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SPE-173558-MS
Implementing New State and Federal Air
Regulatory Programs – A Systematic Approach
To Compliance
Jay Christo...
OIL & GAS ENVIRONMENTAL COMPLIANCE IS BECOMING
INCREASINGLY COMPLEX
Slide 2
SPE-173588-MS • Implementing New State and Fed...
AIR REGULATIONS ARE EXPLODING!
Slide 3
HERE ARE A FEW OF THE MORE IMPORTANT AIR REGULATIONS
Slide 4
SPE-173588-MS • Implementing New State and Federal Air Regula...
MORE AND MORE AIR PERMITS
Slide 5
SPE-173588-MS • Implementing New State and Federal Air Regulatory Programs – A Systemati...
Source: USEPA; http://www.epa.gov/airquality/greenbook/map/map8hr_2008.pdf
Source: National Association of Manufacturers;
...
MORE AND MORE AIR REGULATIONS
Slide 7
SPE-173588-MS • Implementing New State and Federal Air Regulatory Programs – A Syste...
HOW CAN YOU DEAL WITH IT ALL?
Slide 8
SPE-173588-MS • Implementing New State and Federal Air Regulatory Programs – A Syste...
THE NEED TO DEMONSTRATE COMPLIANCE IS MORE
IMPORTANT NOW THAN EVER
Slide 9
SPE-173588-MS • Implementing New State and Fede...
SYSTEMATIC PROCEDURES AND PROTOCOLS
Slide 10
SPE-173588-MS • Implementing New State and Federal Air Regulatory Programs – ...
OPERATOR-BASED INSPECTIONS
Slide 11
SPE-173588-MS • Implementing New State and Federal Air Regulatory Programs – A Systema...
LOOK FOR OPPORTUNITIES TO GATHER DATA ONCE
Slide 12
• Several regulatory programs may use the
same data for compliance dem...
COMPLEXITY OF YOUR APPROACH DEPENDS ON YOUR EXISTING
SYSTEMS, OPERATIONS, AND PHILOSOPHY
Slide 13
• Some environmental dat...
Acknowledgements / Thank You / Questions
Jay Christopher, Trihydro Corporation
jchristopher@trihydro.com
Slide 14
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Implementing New State and Federal Air Regulatory Programs – A Systematic Approach To Compliance

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SPE E&P Health, Safety, Security, and Environmental Conference - Americas presentation on Implementing New State and Federal Air Regulatory Programs

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Implementing New State and Federal Air Regulatory Programs – A Systematic Approach To Compliance

  1. 1. SPE-173558-MS Implementing New State and Federal Air Regulatory Programs – A Systematic Approach To Compliance Jay Christopher, Trihydro Corporation
  2. 2. OIL & GAS ENVIRONMENTAL COMPLIANCE IS BECOMING INCREASINGLY COMPLEX Slide 2 SPE-173588-MS • Implementing New State and Federal Air Regulatory Programs – A Systematic Approach to Compliance • Jay Christopher Water Waste Air Permits, Controls, VOCs, Methane, GHGs NEPA
  3. 3. AIR REGULATIONS ARE EXPLODING! Slide 3
  4. 4. HERE ARE A FEW OF THE MORE IMPORTANT AIR REGULATIONS Slide 4 SPE-173588-MS • Implementing New State and Federal Air Regulatory Programs – A Systematic Approach to Compliance • Jay Christopher Air Permitting Programs Minor Source New Source Review Applies to a majority of production facilities. Prevention of Significant Deterioration (PSD) Applies to major emission source facilities in attainment areas. Non-attainment New Source Review Applies to major emission source facilities in non-attainment areas. New Source Performance Standards (NSPS) Subparts K, Ka, and Kb Standards of Performance for Storage Vessels for Petroleum Liquids Subpart GG Standards of Performance for Stationary Gas Turbines Subpart KKK Standards of Performance for Equipment Leaks of VOC From Onshore Natural Gas Processing Plants for Which Construction, Reconstruction, or Modification Commenced After January 20, 1984, and on or Before August 23, 2011 Subpart LLL Standards of Performance for SO2 Emissions From Onshore Natural Gas Processing for Which Construction, Reconstruction, or Modification Commenced After January 20, 1984, and on or Before August 23, 2011 Subpart IIII Standards of Performance for Stationary Compression Ignition Internal Combustion Engines Subpart JJJJ Standards of Performance for Stationary Spark Ignition Internal Combustion Engines Subpart KKKK Standards of Performance for Stationary Combustion Turbines Subpart OOOO Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution National Emission Standards for Hazardous Air Pollutants, Maximum Achievable Control Standards (NESHAP, MACT) Subpart H National Emission Standards for Organic Hazardous Air Pollutants for Equipment Leaks Subpart HH National Emission Standards for Hazardous Air Pollutants From Oil and Natural Gas Production Facilities Subpart VV National Emission Standards for Oil-Water Separators and Organic-Water Separators Subpart HHH National Emission Standards for Hazardous Air Pollutants From Natural Gas Transmission and Storage Facilities Subpart YYYY National Emission Standards for Hazardous Air Pollutants for Stationary Combustion Turbines Subpart ZZZZ National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines
  5. 5. MORE AND MORE AIR PERMITS Slide 5 SPE-173588-MS • Implementing New State and Federal Air Regulatory Programs – A Systematic Approach to Compliance • Jay Christopher • Air Permits – Issued by state environmental agencies (not oil and gas commissions), pre-construction, multiple requirements  Minor source New Source Review – most oil & gas wells  Prevention of Significant Deterioration – large facilities  Non-attainment New Source Review – poor air quality areas such as Jonah/Pinedale, Barnett, San Joaquin; very tight controls • Pay attention to forthcoming ozone rules!  EPA has proposed a 65 – 70 ppb ambient ozone requirement, and requested comment on 60 ppb.  Once finalized, this will have significant impact on development
  6. 6. Source: USEPA; http://www.epa.gov/airquality/greenbook/map/map8hr_2008.pdf Source: National Association of Manufacturers; http://www.nam.org/uploadedImages/NAM/Site_Content/Issues/Ozone%20Figure2%20New %20Regulations.jpg Projected 8-Hour Nonattainment (60 ppb) SPE-173588-MS • Implementing New State and Federal Air Regulatory Programs – A Systematic Approach to Compliance • Jay Christopher
  7. 7. MORE AND MORE AIR REGULATIONS Slide 7 SPE-173588-MS • Implementing New State and Federal Air Regulatory Programs – A Systematic Approach to Compliance • Jay Christopher • Federal Regulations  NSPS OOOO (“Quad O”)  Hydraulic fracturing completions  Storage tanks  Pneumatics  LDAR  MACT HH/HHH (Glycol dehydration processes)  BLM Onshore Order 9  GHG Mandatory Reporting Rule (Subpart W) • State Regulations  Colorado Regulation No. 7  Others already in effect and more coming
  8. 8. HOW CAN YOU DEAL WITH IT ALL? Slide 8 SPE-173588-MS • Implementing New State and Federal Air Regulatory Programs – A Systematic Approach to Compliance • Jay Christopher MAGIC?
  9. 9. THE NEED TO DEMONSTRATE COMPLIANCE IS MORE IMPORTANT NOW THAN EVER Slide 9 SPE-173588-MS • Implementing New State and Federal Air Regulatory Programs – A Systematic Approach to Compliance • Jay Christopher • Environmental agencies are just as critical to your operations as oil and gas commissions • The environmental regulations are complex, and often attempt to encompass all operations on a “one size fits all” basis • Some rules do not specify recordkeeping, but how do you demonstrate compliance without records? How do you deal with those situations …
  10. 10. SYSTEMATIC PROCEDURES AND PROTOCOLS Slide 10 SPE-173588-MS • Implementing New State and Federal Air Regulatory Programs – A Systematic Approach to Compliance • Jay Christopher … even if not required • Infrared cameras  Train camera operators  Written monitoring protocols  Keep video records?  Manufacturer calibrations  Daily instrumentation checks  Work process to deal with findings
  11. 11. OPERATOR-BASED INSPECTIONS Slide 11 SPE-173588-MS • Implementing New State and Federal Air Regulatory Programs – A Systematic Approach to Compliance • Jay Christopher … prove that the inspections are taking place • Proof is not just a weekly check box  Consistent training program (explain the requirements)  Documented inspection procedures  Findings that demonstrate inspections are real  Complete records (these are legal documents!)
  12. 12. LOOK FOR OPPORTUNITIES TO GATHER DATA ONCE Slide 12 • Several regulatory programs may use the same data for compliance demonstrations  Emissions inventories and greenhouse gas reporting  Greenhouse gas measurements and leak detection and repair programs • Take a comprehensive look at all data needs, and capture the data one time  Data historians  Environmental information management systems  Databases  Spreadsheets SPE-173588-MS • Implementing New State and Federal Air Regulatory Programs – A Systematic Approach to Compliance • Jay Christopher
  13. 13. COMPLEXITY OF YOUR APPROACH DEPENDS ON YOUR EXISTING SYSTEMS, OPERATIONS, AND PHILOSOPHY Slide 13 • Some environmental data management systems are great  Do they fit with your existing systems?  Do they cover the breadth of your operations?  Can it store the records you need?  Most importantly – do you have a champion to drive implementation and continuing use? • Sometimes a less exotic approach works perfectly The most critical point is that you establish a systematic approach to compliance, and that you incorporate sustaining that system in your plan SPE-173588-MS • Implementing New State and Federal Air Regulatory Programs – A Systematic Approach to Compliance • Jay Christopher
  14. 14. Acknowledgements / Thank You / Questions Jay Christopher, Trihydro Corporation jchristopher@trihydro.com Slide 14

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