
• Report emissions from all combustion sources above the deminimis

(5 mmBTU/hr for external combustion 130 hp for internal)

• Includes sources on site temporarily, even if not owned or operated

by reporting company (drilling, completions, workovers, maintenance)

• Doesn’t include engines that power a drive shaft (not traditional

definition of mobile)

Oil and Gas Air Regulations Air Quality Regulation Review

Added to the Production segment for 2016

• Gas venting during

completions/workovers, with fracing for oil wells

• Reporting well ID numbers (so

calculation inputs can be confirmed) Gathering and Boosting

• Reporting requirements very similar

to production requirements

• Covers almost all equipment not

currently reported under another industry segment

• Emissions aggregated by basin

GHG MRR Subpart W

Oil and Gas Air Regulations Air Quality Regulation Review

• Transmission Pipelines
• Emissions nationally

aggregated

• Only includes emissions

from blowdown vent stacks

GHG MRR Subpart W

Oil and Gas Air Regulations Air Quality Regulation Review

Presenter

Oil and Gas Air Regulations Air Quality Regulation Review

Ja Jay C y Christ ristopher

• pher

Senior Air Specialist jchristopher@trihydro.com

WHA WHAT WHY WHY WHERE WHERE WHEN WHEN WHO WHO HO HOW

Questions?

• A PBR can be requested if PTEs

are:

• < 250 tpy of CO or NOx
• < 25 tpy of VOC, SO2, or H2S
• < 15 tpy PM10 and < 10 tpy

PM2.5 and

• < 25 tpy of any other contaminant,

except

• CO2, H2O, N2, CH4, C2H6, H or

O2

• Can’t meet PBR qualifications? Try

for a standard permit.

• Can’t qualify for a standard

permit? NSR permit is required

Other Important Programs (Federal/State)

Oil and Gas Air Regulations Air Quality Regulation Review

Texas PBR, Continued

Common PBRs for the oil and gas industry (Chapter 106, Subchapter O):

• 106.351 – Saltwater Disposal
• 106.352 – Oil & Gas Handling and Production Facilities
• 106.353 – Temporary Oil & Gas Facilities
• 106.473 – Organic Liquid Loading and Unloading
• 106.492 – Flares
• 106.512 – Stationary Engines & Turbines

Oil and Gas Air Regulations Air Quality Regulation Review

Colorado Regulation No. 7

Colorado Air Quality Control Commission adopted revisions on February 23, 2014 that apply to all oil and gas exploration and production operations, well production facilities, natural gas compressor stations, and natural gas processing plants Affected equipment includes:

• Combustors
• Open-ended lines/valves
• Compressors
• Storage tanks
• Glycol dehydrators
• LDAR
• Pneumatic controllers

Oil and Gas Air Regulations Air Quality Regulation Review

• Wyoming requires Best Available

Control Technology on all emission sources in the state, even if they were imported from another state

• Requires permits for oil and gas

well production sites

• No deminimis levels for permitting
• r BACT
• Oil and Gas Guidance has

presumptive BACT requirements for oil and gas production facilities based on location within the state

• Pump jack engine guidance for

small pump jack engines

Wyoming Requirements

Oil and Gas Air Regulations Air Quality Regulation Review

Wyoming Requirements

• Current emission limits for natural gas-fired engines can be as

low as 0.5 g/hp-hr for NOx and CO, 0.07 for formaldehyde

• Engines must be permitted before being placed on site
• Engine testing requirements exceed the NSPS and NESHAP

requirements

• Have been including annual OGI inspections of well sites on

more recent permits

• Requiring annual emission inventories of the Powder River

Basin facilities (attainment area), including minor sources

Oil and Gas Air Regulations Air Quality Regulation Review

• Registration program instead of

permits

• Published emission factors, so no

tank modeling required

• Requires oil and water tank vapors

to be captured and reduced by at least 98%

• North Dakota Industrial

Commission requiring a reduction in associated gas flaring

• Initial goals - capture 85% by

January 1, 2016 and 90% by October 1, 2020

• Delays in the these dates are

under review

North Dakota Requirements

Oil and Gas Air Regulations Air Quality Regulation Review

• Green completions
• Meet NSPS OOOO and

OOOOa

• Meet engine NSPS and

NESHAP requirements

• Meet NSPS for sulfur

dioxide

• Less cumbersome than

most state requirements

EPA’s Proposed Tribal Lands General Permit

Oil and Gas Air Regulations Air Quality Regulation Review

Presented by: Calvin Niss

Oil and Oil and Gas Essentials Gas Essentials LD LDAR R AR Regulations gulations

• Controlling fugitive

emission leaks

• Leak sources in the oil

and gas industry

• NSPS vs NESHAP
• LDAR regulations for the
• il and gas industry
• BLM – waste prevention

rule

• Fugitive emission plans
• Two-part test for LDAR

modification

• Capital expenditure
• LDAR pitfalls

Overview

Oil and Gas Air Regulations Equipment – Specific Requirements

Reduction of Leaking Equipment – Control of Leaks

Leak Detection and Repair (LDAR) is the control of fugitive emission leaks from process equipment through:

• Equipment standards
• Work practice standards
• Equipment monitoring
• Repair of leaking equipment
• Applies to equipment containing VOCs or HAPs, and for

the oil and gas sector methane (CH4) is a pollutant

Oil and Gas Air Regulations Equipment – Specific Requirements

EPA’s View of the Oil & Gas Industry

http://www3.epa.gov/airquality/oilandgas/basic.html

EPA’s View of the Oil and Gas Industry

• Oil and natural gas systems encompasses wells, gas gathering and

production facilities, storage, and transmission and distribution pipelines.

• Pr

Production

• duction – includes drilling and well completions of oil and gas wells,

gathering lines and booster stations

• Gas Plant Pr

Gas Plant Processing

• cessing – focuses on stripping out impurities and other

hydrocarbons and fluids to produce pipeline grade natural gas that meets specific tariffs (pipeline quality natural gas is 95 – 98 percent methane)

• Transmission &

ansmission & St Storage

• rage – includes transmission compressor stations,

transmission pipelines and underground storage

• Distribution

Distribution – delivery and distribution of natural gas from the major pipelines to end users (e.g., residential, commercial, and industrial)

Oil and Gas Air Regulations Equipment – Specific Requirements

NSPS vs. NESHAP

• New Source Performance Standards (NSPS)
• Criteria pollutants (primarily volatile organic compounds (VOCs)
• New, modified, or reconstructed sources
• Controls consider economic viability
• National Emission Standards for Hazardous Air Pollutants

(NESHAP)

• Maximum Achievable Control Technology (MACT)
• Hazardous Air Pollutants (HAPs)
• All sources, existing and new, at major or area sources of HAPs

Oil and Gas Air Regulations Equipment – Specific Requirements

NSPS Triggers

• Triggered based on having the equipment in the source

category that defines the NSPS subpart. The NSPS subpart does not become applicable until one of the three criteria are met.

• 1. Constructed new after the applicability date (proposed rule date)
• 2. Modification after the applicability date in the regulation
• 3. Reconstruction after the applicability date in the regulation
• Subpart KKK – January 21, 1984 to August 23, 2011
• Subpart OOOO – August 24, 2011 to September 18, 2015
• Subpart OOOOa – September 19, 2015 to present

Oil and Gas Air Regulations Equipment – Specific Requirements

• MACT regulations apply to Major

Source Categories

• Applicability for a MACT standard

for LDAR is based on the percent

• f defined organic hazardous air

pollutants (HAPs) that are present in each piece of regulated equipment

• MACT regulations become

effective on the date that they are published or triggered by a change

• The NSPS criteria of new, modified
• r reconstruction does not apply to

a MACT regulation

• MACT regulations have

exemptions

NESHAP / MACT Triggers

Oil and Gas Air Regulations Equipment – Specific Requirements

Fugitive Emission Regulations that Apply to the Oil and Gas Sector

• NSPS KKK

NSPS KKK – references NSPS VV

• NSPS OOOO

NSPS OOOO – references NSPS VVa

• NSPS OOOOa

NSPS OOOOa –September 18, 2015 newly constructed, modified, or reconstructed facilities

• BLM W

BLM Wast ste Pre e Prevention R ention Rule le – requires first inspection by 1/17/18 for existing facilities and within 60-days of beginning production after 1/17/18

• BLM delayed rule 1/2019
• US District Court California – Reinstated the rule 2/2018
• NSPS LL

NSPS LL – specific to SO2

• Part 63 Subpa

63 Subpart HH t HH – oil and natural gas production facilities

• Part 63 Subp

63 Subpart HHH t HHH – natural gas transmission and storage facilities

Oil and Gas Air Regulations Equipment – Specific Requirements

NSPS KKK Applicability

• Subpart KKK – Standards of performance for equipment leaks of VOC from
• nshore natural gas processing plants that commenced construction,

reconstruction, or modification after January 20, 1984 and or before August 23, 2011.

• Equipment subject to the standard includes equipment in wet gas service or VOC

service with a VOC content greater than 10 percent by weight.

• Compressor station, dehydration unit, sweetening unit, underground storage

tank, field gas gathering system is covered by this subpart if located at an

• nshore natural gas processing plant.
• Each piece of equipment is presumed to be in VOC service or in wet gas service

unless an owner or operator demonstrates that the piece of equipment is not in VOC or wet gas service.

• Joule – Thompson (JT) skids are defined as natural gas processing plants –

subject to NSPS KKK.

Oil and Gas Air Regulations Equipment – Specific Requirements

NSPS KKK Exemptions

• Pressure relief devices in gas/vapor service may be monitored quarterly and

within 5 days after each pressure release to detect leaks provided these PRVs are not at an unmanned gas plant.

1.

Option of VV – 500 ppm within 5 days

2.

Option of KKK – Monitor quarterly and 5 days at 10,000 ppm

• Sampling connection systems are exempt per 60.482 – 5
• Pumps in light liquid service, valves in gas/vapor and light liquid service, and

pressure relief devices in gas/vapor service that are located at a nonfractionating plant that does not have the design capacity to process 10 MM scf/day (283,200 scm/day) or more of field gas are exempt from the routine monitoring requirements of 60.482-2(a)(1) and 60.482-7(a), and 60.6333(b)(1).

• Reciprocating compressors in wet gas service are exempt from compressor

control requirements of 60.482-3.

Oil and Gas Air Regulations Equipment – Specific Requirements

• NSPS OOOO – Standards for

equipment leaks of VOC from onshore natural gas processing plants that commenced construction, reconstruction or modification after August 23, 2011.

• Lower leak definitions – 500 ppm

valves, 2,000 ppm pumps.

• NSPS OOOO – Specific work practice

for both centrifugal and reciprocating compressors.

• NDE requirements for compressors

routed to CVS w/in 180 days

• Emissions from rod packing vents are

not subject to LDAR monitoring.

NSPS OOOO Applicability

Oil and Gas Air Regulations Equipment – Specific Requirements

NSPS OOOO Exemptions

• NSPS OOOO – references VVa
• Indefinite stay of NSPS equipment leaks of VOC from SOCMI and

petroleum refineries

1. Clarification of the definition of process unit in subparts VV, VVa, GGG, and GGGa 2. Assigning of shared storage tanks to specific process units 3. Connector monitoring requirements in subpart VVa 4. The definition of capital expenditure in subpart VVa

• Trihydro regulatory opinion – the stay is only applicable to GGGa

facilities (i.e., petroleum refineries)

• NSPS OOOO – requires annual connector monitoring
• NSPS OOOO – response to comments – JT skids are not gas processing

plants (ADI in flash drive)

Oil and Gas Air Regulations Equipment – Specific Requirements

• LDAR required for well sites and

compressor stations – now includes methane

• Initial monitoring survey for affected

facilities was 6/3/2017

• Changes to the definition of “new” and

“modified” and clarifications of the capital expenditure calculation

• BSER – Best System of Emission

Reduction – Optical Gas Imaging (OGI)

• Site specific monitoring plans must be

developed and implemented

• Next Generation compliance,

verification, and electronic reporting requirements

OOOOa Rule – Big Fugitive Picture

Oil and Gas Air Regulations Equipment – Specific Requirements

OOOOa Rule – Big Fugitive Picture Continued

• Modification
• Well Sites – Addition of a new well or fracturing or refracturing of

an existing well

• Compressors – Addition of a new compressor, or when a physical

change is made to an existing compressor that creates greater horsepower

• Initial survey within 60 days of startup or modification
• Gas Plants – No changes – VVa program

Oil and Gas Air Regulations Equipment – Specific Requirements

Key Fugitive Aspects – NSPS OOOOa

• Fixed monitoring schedule (e.g., compressor stations – quarterly and well sites

semi-annually).

• Semiannual inspections must be conducted at least 4 months apart and

quarterly inspections at least 60 days apart.

• Monitoring using M21 – repair threshold 500 ppm.
• 30-days for repairs of fugitive emission sources.
• 30-days for resurvey.
• Delay of repair – Final rule removes the requirement for completion of delayed

repairs during unscheduled or emergency vent blowdowns. DOR components are required to be repaired during compressor station shutdown, well shutdown after a planned wait, or within two years.

• M21 – Soap solution is allowed for repair verification under certain conditions

(e.g., no moving parts or no surface temperature above the boiling point or below the freezing point of the soap solution).

Oil and Gas Air Regulations Equipment – Specific Requirements

NSPS OOOOa – Changes in Final Rule

• Low production well sites are not exempt.
• Fugitive emission component definition was changed to exclude

equipment types, such as uncontrolled storage vessels and vented emissions.

• Timing of initial monitoring – 60 days from startup of production.
• Owner/Operators must retain a record of each OGI monitoring survey.

The photographed or video must either include the latitude and longitude of the collection of sources imbedded within the photograph

• r video, or consist of an image of the survey being performed with a

separate GPS device with the same picture or video.

• Owner/Operators can either hang a leak tag on the leaking component
• r take a digital photograph, provided the photo is taken with an OGI

instrument and includes latitude and longitude.

Oil and Gas Air Regulations Equipment – Specific Requirements

NSPS OOOOa – Well Sites

• Collection of fugitive emission components at a well site – oil well,

gas well, or injection well and it’s associated well pad.

• Includes all ancillary equipment – valves, connectors, pressure relief

devices, open-ended lines, flanges, convers, and closed vent systems.

• Exemptions – devices that vent as part of normal operations, such

as natural gas-driven pneumatic controllers and pumps.

• Well sites that only contain one or more wellheads are not affected

facilities and are not subject to the fugitive emissions requirements.

• Emissions originating from other than the vent, such as the thief

hatch on a controlled storage vessel, would be considered fugitive emissions.

Oil and Gas Air Regulations Equipment – Specific Requirements

NSPS OOOOa – Compressor Stations

• Compressor station definition – includes natural gas transmission,

storage, gathering, and booster stations. Combination of one or more compressors located at a well site or natural gas processing plant is not a compressor station.

• Collection of fugitive components – includes valves, connectors,

pressure relief devices, open-ended lines, flanges, covers, and closed-vent systems.

• Affected facility – compressor station if an additional compressor is

added or if it is a replacement of greater horsepower.

• BSER – OGI survey.
• Follow-up monitoring – OGI or M21.
• M21 – Repair confirmation leak rate is 500 ppm.

Oil and Gas Air Regulations Equipment – Specific Requirements

• LDAR program based on

NSPS VVa

• Leak definitions – 500

ppm valves, 2,000 ppm pumps and annual connectors at 10,000 ppm

• Repair schedules –

5/15 day and delay of repair

NSPS OOOOa – Natural Gas Processing Plants

Oil and Gas Air Regulations Equipment – Specific Requirements

NSPS OOOOa – Fugitive Emissions Monitoring Plans

• Frequency for conducting surveys
• Technique for determining fugitive emissions (e.g., M21 or

OGI)

• Manufacturer and model number of fugitive emissions

detection equipment

• Procedures and timeframes for identifying and repairing

fugitive emissions component

• Procedures and timeframes for verifying fugitive emission

component repairs

• Records that will be kept and the length of time records will be

kept

Oil and Gas Air Regulations Equipment – Specific Requirements

NSPS OOOOa – Monitoring Plan Requirements

• Site map
• Defined observation path that ensures fugitive emission

components are within instrument sight

• If a facility is using M21, the plan must include a list of

fugitive emission components to be monitored and method for determining location of components

• The plan must include all components designated as

difficult-to-monitor or unsafe-to-monitor

Oil and Gas Air Regulations Equipment – Specific Requirements

NSPS OOOOa – Monitoring Plan Requirements / OGI

• OGI equipment must be capable of imaging gases in the

spectral range for the compound of highest concentration

• OGI equipment must be capable of imaging a gas that is half

methane, half propane at a concentration of 10,000 ppm at a flow rate 60g/hr

• Procedure for daily instrument verification
• Procedure for determining operator’s maximum viewing

distance

• Procedure for determining maximum viewing distance

Oil and Gas Air Regulations Equipment – Specific Requirements

NSPS OOOOa – Monitoring Plan Requirements / OGI

• Procedure for conducting surveys
• How the operator will ensure adequate thermal background
• How the operator will deal with adverse weather, such as wind
• How the operator will deal with interference (e.g., steam)
• Training and experience needed prior to perform surveys
• Procedures for instrument calibration and maintenance

Oil and Gas Air Regulations Equipment – Specific Requirements

NSPS OOOOa – Clarifications

• Owners / operators shall demonstrate compliance within 180

days of initial pr process unit

• cess unit startup. Applies to new, modified

and reconstructed sources.

• Defines annual connector monitoring for process units subject

to NSPS OOOO

• Capital expenditure calculation – was not revised in NSPS

OOOO and reverts to NSPS KKK, which references VV

• B value in the formula – based on IRS annual asset guideline repair

allowance for exploration and production including natural gas plant processing, specified as 4.5

Oil and Gas Air Regulations Equipment – Specific Requirements

• Applicable to MACT major and

area sources

• Major sources – affected

equipment includes glycol dehydration units, storage vessels and loading facilities

• Area sources – Triethylene Glycol

(TEG) dehydration unit

• VHAP is defined as a piece of

equipment that contains or contacts a fluid (e.g., liquid or gas) with a VHAP concentration > 10 percent by weight

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

Oil and Gas Air Regulations Equipment – Specific Requirements

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

• Equipment leak standards – only applies to equipment in VHAP

service at natural gas processing facilities

• HH – Amended in August 2012 - lower leak definition for valves at

500 ppm, pumps 10,000 ppm, and no connector monitoring

• Exemption – if the piece of equipment is not in VHAP service > 300

hours per year

Oil and Gas Air Regulations Equipment – Specific Requirements

MACT HHH – National Emission Standards for Hazardous Air Pollutants From Oil and Natural Gas Production Facilities

• Applies to owners and operators of natural gas transmission and

storage facilities that transport or store natural gas (i.e., downstream of natural gas plants)

• Applicable to MACT major transmission facilities
• For Subpart HHH – affected equipment is each glycol unit
• NDE initial monitoring M21 of CVS – annual visual thereafter

Oil and Gas Air Regulations Equipment – Specific Requirements

BLM Flaring Rule – LDAR Applicability

• Applicable – Existing well sites and all associated equipment used to

produce, process, compress, treat, store or measure natural gas (e.g., oil, and gas wells) allocated to a Federal or Indian lease.

• The rule also applies to equipment associated with produced

water.

• First Inspection – January 17, 2018 for sites that have begun

production prior to January 17, 2018.

• Within 60 days of beginning production for sites that begin

production after January 17, 2018.

• Within 60 days of the date where a site that was out of service

brought back into service and re-pressurized.

Oil and Gas Air Regulations Equipment – Specific Requirements

BLM Flaring Rule – LDAR Exemptions

• A site that contains a wellhead or wellheads and no other

equipment

• A well or well equipment that has been depressurized
• A component that is deemed “inaccessible”

Oil and Gas Air Regulations Equipment – Specific Requirements

BLM Flaring Rule – LDAR Inspection Requirements

• Existing well sites – semi-annually must be conducted at least 4

months apart

• Existing compressor stations – quarterly, must be conducted at

least 60 days apart

• New, modified, or reconstructed – well sites and compressor

stations will be required to comply with NSPS OOOOa

• Leak rates – NSPS OOOOa
• Approved instruments and methods – NSPS OOOOa
• Repairing leaks – NSPS OOOOa
• Reporting – annual report due to BLM by March 31, each

calendar year

Oil and Gas Air Regulations Equipment – Specific Requirements

• Determine if the “process unit”

has been reconstructed – NSPS Subpart A, 60.15

• Process unit reconstructed for

LDAR if you replace components (individual LDAR equipment) of an existing facility to the extent that:

• The fixed capital cost of the new

components exceeds 50 percent

• f the fixed capital cost that

would be required to construct a comparable new “affected facility” (e.g., process unit and a compressor)

Reconstruction

Oil and Gas Air Regulations Equipment – Specific Requirements

Modification

Modification means any physical change in, or change in the method of operation of, an existing facility, which:

• Increases the amount of any pollutant (to which a standard

applies) emitted into the atmosphere by that facility, or

• Results in the emission of any pollutant (to which a standard

applies) into the atmosphere not previously emitted

Oil and Gas Air Regulations Equipment – Specific Requirements

Two Part Test for LDAR Modification

Was there a net increase in VOC emissions?

• 1. Calculate your emission change. There is no deminimus increase

defined, so any increase meets the first part of the test. Example: adding one valve without removing a valve in the same service within the process unit would constitute an increase in

• emissions. If there is an emissions increase proceed to step 2.
• 2. Calculate if you have a “capital expenditure”
• 3. Addition or replacement of equipment (defined in 60.591) for the

purpose of process improvement which is accomplished without a capital expenditure shall not by itself be considered a modification

Oil and Gas Air Regulations Equipment – Specific Requirements

Capital Expenditure

NSPS VV section 60.481 explains how to calculate whether or not a facility has had a capital expenditure

• A facility is defined in the NSPS subparts as the group of equipment

in a process unit. Only the cost of LDAR-associated equipment, including pumps, valves, connectors, flanges, etc., are considered in the calculation. The cost of heaters, piping, vessels, heat exchanger and other process equipment in a process unit is not part of the facility for determining if there has been a modification for LDAR.

• Compressors are also not used in the modification calculation (see

60.591)

• A separate calculation must be made for each affected facility

Oil and Gas Air Regulations Equipment – Specific Requirements

Capital Expenditure Calculation

Capital expenditure defined. In addition to the definition in 40 CFR 60.2, an expenditure for a physical or operational change to an existing facility that:

• 1. P = Allowable amount of replacement cost that the project must be less than

for the project to not be considered a modification

• 2. B = Annual asset guideline repair allowance
• 3. R = Facility replacement cost (only LDAR related equipment/components)
• 4. A = Adjusted annual asset guideline repair allowance percentage (AAGRP)
• 5. X = 1982 minus year of construction of the “existing facility”
• 6. P = R x A
• 7. A = Y x (B/100)
• 8. Y = 1-0.575 log x

Oil and Gas Air Regulations Equipment – Specific Requirements

Modification – Scenario

• A natural gas processing facility was constructed in 2009. The

plant underwent a modification with the addition of new valves, pumps and connectors in the inlet processing unit. The contract with the engineering firm was executed on September 1, 2011. The original authorization for expenditure (AFE) for the entire project was $110,000,000 and the cost of the LDAR related equipment totaled $5,000,000. The additional pumps and valves for the modification totaled $100,000.

• Discussion - Is the $100,000 project expense considered a

capital expenditure? Did the facility trip a new LDAR regulation?

Oil and Gas Air Regulations Equipment – Specific Requirements

• YOC = 2009
• Change 2006 to 2011

(since that is the NSPS OOOO applicability date)

• Change B to 4.5 for oil and

natural gas sector

• X = 2011 – 2009 = 2
• Y = 1.0 – (0.575 * log (2)) = 0.83
• A = 0.83 * (4.5/100) = 0.04
• P = $5,000,000 * 0.04 = 200,000
• P = Replacement Cost is $200,000
• Project expense = $100,000

The $100,000 project expense is not considered a “capital expenditure” for modification because the project expense has to be greater than the replacement cost for the capital expenditure to be considered a modification. Because the facility modification was done after August 23, 2011, the NSPS OOOO date of 2011 was used in the calculation.

Answer

Oil and Gas Air Regulations Equipment – Specific Requirements

Applicability to More Than One NSPS / MACT Regulation

• What do you do when you are subject to more than one

NSPS or MACT regulation?

• A facility is still subject to each regulation that is applicable
• Look for overlap provisions in each of the regulations. They will

tell what part of each regulation is applicable

Oil and Gas Air Regulations Equipment – Specific Requirements

Common LDAR Pitfalls – Applicability, Inventory, and Tagging

• Not completing the calculation of capital expenditure for

modification under NSPS KKK, OOOO and OOOOa

• Modification of a process unit can only occur if there is an

increase in emissions combined with a capital expenditure

• Missing the initial monitoring event of 30 days for new

equipment in existing process units

• Missing equipment (e.g., storage tanks, glycol dehydrators) in

VHAP service that are greater than 10 percent VHAPs and subject to MACT HH

• Incorrectly identifying a “process unit” in a natural gas

processing facility

Oil and Gas Air Regulations Equipment – Specific Requirements

Common LDAR Pitfalls – Applicability, Inventory and Tagging

• Overlooking contiguous and adjacent facilities that potentially could be

subject to LDAR monitoring and reporting

• Failure to monitor all components associated with a wet gas compressor

(integral to the compressor) at a natural gas processing facility

• Failure to monitor all components in a process unit for two successive

months after tripping into a new regulation (e.g., KKK, OOOO, OOOOa)

• Incomplete or outdated weekly pump visual list including documentation

and recordkeeping

• The final repair follow-up reading does not count as the first of two

successive monthly readings after successful repair

Oil and Gas Air Regulations Equipment – Specific Requirements

LDAR Pitfalls – Method 21 Monitoring

• Collecting monitoring reading in less time than it takes to physically

move between two points in the facility

• Using an instrument which cannot detect the hydrocarbon in the

equipment or detect within the 10 X response factor range allowed by M21

• Failure to monitor all potential leak interfaces or monitoring too quickly
• Failure to monitor per M21 requirements – soap solution can be used

for follow-up monitoring

• Failure to monitor new valves for two successive months prior to placing

the valve on a quarterly schedule

• Changing a sub grouping of a valve within the monitoring schedule per

NSPS rules that monitoring is completed with the month period

• Failure to monitor connectors within 12 months

Oil and Gas Air Regulations Equipment – Specific Requirements

• Missing repair time frames

(first attempt and final repair)

• Missing instrument and
• perator identification, repair

methods, or repair attempt date information in leak log

• Facility maintenance personnel

missing final repair date

• Failure to monitor valves

placed on delay-of-repair on a routine schedule that are

• Failure to track and record all

repair attempts, including AVO’s

LDAR Pitfalls – Repairs

Oil and Gas Air Regulations Equipment – Specific Requirements

Presenter

Calvi Calvin Ni Niss ss

Senior Vice President cniss@trihydro.com

Oil and Gas Air Regulations Equipment – Specific Requirements

WHA WHAT WHY WHY WHERE WHERE WHEN WHEN WHO WHO HO HOW

Questions?

Presented by: Jay Christopher

Oil and Gas Air R Oil and Gas Air Regulations gulations Eq Equipment – uipment – Specif pecific R c Requirements irements

Overview

We will summarize the air regulatory requirements in terms of regulated equipment/operations, including:

• Gas venting with workovers and completions with hydraulic

fracturing

• Production
• Storage Vessels
• Pneumatics
• Compressors
• Glycol Dehydrators
• Flares

Oil and Gas Air Regulations Equipment – Specific Requirements

Oil & Gas Operations – Gas Well Modifications

• Fracturing/re-fracturing an existing natural gas well = NSPS

modification

• Gas wells that are re-fractured and use RECs plus completion

combustion controls are not considered modifications

• But these wells must meet all notification, recordkeeping, and

reporting requirements

• Ultimately, not much difference, but better to avoid an NSPS

trigger

• Significant recordkeeping/reporting requirements
• Geotagged photo of green completion operations, responsible
• fficial self-certification, and many, many more

Oil and Gas Air Regulations Equipment – Specific Requirements

“Well completion following fracturing or refracturing where gas flowback that is otherwise vented is captured, cleaned, and routed to the flow line or collection system, re-injected into the well or another well, used as an on-site fuel source,

• r used for other useful purpose

that a purchased fuel or raw material would serve, with no direct release to the atmosphere.”

Production Operations – Reduced Emissions Completion

Oil and Gas Air Regulations Equipment – Specific Requirements

• NSPS OOOO is the primary

rule

• State regulations

important too

• Controls
• Flares, seals, piping
• Quad O – “once in always

in”

• If you fall to 4 tpy you can

move flares but still have requirements

Production Operations – Reduced Emissions Completion

Oil and Gas Air Regulations Equipment – Specific Requirements

Storage Vessels

• 6 tons per year actual emission limit per tank for Quad O
• Leak detection requirements for Quad Oa
• Calculations challenges for tank emissions – look at the

Noble Energy and Slawson Consent Decrees

• Challenge of keeping the system leak tight and getting

the vapors to controls while not over pressurizing the tanks

• Pressure relief valves or thief hatches frequent venting is a

serious problem, easily seen by IR camera

Oil and Gas Air Regulations Equipment – Specific Requirements

Storage Vessels - Applicability

• Applies to each new, modified, or reconstructed storage vessel

in oil or natural gas production operations, natural gas processing, or natural gas transmission/storage facilities

• Storage vessel on mobile equipment (e.g., frac tanks) that is

intended to be located at a site for at least 180 days is an affected storage vessel (OOOOa adds requirement to demonstrate less than 180 days onsite)

• Excludes surge control vessels, knockout vessels, and pressure

vessels designed to operate without emissions to atmosphere

• Adding a new source (well) to a tank battery is a modification

Oil and Gas Air Regulations Equipment – Specific Requirements

• Enforceable controls to stay

under 6 tpy (can be permit, permit by rule, and other “legally and practically enforceable” requirement)

• If VOC emissions >6

tons/year, reduce emissions by 95%. Controls may be fixed roof with control device

• r floating roof (meets NSPS

Kb).

Storage Vessels - Limits

Oil and Gas Air Regulations Equipment – Specific Requirements

Storage Vessels - Applicability

• State programs may require additional plans and

requirements

• States are aggressively and actively establishing new

requirements, particularly around storage vessel vapor controls

• Most states specify controls for existing storage vessels that have

emissions greater than 6 tons per year VOCs

• Different calculation methods and their limitations
• Simulations only as good as analytical results
• E&P Tanks, older program based on traditional wells (heavier)
• HYSYS and ProMax, expensive process design software packages

Oil and Gas Air Regulations Equipment – Specific Requirements

Natural gas-driven pneumatic equipment has become a significant regulatory focus.

Pneumatic Equipment

Oil and Gas Air Regulations Equipment – Specific Requirements

Pneumatic Controllers – Production Sites

• Each continuous bleed natural gas-driven pneumatic

controller with a bleed rate > 6 scfh is a separate affected device under the NSPS OOOO

• New or modified, located between wellhead and custody transfer

point

• No bleed and low bleed required when replaced
• Exemptions for high bleed pneumatics necessary for

safety and operational need

• Inventory – tagging, management requirements if high

bleed

Oil and Gas Air Regulations Equipment – Specific Requirements

Pneumatic Pumps – Production Sites

• Each natural gas-driven diaphragm pump is a separate

pneumatic pump affected facility.

• Exempt if in operation less than 90 days per calendar year; records

must be kept to demonstrate this.

• Newly affected pumps must be routed to 95% efficient control

device or to process, but:

• OK to route to existing control with less than 95% efficiency
• If technically infeasible to route to process (at existing site only)
• Annual report includes newly affected pumps, control

approach, and any deviations.

Oil and Gas Air Regulations Equipment – Specific Requirements

Pneumatic Controllers – Natural Gas Plants

• Each continuous bleed natural gas-driven pneumatic

controller with a bleed rate > 6 scfh is a separate affected device under the NSPS OOOO

• New or modified, located between wellhead and custody transfer

point

• Zero bleed controllers required (i.e., air-driven)
• Exemptions for high bleed pneumatics necessary for

safety and operational need

• Inventory – tagging, management requirements if high

bleed

Oil and Gas Air Regulations Equipment – Specific Requirements

Pneumatic Controllers – GHG Reporting

• Emissions must be reported for the following categories
• Production facilities
• Onshore natural gas transmission compression
• Underground natural gas storage
• Gathering and boosting
• Calculation based on count of each type of pneumatic, a

published emission factor, hours run and concentration

• f GHG in the gas

Oil and Gas Air Regulations Equipment – Specific Requirements

EPA’s requirements for compressors focus on frequent emission points and Subpart W emission measurement.

Compressors

Oil and Gas Air Regulations Equipment – Specific Requirements

Compressors

• Commenced construction definition is different than

NSPS General Provisions

• NSPS OOOO – August 23, 2011
• Commenced construction = installation date
• Relocation of existing compressors is excluded; moving a

compressor does not trigger NSPS requirements

• Centrifugal compressors with dry seals are not “affected

facilities”

Oil and Gas Air Regulations Equipment – Specific Requirements

Compressors

• Operation and maintenance requirements under NSPS

OOOO

• Reciprocating compressors rod packing seals changed every 36

months or 26,000 operating hours

• Centrifugal compressor wet seal systems routed through closed

vent system to 95% efficiency control device

• Both have various recordkeeping and reporting requirements,

and the control device on the centrifugal wet seal system is subject to performance testing

Oil and Gas Air Regulations Equipment – Specific Requirements

Compressors

• New Gathering and Boosting Segment for Subpart W (GHG)
• Need count of compressor and type – centrifugal or reciprocating

(screws not included in any air reg)

• Emissions based on emission factor
• Subpart W requires field testing of compressor vent emission

flow rates (except for Gathering and Boosting Segment compressors)

• Blowdown vents
• Rod packing vents
• Unit isolation valves

Oil and Gas Air Regulations Equipment – Specific Requirements

Compressors

• Permit changes
• Many states now requiring emissions be submitted on annual

inventories

• New facilities, some states putting emission limits or requiring

controls

• Some states requiring LDAR even if not required by Federal

regulation

Oil and Gas Air Regulations Equipment – Specific Requirements

• NESHAP HH and HHH
• Area sources split out by

urban and non urban

• Rule benzene focused, less

than 1 tpy is generally exempt from both major and area sources requirements

• State requirements and

potential permit requirements

Glycol Dehydrators

Oil and Gas Air Regulations Equipment – Specific Requirements

Glycol Dehydrators

• Subpart W
• Under 0.4 MMcfd - only need a count
• Commonly used emission estimation tools - Gly-Calc and

ProMax

• Must use Peng-Robinson equation of state if there are choices in

computer program

• Gathering and Boosting Segment will pull in hundreds if

not thousands of dehydrators into the regulation

Oil and Gas Air Regulations Equipment – Specific Requirements

• NSPS OOOO requires

combustors/flares to meet NSPS Subpart A

• EPA is certifying

combustor models under Quad O

• Auto ignitors
• Pilot monitoring
• 95% vs 98% controls

Flares and Combustors

Oil and Gas Air Regulations Equipment – Specific Requirements

• Potential for new flare

requirements at gas plants

• Monitoring
• Steam-assisted
• Subpart W reporting –

inconsistent across various reporting categories, so be sure to verify where the emissions should be reported

Flares and Combustors

Oil and Gas Air Regulations Equipment – Specific Requirements

Amine Sweetening Units

• NSPS LLL
• Sources constructed between Jan 20, 1984 and Aug 23, 2011
• After 2011 covered by Quad O
• Percent sulfur reduction limit based on sulfur feed rate and H2S

concentration of acid gas stream and plant size (79.0 – 97.9%)

• If facility is less than two long tons per day capacity, only

recordkeeping and reporting requirements apply

Oil and Gas Air Regulations Equipment – Specific Requirements

Amine Sweetening Units

• Subpart W - (applies to all acid removal vents, not just amine

units)

• Only required to report CO2 (not methane) vented directly to the

atmosphere or through a flare, engine or sulfur recovery plant

• Can be measured with a CEMs
• Calculated based on a flow meter measurements and the CO2

composition of gas

• Modeled with a software simulation that uses the Peng-Robinson

equation of state such as HYSIS, AMINECalc or ProMax

Oil and Gas Air Regulations Equipment – Specific Requirements

Presenter

Oil and Gas Air Regulations Equipment – Specific Requirements

Ja Jay C y Christ ristopher

• pher

Senior Scientist Specialist jchristopher@Trihydro.com

WHA WHAT WHY WHY WHERE WHERE WHEN WHEN WHO WHO HO HOW

Questions?

Presented by: Chad Flynn

Oil and Gas Essentials Oil and Gas Essentials Re Record rdkeeping & & Re Reporting

NSPS OOOOa – Fugitive Emissions Monitoring Plans

• Frequency for conducting surveys
• Technique for determining fugitive emissions (e.g., M21 or

OGI)

• Manufacturer and model number of fugitive emissions

detection equipment

• Procedures and timeframes for identifying and repairing

fugitive emissions component

• Procedures and timeframes for verifying fugitive emission

component repairs

• Records that will be kept and the length of time records will be

kept

Oil and Gas Essentials ‐ Recordkeeping & Reporting

NSPS OOOOa – Monitoring Plan Requirements

• Site map
• Defined observation path
• If a facility is using M21, the plan must include a list of fugitive

emission components to be monitored and method for determining location of components

• The plan must include all components designated as difficult-

to-monitor or unsafe-to-monitor

Oil and Gas Essentials ‐ Recordkeeping & Reporting

NSPS OOOOa – Monitoring Plan Requirements / OGI

• Procedure for conducting surveys
• How the operator will ensure adequate thermal background
• How the operator will deal with adverse weather, such as wind
• How the operator will deal with interference (e.g., steam)
• Training and experience needed prior to performing surveys
• Procedures for instrument calibration and maintenance

Oil and Gas Essentials ‐ Recordkeeping & Reporting

OOOOa – OGI Recordkeeping

• Surveys
• Date of the survey
• Beginning and end time of the survey
• Facility name and type
• Name of operator(s) performing survey
• Training and experience of the operator
• Monitoring instrument used
• Monitoring instrument verification check

Oil and Gas Essentials ‐ Recordkeeping & Reporting

• Surveys (continued)
• Site photo
• Ambient temperature
• Sky conditions
• Maximum wind speed
• Deviations from the

monitoring plan or a statement that there were no deviations from the monitoring plan

OOOOa – OGI Recordkeeping

Oil and Gas Essentials ‐ Recordkeeping & Reporting

• Leaks
• Date and time leak found
• Component type
• Component sub type
• Optional information
• LDAR tag
• Description
• Photo/Video
• Lat/Long

OOOOa – OGI Recordkeeping

Oil and Gas Essentials ‐ Recordkeeping & Reporting

• Repairs
• Date and time repair was

attempted

• Repair status
• Repair method
• Repair confirmations
• Date and time repair was

confirmed

• Confirmation method

OOOOa – OGI Recordkeeping

Oil and Gas Essentials ‐ Recordkeeping & Reporting

BLM Venting/Flaring – Recordkeeping

• Records Maintained (not submitted)
• Date of the inspection
• Location (site) of the inspection
• Monitoring method used
• List of leaking components
• Date each leak was repaired

Oil and Gas Essentials ‐ Recordkeeping & Reporting

BLM Venting/Flaring –Reporting

• Annual Summary Report
• Due March 31 each year
• Number of sites inspected
• Number of leaks detected, by component type
• Total number of leaks repaired
• Total number of leaks not repaired, reason for delay,

and planned date of repair

• Certification statement by Responsible Office
• Submitted by SUNDARY Notice

Oil and Gas Essentials ‐ Recordkeeping & Reporting

Field Data Considerations

• Who is collecting it?
• How are they collecting it?
• How to ensure they’re following

the regulation?

• How do they know when to

recalibrate equipment?

• How do they track the last

survey event?

Oil and Gas Essentials ‐ Recordkeeping & Reporting

Equipment Considerations

• Field Equipment
• OGI camera
• Clipboard/Notebook
• Phone
• Ruggedized Tablet
• Intrinsically safe

Oil and Gas Essentials ‐ Recordkeeping & Reporting

• Data Management
• Data transcription
• Data synchronicity
• Notifications
• Survey status
• Photo associations

Recordkeeping Considerations

Oil and Gas Essentials ‐ Recordkeeping & Reporting

Regulations Considerations

• Regulation Overlaps
• Varying data capture requirements
• Different reporting requirements

Oil and Gas Essentials ‐ Recordkeeping & Reporting

Recordkeeping Considerations

• Regulation Overlaps (continued)
• Different survey windows
• Different leak and repair timeframes

Oil and Gas Essentials ‐ Recordkeeping & Reporting

Reporting Considerations

• Reporting
• CEDRI for OOOOa
• BLM submittal
• Summary tables
• Leak lists (date/region/etc.)

Oil and Gas Essentials ‐ Recordkeeping & Reporting

Solutions Considerations

• Software
• Excel
• Access
• Sharepoint
• LeakTracker Pro

Oil and Gas Essentials ‐ Recordkeeping & Reporting

Presenter

Oil and Gas Essentials ‐ Recordkeeping & Reporting

Cha Chad Flynn Flynn

Lead Project IT Professional cflynn@Trihydro.com

WHA WHAT WHY WHY WHERE WHERE WHEN WHEN WHO WHO HO HOW

Questions?

Presented by: Jay Christopher Cal Niss

Oil and Gas Air R Oil and Gas Air Regulations gulations What Happens Ne What Happens Next? xt?

We will discuss the following EPA enforcement methods:

• Today’s Regulatory

Environment

• National Enforcement

Priorities

• 114 Requests
• Information Collection Request
• Consent Decrees
• Optical Gas Imaging
• Next Generation Compliance

Overview

Oil and Gas Air Regulations What Happens Next?

What we assumed before may not be true any more:

• De-emphasis on GHG-

based regulations (but not States)

• Permitting changes

(particularly NSR)

• BLM Venting/Flaring ???
• NSPS OOOOa – changes

coming

Today’s Regulatory Environment

Oil and Gas Air Regulations What Happens Next?

• Air
• Reducing emissions of

hazardous air pollutants

• Energy Extraction
• Ensuring energy extraction

activities comply with environmental laws

• Protecting communities

from exposure to toxic air emissions

• Focus on local impacts

from energy development

EPA’s National Enforcement Priorities with Oil and Gas Focus

Oil and Gas Air Regulations What Happens Next?

Primary focus for air issues:

• Equipment leaks
• Flares
• Hazardous air pollutant

emissions (such as benzene)

EPA’s National Enforcement Priorities - Air

Oil and Gas Air Regulations What Happens Next?

EPA’s National Enforcement Priorities – Energy Extraction

• Oil and natural gas extraction/production - compliance

with existing laws

• Enforcement shifts to States – State and federal regulations.
• Natural gas development activities in energy rich areas of the

country have led to concerns about increases in air pollution levels, pollution of surface and ground waters, safety of community drinking water supplies, and damage to ecosystems.

• Greater use of advanced pollution monitoring and reporting

techniques and Next Generation technologies.

Oil and Gas Air Regulations What Happens Next?

EPA’s National Enforcement Priorities – Storage Tanks

• Organic liquid storage tanks
• Storage tanks are an easy target
• States/EPA using optical gas imaging cameras.
• EPA/States believes these emissions are the result of expansion
• f production volumes without corresponding increases in

emissions control systems, inadequate maintenance of tanks and associated emissions controls, and design flaws.

Oil and Gas Air Regulations What Happens Next?

EPA 114 Requests – What Are They?

• Lower frequency, but still happening
• Broad authority under Section 114(a) of the Clean Air Act

to collect information

• Often the starting point of enforcement initiatives and

significant enforcement actions

• Due to the amount of information requested, 114

requests can seem overwhelming

Oil and Gas Air Regulations What Happens Next?

EPA 114 Requests – What Should You Do?

• Involve your legal counsel from the start. Follow the instructions!
• A timely response is very important, make an immediate data gathering

plan

• Document when you received the request (response due based on receipt date)
• Be prepared to commit significant resources and costs
• Be prepared to gather information not required by current permits or regulations
• Document who obtained data, and where from
• Carefully evaluate the request and tailor response to provide exact data needed
• Flag business confidential data and discuss with EPA
• Request an extension if needed, consider phased response with first

phase fulfilling most of the response

Oil and Gas Air Regulations What Happens Next?

114 Requests - Production

• Focused on tank vapor emission control
• Very detailed
• Details on all separators and piping, including diameters
• Includes details that are not commonly available
• What triggers dump valve activation?
• Production information
• Pressure settings of tank hatches and pressure relief valves
• Estimated emissions and methodology
• Much more (see example on flash drive)

Oil and Gas Air Regulations What Happens Next?

114 Requests – Natural Gas Plants

• Focused on Leak Detection and Repair (LDAR) programs, and

particularly modification triggers

• Summary and general history of the facility including process

units, and equipment associated with each process unit

• List of equipment (e.g., valve, pump, compressor, PRD, etc.)

and equipment sub–type (e.g., gate-valve, check-valve, dual- seal pump, flange, screwed connector, etc.), piping sizes

• Date of physical installation and/or in VOC service date
• Hot topics! Drill & tap, and steam-assisted flares

Oil and Gas Air Regulations What Happens Next?

114 Requests – Natural Gas Plants

• Whether equipment is in VOC, VHAP, or wet gas service
• Indicate the regulations for which the equipment is subject
• Provide in editable format a copy of the facility LDAR database
• Provide copies of any calculations to determine applicability or

non-applicability of NSPS KKK, OOOO, or OOOOa

• Provide a detailed analysis indicating whether the facility is

subject to NSPS NNN and RRR

• Provide semi-annual LDAR reports, LDAR database for 5 years
• Much more (see flash drive)

Oil and Gas Air Regulations What Happens Next?

Consent Decrees – How Do They Happen?

• Releases observed by Federal/State inspectors using infrared

cameras, site inspections, records

• Enforcement negotiations preceded by EPA 114 information

request

• Typical provisions
• Formal written programs or control system design evaluations with

upgrades as needed

• Implement Inspection and Preventative Maintenance Plan
• Periodic inspections using Approved Instrument Monitoring Method
• 3rd party audits

Oil and Gas Air Regulations What Happens Next?

Consent Decrees – Recent Examples

• Merit Energy - Kalkaska, Michigan Gas Plant
• Noble Energy Denver - Julesburg Field Operations,

Colorado

• Slawson Exploration – Williston Basin, North Dakota

Oil and Gas Air Regulations What Happens Next?

Consent Decrees – Merit Energy

Issues Cited by the EPA

• Comparative Monitoring
• Merit’s historic leak rate for the units EPA monitored was 0.3%, EPA

found 3.8%

• Open-ended valves or lines were discovered
• Failure to physically tag each leaking component with a

weatherproof tag marked with the equipment identification number

Oil and Gas Air Regulations What Happens Next?

Consent Decrees – Merit Energy

Issues Cited by the EPA

• Method 21 Issues – Failure to:
• Properly follow Method 21 monitoring methods
• Conduct monitoring on each component within the timelines laid out in

the rule

• Conduct required daily instrument calibrations
• Comply with insulated valve monitoring (probe did not reach the surface
• f the component interface)

Oil and Gas Air Regulations What Happens Next?

Consent Decrees – Merit Energy

Enforcement Stipulations

• Civil penalties totaling $885,000
• Required to implement an enhanced LDAR Program

facility-wide, composed of:

• Written LDAR program document
• No skip period monitoring
• Lower leak limits
• Enhanced reporting and recordkeeping requirements

Oil and Gas Air Regulations What Happens Next?

Consent Decrees – Merit Energy

Enforcement Stipulations (continued)

• No skip period monitoring (i.e., valves quarterly and pumps monthly,

allowing for regulatory DTM or UTM schedules as appropriate)

• Lower leak limits (500 ppm valves, 2000 ppm pumps)
• First attempt at repair at 250 ppm
• Drill and tap prior to putting valve on Delay of Repair (DOR)
• DOR signoff and other logistical steps
• Valve replacement program for chronic leakers with low emission

components

Oil and Gas Air Regulations What Happens Next?

Consent Decrees – Merit Energy

Enforcement Stipulations (continued)

• Initial detailed component inventory
• Initial valve tightening program for all newly installed valves
• Expedited (30 day) valve replacement timing for valves with initial

screening levels > 500 ppm

• Use of low emission packing material to repair valves
• Ensure that all replacement valves/pumps are evaluated

specifically for LDAR applicability in the facility MOC program

Oil and Gas Air Regulations What Happens Next?

Consent Decrees – Merit Energy

Enforcement Stipulations (continued)

• LDAR training requirements
• Enhanced LDAR QA/QC
• Daily LDAR monitoring technician sign-off that the day’s monitoring was

completed accurately

• Quarterly field verification of that the LDAR technicians are properly

implementing the LDAR program and records are properly maintained

• 3rd Party LDAR audits every other year (first one within the first year)
• Annual reports on the program, certified by high-level environmental

compliance official

Oil and Gas Air Regulations What Happens Next?

Consent Decrees – Noble Energy/Slawson Exploration

• Major operators in Colorado’s Denver-Julesburg and North Dakota’s

Williston basins

• Federal and State involvement, alleged SIP/FIP violations
• Focused on venting from storage tanks generally occurring during

separator dump cycles, releasing flash gases from the tanks

• “All condensate collection, storage, processing and handling operations,

regardless of size, shall be designed, operated, and maintained so as to minimize leakage of VOCs to the atmosphere to the maximum extent practicable”

• “Fluctuations in emissions that occur when the separator dumps into the

tank are reasonably foreseeable”

Oil and Gas Air Regulations What Happens Next?

Consent Decrees

• Stipulated penalty provisions for missing deadlines, etc.
• Significant reporting requirements

Oil and Gas Air Regulations What Happens Next?

Penalti nalties Noble

• ble

Sla Slawson son Civil Penalty $4.95 MM $2.1 MM Environmental Mitigation Projects $4.5 MM $1.5 MM + Supplemental Environmental Projects $4.0 MM $0

EPA’s Strategic Plan Concepts

• More Effective Regulations

and Permits

• Advanced Monitoring
• Electronic Reporting
• Expanded Transparency
• Innovative Enforcement

Next Generation Compliance

Oil and Gas Air Regulations What Happens Next?

http://www.epa.gov/compliance/next-generation-compliance

Optical Gas Imaging

• Forward looking infrared cameras that can see

hydrocarbons are a game changer for air compliance and enforcement

• Aliso Canyon (Porter Ranch), Los Angeles, California (link)
• Common tool for regulatory enforcement personnel
• Technology is advancing rapidly
• Intrinsically safe camera are here now
• Rebellion Photonics has a FLIR add-on that focuses on mass of

emissions

Oil and Gas Air Regulations What Happens Next?

Presenters

Oil and Gas Air Regulations What Happens Next?

Cal Ni Cal Niss ss

Senior Vice President cniss@Trihydro.com

Ja Jay C y Christ ristopher

• pher

Senior Scientist Specialist jchristopher@Trihydro.com

WHA WHAT WHY WHY WHERE WHERE WHEN WHEN WHO WHO HO HOW

Questions?

Thank You for Joining Us

Calvi Calvin Ni Niss ss

Senior Vice President cniss@trihydro.com

Ja Jay C y Christ ristopher

• pher

Senior Air Specialist jchristopher@trihydro.com

Cha Chad Flynn Flynn

Lead Project IT Professional cflynn@trihydro.com