Air Quality Compliance Training 12-8-16

2 Yourenvironmentalcomplianceisclearly ourbusiness.

Agenda Industry Structure Regulatory Structure Regulatory Overview


IndustryStructureOil Production, Natural Gas Production, and Natural Gas Processing

Well completionsStorage vesselsPneumatic devicesProcessing plantsCompressors/enginesFugitive emissionsLiquids unloadingGlycol dehydratorsProcessing units

Storage vesselsPneumatic devicesCompressors/enginesFugitive emissionsGlycol dehydrators

Pneumatic devicesFugitive emissionsPipeline blowdowns


Standards of Performance for New Stationary Sources (NSPS) – 40 CFR Part 60

National Emissions Standards for Hazardous Air Pollutants (NESHAP) – 40 CFR Part 63

40 CFR Part 98 – Mandatory Greenhouse Gas Reporting State Implementation Plan (SIP) Requirements

• PA Permit Requirements – 25 PA Code Chapter 127 General Permits – 25 PA Code Chapter 127 Subchapter H

• PA Emission Standards – 25 PA Code Chapters 123 and 129

RegulatoryStructure


Standards of Performance for New Stationary Sources (NSPS) – 40 CFR Part 60• Subpart OOOO ‐ Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution for which Construction, Modification or Reconstruction Commenced after August 23, 2011, and on or before September 18, 2015 Standards for well completions, compressors (reciprocating and centrifugal), pneumatic controllers, storage vessels, process units, and sweetening units

RegulatoryOverview


• Subpart OOOOa ‐ Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification or Reconstruction Commenced After September 18, 2015 Production, processing, transmission, and storage Expanded applicability includes:

RegulatoryOverview

Coverage Affected UnitsUnregulated Subpart OOOO sources • Hydraulically fractured oil well completions

• Pneumatic pumps• Well site fugitive emissions• Compressor site fugitive emissions

Subpart OOOO regulated VOC sources that are unregulated for GHG

• Hydraulically fractured gas well completions• Equipment leaks at natural gas processing plants

Common category equipment partially regulated for VOC only (except well site compressors)

• Pneumatic controllers• Centrifugal compressors• Reciprocating compressors


• Subpart Kb – Standards of Performance for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, or Modification Commenced After July 23, 1984 Requires storage vessels (19,812 gallons) be equipped with an internal floating roof, external floating roof, or closed vent system and control device, as applicable

Includes notification, monitoring, testing, recordkeeping, and reporting requirements

RegulatoryOverview


• 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 Affected facilities include compressors in VOC service or wet gas service and the group of all equipment except compressors within a process unit

Requires compliance with the equipment leak provisions of 40 CFR Part 60 Subpart VV

Includes notification, monitoring, recordkeeping, and reporting requirements

Currently regulated under Subparts OOOO and OOOOa

RegulatoryOverview


• 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 Requires a minimum SO2 emissions reduction efficiency based on sulfur feed rate and the sulfur content of the acid gas


Currently regulated under Subparts OOOO and OOOOa

RegulatoryOverview


• Subpart KKKK – Standards of Performance for Stationary Combustion Turbines combustion turbines with a heat input at peak load equal to or greater than 10.7 gigajoules (10 MMBtu) per hour and that commenced construction, modification or reconstruction after 2/18/05

Limits emissions of NOX and SO2 from affected units Includes notification, monitoring, testing, recordkeeping, and reporting requirements

RegulatoryOverview


• Subpart JJJJ ‐ emission standards for manufacturers and owners/operators of stationary spark ignition internal combustion engines Standards for NOX, CO, and VOC depending upon engine type, size, and date of manufacture


RegulatoryOverview


National Emissions Standards for Hazardous Air Pollutants (NESHAP) – 40 CFR Part 63• Subpart HH ‐ standards for affected units at both major and area source oil and natural gas production facilities At Major HAP Sources – Covers glycol dehydration units, storage vessels, ancillary equipment in volatile HAP service, and compressors in volatile HAP service

At Area HAP Sources – Covers triethylene glycol (TEG) dehydration units

RegulatoryOverview


• Subpart HHH – process vent standards for new and existing small and large glycol dehydration units located at natural gas transmission and storage facilities that are major sources of HAP emissions Limits emissions of BTEX compounds from new and existing small and large glycol dehydration units and requires the connection of a closed vent system and control device for large glycol dehydration units


RegulatoryOverview


• Subpart ZZZZ ‐ establishes emission limitations and operating limitations for hazardous air pollutants (HAP) emitted from stationary reciprocating internal combustion engines (RICE) located at major and area sources of HAP emissions Emission and operating limits depending on size and manufacture date of engines and HAP major/area source status


RegulatoryOverview


40 CFR Part 98 – Mandatory Greenhouse Gas Reporting• Subpart W ‐mandatory greenhouse gas (GHG) reporting for the following facilities: Onshore/offshore petroleum and natural gas production Onshore natural gas processing Onshore natural gas transmission compression Underground natural gas storage Liquefied natural gas (LNG) storage LNG import and export equipment Natural gas distribution Onshore petroleum and natural gas gathering and boosting Onshore natural gas transmission pipeline

RegulatoryOverview


Recent Subpart W Final Revisions• Intended to align leak detection methods with 40 CFR Part 60 Subpart OOOOa

• Subpart W sources subject to Subpart OOOOa: Fugitive emissions surveys Subpart W equipment leak survey calculations Use of “leaker” emission factors

• Subpart W sources not subject to Subpart OOOOa: Use of original calculation methods Voluntary use of new provisions

RegulatoryOverview


Pennsylvania SIP Requirements• Chapter 127 – Construction, Modification, Reactivation, and Operation of Sources §127.11 ‐ a person may not cause or permit the construction or modification of an air contamination source…unless the construction, modification, reactivation or installation has been approved by the Department

§121.1 “Air contamination source” ‐ Any place, facility or equipment, stationary or mobile, at, from or by reason of which there is emitted into the outdoor atmosphere any air contaminant

RegulatoryOverview


§ 127.14 Exemptions:• (9) Physical changes to sources when the Department has determined the physical changes to be of minor significance

• Document No: 275‐2101‐003: Air Quality Permit Exemptions• Exemption No. 38 ‐ Oil and gas exploration, development, and production facilities and associated equipment and operations Conditional exemption that includes emission limits, monitoring requirements, LDAR requirements, control requirements, and an overall requirement to comply with all applicable state and federal requirements including 40 CFR part 60 Subpart OOOO

• PADEP proposing draft GP‐5A to replace Exemption No. 38

RegulatoryOverview


General Permits• General Permit No. 5 ‐ Natural Gas Compression and/or Processing Facilities Limited to non‐Title V facilities Covers spark ignition internal combustion engines (SI ICE), simple cycle gas turbines, centrifugal compressors, glycol dehydration units and associated equipment, separators, natural gas fractionation, storage vessels, equipment leaks, pneumatic controllers and sweetening units

Incorporates applicable federal requirements Identifies best available technology (BAT) for affected sources

RegulatoryOverview


Pennsylvania Emission Standards –• 25 PA Code Chapter 123 – Standards for Contaminants

General emissions standards for sources• PM and SO2 from process sources and combustion units• Visible emissions limits• Fugitive emissions limits

• 25 PA Code Chapter 129 – Standards for Sources Reasonably Available Control Technology (RACT)

• Specifies RACT requirements for new and existing sources• NOX and VOC RACT based on Control Technique Guidelines (CTG) • EPA finalized CTG for oil and gas operations earlier this year

RegulatoryOverview


SubmitYourQuestionsNowforthePanelDiscussion


AirQualityRegulatoryDirection

Roy Rakiewicz| [email protected] | 610‐933‐5246 X127December 8, 2016



Agenda Federal Initiatives

• Information Collection Request

Pennsylvania Initiatives• General Permit (GP) 5A• GP‐5 Revisions• Existing Sources


Information Collection Request (ICR)• On November 10, 2016 U.S. EPA issued a final Information Collection Request (ICR) Requires existing oil and natural gas facilities to provide extensive information on facility operations

• Will apply to: Onshore production Gathering and boosting Gas processing Gas transmission Storage Import/export facilities.

FederalInitiatives


Information Collection Request (ICR) (cont.)• Part 1: Operator Survey

General information from ~15,000 onshore petroleum and natural gas production facilities

Facility‐level information (e.g., facility name, location, and contact information), as well as the quantities and types of equipment present at the facility

Owner/Operator must respond within 60 days after ICR is received Estimated industry cost: $14 Million

FederalInitiatives


Information Collection Request (ICR) (cont.)• Part 2: Detailed Facility Survey

EPA will use a statistical approach to select ~4,650 oil and natural gas facilities to participate in Part 2 of the ICR

Selected facilities required to provide detailed information on emissions sources and control practices

Owner/Operator must respond within 180 days after facility is selected Estimated industry cost: $24 Million

FederalInitiatives


General Permit No. 5a for well pads (pre‐proposal draft)• Would effectively replace exemption No. 38 for new unconventional operations

• 43 pages long• Required before drilling• Includes noise/odor control provisions• Includes annual compliance report, emissions report, and compliance certification by responsible official

PennsylvaniaInitiatives


Draft GP-5A Components1. General Requirements 8. Applicable Laws2. Contents 9. Compliance Requirement/Certification3. Definitions 10. Notification4. Applicability/Scope 11. Recordkeeping5. Prohibitions 12. Reporting6. Authorized Use 13. Source Testing7. Fees

DraftGP‐5A

• Applies only to non-Title V facilities• Authorizes construction/operation for a term of 5 years• Permit is not transferable – new GP-5A required for new owner• Fees include $1,700 application fee, $375 operating permit fee, $375 annual

administrative fee, and $300 fee for admin. amendments• Constraints to ensure compliance with annual limits• Includes noise control provisions


Draft GP-5A Source CoverageB. Fugitive Particulate Matter J. Tanker Truck LoadoutC. Well Drilling and Fracking K. Fugitive Emissions ComponentsD. Well Completions L. ControllersE. Natural Gas (NG) Fired Combustion Units M. PumpsF. Glycol Dehydration Units N. Emission Control DevicesG. Stationary NG Fired RICE Units O. PiggingH. Reciprocating Compressors P. Wellbore Liquids UnloadingI. Storage Vessels

DraftGP‐5A

• Permit sections for each source type include:• Compliance, notification, recordkeeping, and reporting, emission testing, and

periodic monitoring requirements (as applicable)


Regulations Incorporated into Draft GP-5ARegulations:40 CFR Part 60 Subpart JJJJ – Standards of Performance for Stationary Spark Ignition Internal Combustion Engines40 CFR Part 60 Subpart OOOO – Standards of Performance for Crude Oil Natural Gas Production, Transmission, and Distribution40 CFR Part 60 Subpart OOOOa – Standards of Performance for Crude Oil and Natural Gas Facilities 40 CFR Part 63 Subpart HH – National Emissions Standards for Hazardous Air Pollutants from Oil and Natural Gas Production Facilities 40 CFR Part 63 Subpart ZZZZ – National Emissions Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines

DraftGP‐5A

• Regulatory text is included in GP-5A – not incorporated by reference


Emission Limits Incorporated into Draft GP-5ANitrogen Oxides (NOX) – 100 tons per year (tpy)Carbon Monoxide (CO) – 100 tpySulfur Oxides (SO2) – 100 tpyParticulate Matter with an aerodynamic diameter of < 10 microns (PM10) – 100 tpyParticulate Matter with an aerodynamic diameter of < 2.5 microns (PM2.5) – 100 tpyVolatile Organic Compounds (VOC) – 50 tpyIndividual Hazardous Air Pollutants (HAP) – 10 tpyTotal HAP – 25 tpy

DraftGP‐5A

• No Greenhouse Gas (GHG) emission caps


Fugitive Particulate Matter

Drilling and Fracking

Well Completions

NG Fired Combustion Units

RegulatedOperations


Glycol Dehydration Units

Stationary NG SI Ignition Internal Combustion Engines

Reciprocating Compressors

Storage Vessels

RegulatedOperations


Fugitive Emissions Components• Fugitive emissions monitoring plan• Monthly auditory, visual, and olfactory (AVO) inspection

• Quarterly leak detection and repair program (LDAR) inspection Option to use optical gas imaging (OGI) or Method 21 inspections

Operators can reduce the frequency of inspection to semi‐annually if the percentage is less than or equal to 2% in two consecutive inspections

Leaks quantified using a high flow sampler

RegulatedOperations


• Leak definition: Any positive indication, whether audible, visual, or odorous, determined during an AVO inspection

Any visible emissions detected by an OGI camera A concentration of 500 ppm or greater detected by an instrument reading

First attempt of leak repair must occur within 5 calendar days

• The leak must be repaired within 15 calendar days unless: New part required (10 days after part receipt) or Two years if infeasible to perform without a shutdown, blowdown, or well shut‐in

RegulatedOperations


Tanker Truck Load‐Out

Controllers and Pumps

Emission Control Devices

Pigging Operations

RegulatedOperations


Wellbore Liquids Unloading Operations

RegulatedOperations


Draft Revised GP‐5: Natural Gas Compression Stations, Processing Plants, and Transmission Stations• Similar to GP‐5A

Same annual emissions caps

• 45 pages long• Includes noise/odor control provisions• Includes annual compliance report, emissions report, and compliance certification by responsible official

DraftRevisedGP‐5


Draft Revised GP-5 Source CoverageB. Fugitive Particulate Matter I. Storage VesselsC. Natural Gas (NG) Fired Combustion Units J. Tanker Truck LoadoutD. Glycol Dehydration Units K. Fugitive Emissions ComponentsE. Stationary NG Fired SI RICE L. ControllersF. Stationary NG Fired Combustion Turbines

M. Pumps

G. Reciprocating Compressors N. Emission Control DevicesH. Centrifugal Compressors O. Pigging

DraftRevisedGP‐5

• Permit sections for each source type include:• Compliance, notification, recordkeeping, and reporting, emission testing, and

periodic monitoring requirements (as applicable)


Regulations Incorporated into Draft Revised GP-5

40 CFR Part 60, Subpart KKK - Standards of Performance for Equipment Leaks of VOC from Onshore Natural Gas Processing Plants for which Construction, Reconstruction, or ModificationCommenced After January 20, 1984, and On or Before August 23, 201140 CFR Part 60, Subpart JJJJ - Standards of Performance for Stationary Spark Ignition Internal Combustion Engines40 CFR art 60, Subpart KKKK - Standards of Performance for Stationary Combustion Turbines

40 CFR Part 60, Subpart OOOO - Standards of Performance for Crude Oil and Natural Gas Production, Transmission, and Distribution for which Construction, Modification, or Reconstruction Commenced after August 23, 2011, and on or before September 18, 201540 CFR Part 60, Subpart OOOOa - Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification, or Reconstruction Commenced after September 18, 201540 CFR Part 63, Subpart HH - National Emission Standards for Hazardous Air Pollutants from Oil and Natural Gas Production Facilities40 CFR Part 63, Subpart ZZZZ - National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines

DraftRevisedGP‐5


NG Fired Combustion Units

Stationary NG Fired SI RICE

Stationary NG Fired Combustion Turbines

Centrifugal Compressors

DraftRevisedGP‐5


Fugitive Emissions Components• Monthly auditory, visual, and olfactory (AVO) inspections

• Quarterly leak detection and repair program (LDAR) inspection

• Option to use optical gas imaging (OGI) or Method 21 inspections

DraftRevisedGP‐5


Control of Existing Oil and Gas Operations• CTGs finalized by U.S. EPA on October 27, 2016• CTGs identify approaches to control VOC emissions from existing sources located in ozone nonattainment areas

• CTGs largely mirror Subpart OOOOa for the control of VOC emissions (except completions) https://www.epa.gov/sites/production/files/2016‐09/documents/og_ctg_draft_081815.pdf

• PADEP is required to submit SIP regulations for existing sources

ExistingSourceRules


Storage vessels• RACT for Condensate and Crude Oil Storage Vessels: Reduce emissions by 95 percent continuously from crude oil storage vessels with a PTE > 6 tpy of VOC

Compressors• Reciprocating – rod packing replacement 26,000 hrs.• Centrifugal – capture and control to 95%

Pumps and Controllers • Pumps ‐ natural gas bleed rate less than or equal to 6 scfh• Controllers – capture and rout VOC emissions to an existing control device unless technically infeasible

CTGRecommendations


Fugitive Emission Components at Well Sites With GOR Greater than or Equal to 300, that Produce, on Average, Greater than 15 Barrel Equivalents per Well per Day• Semiannual monitoring using OGI/M21 and repair of components that are found to be leaking

Fugitive Emission Components at Gathering/Boosting Stations• Quarterly monitoring using OGI/M21 and repair of components that are found to be leaking

CTGRecommendations


GHGCompliance

JP Kleinle| [email protected] | 610‐933‐5246 X120December 8, 2016



Agenda 40 CFR Part 98 Overview Definition of “Facility” Applicability Determination Considerations Compliance Demonstration Considerations


40CFRPart98Overview Greenhouse Gas

Reporting Program (GHGRP)

All aspects of the oil and gas industry are potentially subject to GHGRP

Petroleum and Natural Gas Systems became applicable in 2010 & 2016 https://www.epa.gov/ghgreporting/ghgrp‐and‐oil‐and‐gas‐industry


40CFRPart98Overview Subpart W

• Onshore petroleum and natural gas production wells1

• Onshore petroleum and natural gas gathering and boosting1

• Natural gas processing• Natural gas transmission compression• Liquefied natural gas (LNG) storage

1Combined emissions for all equipment within each hydrocarbon basin


40CFRPart98Overview Subpart W Fuel Combustion

• Onshore petroleum and natural gas production ‐ (c)• Natural gas distribution ‐ (i)• Onshore petroleum and natural gas gathering and boosting facilities ‐ (j)

Subpart C Fuel Combustion• Natural gas processing• Natural gas transmission compression• Liquefied natural gas (LNG) storage


40CFRPart98Overview Applies if emissions are 25,000 metric tons (Mton) CO2e or more per year from a “facility”

Annual report must be submitted by March 31 of each calendar year

Photo: http://idahopetroleumcouncil.com/natural‐gas‐production‐records‐from‐idaho‐well‐made‐public/


40CFRPart98Overview Facility becomes subject to the rule if the applicability threshold is exceeded at any time

Reevaluation of applicability is needed whenever there is any change that could cause a facilityto meet the applicability requirements

GHGRP applicability should be an ongoing process in virtually all environmental compliance programs

Photo: https://www.osha.gov/dep/industry_profiles/p_profile-138.html


Definitionof“Facility” Subpart W contains four (4) different definitions of Facility1. Facility with respect to natural gas distribution2. Facility with respect to onshore petroleum and

natural gas gathering and boosting 3. Facility with respect to onshore petroleum and

natural gas production 4. Facility with respect to the onshore natural gas

transmission pipeline segment


Definitionof“Facility” Facility with respect to onshore petroleum and natural gas production [40 CFR §98.238]• All petroleum or natural gas equipment on a single well‐pad orassociated with a single well‐pad and CO2 EOR operations thatare under common ownership or common control includingleased, rented, or contracted activities by an onshorepetroleum and natural gas production owner or operator andthat are located in a single hydrocarbon basin… Where aperson or entity owns or operates more than one well in abasin, then all onshore petroleum and natural gas productionequipment associated with all wells that the person or entityowns or operates in the basin would be considered onefacility.


EmissionsInventoryTool


CaseStudy Initial inventory: >497,000 Mton CO2e

• General/representative equipment counts Scaled up from 1 ‐3 well pads

• No analytical or general analytical• Equipment operation assumptions [8,760 hrs]


GHGs To Report 1. Natural gas pneumatic device venting2. Natural gas driven pneumatic pump

venting3. Well venting for liquids unloading4. Gas well venting during well completions

without hydraulic fracturing5. Well venting during well completions with

hydraulic fracturing that have a GOR…6. Gas well venting during well workovers

without hydraulic fracturing.7. Well venting during well workovers with

hydraulic fracturing that have a GOR…8. Flare stack emissions9. Storage tanks vented emissions from

produced hydrocarbons

10. Reciprocating compressor venting11. Well testing venting and flaring12. Associated gas venting and flaring from

produced hydrocarbons13. Dehydrator vents14. EOR injection pump blowdown15. Acid gas removal vents16. EOR hydrocarbon liquids dissolved CO2

17. Centrifugal compressor venting18. Equipment leaks (e.g., valves, connectors,

flanges)19. stationary or portable fuel combustion

equipment (e.g., well drilling and completion equipment, process heaters)

ApplicabilityConsiderations


ApplicabilityConsiderations Equipment types Equipment counts Production records Maintenance records Process operating parameters Fuel and product usage records Representative analytical data (e.g., brine, condensate, produced water, oil, and flash vapor)

Leak detection data (e.g., optical gas imaging), leaker emission factors, & population factors


CaseStudy Final inventory: <16,000 Mton CO2e

• That’s a 480 Mton CO2e decrease• Detailed equipment counts• Detailed production records• Representative analytical used• Elimination of unnecessary equipment


ApplicabilityConsiderations 40 CFR Part 98, Subpart W has changed several times since its original promulgation in 2010—is your applicability analysis or emissions inventory up to date?

11/30/2010 Final Rule

9/27/2011 Finalized

Amendments

11/29/2011 Finalized

Amendments

12/23/2011 Finalized

Amendments

8/24/2012 Finalized

AmendmentsYou Get the

Picture1/29/2016 Proposed

Rule


ApplicabilityConsiderations New sources added by the October 22, 2015 Final Amendments to 40 CFR Part 98, Subpart W 1. Gathering and boosting facilities2. Completions and workovers of oil wells with

hydraulic fracturing Must include well identification numbers.

3. Blowdowns of natural gas transmission pipelines between compressor stations

Amendments in effect since January 1, 2016 and come into play with the annual report due March 31, 2017.


ComplianceConsiderations If not already reporting GHGs

1. Do I have a comprehensive applicability analysis demonstrating the 25,000 Mton CO2e threshold was not exceeded.

2. Do I perform regular reviews of my applicability analysis to verify no changes have occurred that would change the conclusion?.

4. Do I have complete equipment inventories?5. Emissions would need to be reported for the first

calendar year in which the 25,000 Mton CO2e threshold was exceeded.


If not already reporting GHGs Contd.4. Emissions reporting will begin with the first month of

the change and ending on December 31 of that year.5. Develop an auditable emissions inventory tool that

can be updated quickly to demonstrate future non‐applicability and aid in business decisions.

6. Facilities must calculate GHG emissions according to the specified calculation methodologies in Subpart W.

7. Discontinue use of Best Available Monitoring Methods (BAMM) after calendar year 2016 .

ComplianceConsiderations


40CFRPart98Reporting Reporting is a life sentence:

• Once a facility is subject it must continue to comply even if the facility no longer meets the applicability requirements in a future year.

Getting Out:• Reported CO2e emissions <25,000 MTon/year for five (5) consecutive years

• Reported CO2e emissions <15,000 MTon/year for three (3) consecutive years

• A notification that announces the cessation of reporting and explains the reasons for the reduction is required.


RICECompliance




Agenda RICE Overview

• Mobile vs. Nonroad vs. Stationary• RICE Terms

RICE Regulatory Overview• PA Permitting Options• NSPS & NESHAP

Compliance Requirements Overview• Notification, Testing, Monitoring, Reporting, Recordkeeping, etc.

Recommendations & Questions


Mobile&NonroadRICE

↗NONROAD →

↘

MOBILE


Stationary Engines are: NOT mobile NOT nonroad

Portable/transportable nonroad RICE becomes stationary if located onsite >12 consecutive months

StationaryRICE


RICE – Reciprocating Internal Combustion Engines CI – Compression Ignition SI – Spark Ignition

• 2S – 2 Stroke• 4S – 4 Stroke• 4SLB – 4 Stroke Lean Burn• 4SRB – 4 Stroke Rich Burn

RICETerms


25 Pa Code §127.11 : “…a person may not cause or permit the construction or modification of an air contamination source…or the installation of an air cleaning device on an air contamination source, unless the construction, modification, reactivation or installation has been approved by the Department”.

PARegulatoryOverview


Exemption No. 38• Only applicable for Oil & Gas Exploration, Development, & Production

• Conditional plan approval exemption• 180 days compliance demonstration• Do not need to show the use of best available technology (BAT)

• No term/expiration for authorization• No fee for PADEP review $0• RICE is not exempt from applicable state & federal regulations

PARICEPermittingOption1a


Request for Determination of Exemption from Plan Approval/Operating Permit (RFD)• No added benefit to Oil & Gas Exploration, Development, & Production Emissions exemption for RICE is the same as Exemption 38 RICE will still need to comply with Exemption 38

• Do not need to show the use of BAT• No term/expiration for authorization• No fee for PADEP review $0• RFD approved RICE is not exempt from applicable state & federal regulations

PARICEPermittingOption1b


General Plan Approval and/or General Operating Permits• GP‐5: Only applicable for natural gas compression and/or processing facilities and SI engines

• GP‐9: Only applicable for diesel or No. 2 fuel fired internal combustion engines

• GP‐11: Only applicable for nonroad CI engines BAT is addressed by meeting the emissions limitations Permit term is five (5) years and requires renewal PADEP fee: $375 for application and annually thereafter PADEP review: Approximately 30 days Not exempt from applicable state & federal regulations

PARICEPermittingOption2


Plan Approval• Requires the submittal of a plan approval application• Must show that the emissions will be the minimum attainable through the use of BAT

• Applicable state and federal regulations will be incorporated into the permit Permit term is five (5) years and requires renewal PADEP application & annual fees PADEP review: 130+ business days plus public review period

PARICEPermittingOption3


Most laborious application

130+ day review and additional public comment period

Maximum PADEP fees

BAT requirements

Temporary construction & shakedown permit

Operating Permit needed

Plan Approval

Moderate preparation

30-day approval

Nominal PADEP fees

Five (5) year term

More liberal emissions limits

General Permit

Easiest to prepare (possibly DIY)

No approval or fastest approval

No PADEP fees

No term / expiration

Tightest / most restrictive emissions limits

Exemption 38 & RFD

PARICEPermittingOptions


NSPS• 40 CFR Part 60, Subpart IIII [Standards of Performance for Stationary Compression Ignition ICE]

• 40 CFR Part 60, Subpart JJJJ [Standards of Performance for Stationary Spark Ignition ICE]

NESHAP• 40 CFR Part 63, Subpart ZZZZ [National Emissions Standards for Hazardous Air Pollutants for StationaryReciprocating Internal Combustion Engines]

FederalRICERegulations


Regulated pollutants:• NOX, CO, HCHO (formaldehyde), VOC & THC (non methane & non ethane)

Numeric limits Emissions reduction requirements U.S. EPA certification to meet the emissions standards in 40 CFR Subpart JJJJ

EmissionStandards


Emission Performance Testing• Initial Performance Testing

Typically within 180 days from commencement of operation

• Subsequent Performance Testing Typically every 8,760 hours of operation or 3 years

• Test Program Department approval required

• Protocol – 60 calendar days prior• Test notification – 10 calendar days prior• Test report – 60 calendar days after

Three 1‐hour runs required for most tests EPA and ASTM methodology

RegulatoryRequirementOverview


Emission Performance Testing Contd.• Periodic Emissions Monitoring Requirements

Typically every 2,500 hours of operation Portable gas analyzer may be used Three 20‐minute runs required for most tests Department approval required (i.e., protocol and results) ASTM methodology



Continuous Monitoring (Whenever Engine is In Operation)• Hours of operation utilizing a non‐resettable meter• Air‐to‐fuel rate controller• Catalyst temperature and pressure• Visual and audible alarm requirements• High temperature shutdown

Work Practice Standards• Operate per manufacturer instructions/owner‐developed maintenance plan

• Optional oil analysis program



Initial Notifications to U.S. EPA & PADEP• Typically no later than 30 days after construction has commenced

Semiannual/annual compliance reports Reporting and recordkeeping requirements

• Monthly emission estimates and supporting calculations to demonstrate compliance

• Monthly hours of operation• Maintenance plan and maintenance records• Emergency use records• Fuel usage records



OOOOaCompliance




Agenda OOOOa Introduction & Overview Well Affected Facilities

• Compressor Affected Facilities• Pneumatic Controller Affected Facilities• Pneumatic Pump Affected Facilities• Storage Vessel Affected Facilities

Fugitive Emissions at Well Sites and Compressor Stations

Reporting


OOOOaIntroduction&OverviewApplicability Date was September 18, 2015

Published in Federal Register June 3, 2016

Effective on August 2, 2016

Compliance Date was August 2, 2016

Initial Compliance Period Ends August 2, 2017


Added emissions standards for GHGs (methane)

Addresses sources OOOO doesn’t (e.g., Added crude oil wells)

Applies updated emission control requirements

Considered to be in compliance with OOOO when in compliance with OOOOa (NOT vice versa)

OOOO&OOOOaDifferences


“Affected Facility”• Any apparatus to which the standard is applicable• May have one or several affected facilities at the same location

A single well is an affected facility A single Pneumatic Controller is an affected facility

Etc.

OOOOaApplicability


Affected Facility Triggers = 1. Well hydraulically fractured or refractured2. Well completion operation commenced after

September 18, 20153. Natural gas and oil well completions

WellApplicability


1. Low Gas to Oil Ratio (GOR) Wells2. Low pressure, delineation and wildcat wells3. Non‐low pressure, non‐delineation and non‐

wildcat wells

WellAffectedFacilityTypes


1. Low Gas to Oil Ratio (GOR) Wells• <300 scf of gas per stock tank barrel of oil produced• Make the <300 scf determination and maintain records The location of the well; The United States Well Number; The specific exception claimed; The starting date and ending date for the exception; An explanation of why the well meets the claimed exception



2. Low pressure, delineation and wildcat wells• Must make the low pressure determination and maintain records (e.g., data input and calculations)

• Low pressure well means: The static pressure at the wellhead following fracturing but prior to the onset of flowback is less than the flow line pressure at the sales meter, or

The pressure of flowback fluid immediately before it enters the flow line is less than the flow line pressure at the sales meter [MUST use calculation in the rule 40 CFR §60.5432a], or

Flowback of the fracture fluids will not occur without the use of artificial lift equipment



1. Low Gas to Oil Ratio (GOR) Wells• No control or work practice requirements

2. Low pressure, delineation and wildcat wells• Any gas present in the flowback before the separator can function is not subject to control requirements

• Route all flowback to a completion combustion device • Completion combustion device must be equipped with a reliable continuous pilot flame

WellCompletionRequirements


3. Non‐low pressure, non‐delineation and non‐wildcat wells• Must have a separator onsite during the entire flowback period

• Initial flowback stage• Flowback must be routed to a separator as soon as a separator is able to function

• Separation flowback stage



3. Non‐low pressure, non‐delineation and non‐wildcat wells (cont.)• Separation flowback stage Liquids routing options:

1. One or more well completion vessels or storage vessels2. Re‐inject the recovered liquids into the well or another well3. Route the recovered liquids to a collection system

Gas routing options:1. Into a gas flow line or collection system2. Re‐inject into the well or another well 3. Use as an onsite fuel source4. Use for another useful purpose that a purchased fuel or raw

material would serve



Compliance phase in period ended:

November 30, 2016**Compliance phase in did not apply to refractured wells that were previously subject to OOOO. The owner operator must be in compliance upon startup of flowback.

WellAffectedFacilities


OOOOa Affected Components1. Located at a well site or compressor station2. Commence construction, modification, or

reconstruction after September 18, 20153. Has the PTE fugitive emissions of methane or VOC

Devices that vent as part of normal operations are not fugitive emissions components• Example: Snap action natural gas‐driven pneumatic

controllers

FugitiveComponentApplicability


Well Site Definition• Constructed for the drilling and subsequent operation of any oil well, natural gas well, or injection well

• Includes separate tank batteries collecting well site crude oil, condensate, intermediate hydrocarbon liquids, or produced water

Well Site Modification • A new well is drilled at an existing well site• A well at an existing well site is hydraulically fractured or refractured

FugitiveEmissionsComponents


Compressor Station Definition• Has any permanent combination of one or more compressors that move natural gas at increased pressure through gathering or transmission pipelines, or into or out of storage

• Compressors at a well site or onshore natural gas processing plant is not a compressor station

Compressor Station Modification • An additional compressor is installed at the compressor station

• One or more compressors are replaced by compressors with a greater horsepower



Well site exceptions• Well site containing only one or more wellheads is notsubject to OOOOa

Compressor station exceptions• Compressor replacement of equal or less horsepower does not trigger a modification and is not subject to OOOOa if replaced compressor was not originally subject



Fugitive emissions monitoring requirements• They are the same for well sites and compressor stations, excluding frequency

Basic requirements include:1. Preparation of a fugitive emissions monitoring plan 2. Conducting initial and periodic monitoring3. Repair of any components found to be leaking4. Verification (resurvey) that the repair was successful 5. Recordkeeping and reporting of monitoring

FugitiveEmissionsCompliance


Fugitive emissions means1. Any visible emission observed using OGI 2. An instrument reading of 500 ppm or greater using

Method 21



Well site frequency• Initial monitoring

By June 3, 2017 Within 60 days of startup of production, modification, or reconstruction

• Periodic monitoring No sooner than 4 months and no later than 6 months from previous survey



Compressor station frequency• Initial monitoring

By June 3, 2017 Within 60 days of startup of production, modification, or reconstruction

• Periodic monitoring No sooner than 60 days and no later than 3 months from previous survey

• Periodic monitoring exception When the average calendar month temperature is below 0 Fahrenheit for two of three consecutive calendar months Monitoring cannot be waived for two consecutive quarters



Fugitive monitoring plan requirements are specified in the rule

Must use an OGI camera or a Method 21 approved portable analyzer

Special provisions for monitoring components that are difficult or unsafe to monitor

Digital photograph and tagging requirements when a leaking component cannot be repaired during the survey



A leaking component must be repaired or replaced no later than 30 calendar days after detection

A leaking component must be resurveyed no later than 30 days after being repaired

Use either Method 21 or OGI to complete resurvey

Repair/replacement can be delayed 2 years or until next shutdown/shut‐in if the repair or replacement is technically infeasible or unsafe



First annual report due 90 days after the end of the initial compliance period• 08/02/2017 + 90 = 10/31/2017

Subsequent reports due annually on October 31 Reports must be submitted to the U.S. EPA via the Compliance and Emissions Data Reporting Interface (CEDRI).

If the electronic report is not available in CEDRI at the time that the report is due, you must submit hardcopy.

Reporting

Air Quality Compliance Training 12-8-16

Environment

Transcript of Air Quality Compliance Training 12-8-16