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

1. SPE-173558-MS
Implementing New State and Federal Air
Regulatory Programs – A Systematic Approach
To Compliance
Jay Christopher, Trihydro Corporation

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. AIR REGULATIONS ARE EXPLODING!
Slide 3

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. MORE AND MORE AIR PERMITS
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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. 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. MORE AND MORE AIR REGULATIONS
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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. HOW CAN YOU DEAL WITH IT ALL?
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SPE-173588-MS • Implementing New State and Federal Air Regulatory Programs – A Systematic Approach to Compliance • Jay Christopher
MAGIC?

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. SYSTEMATIC PROCEDURES AND PROTOCOLS
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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. OPERATOR-BASED INSPECTIONS
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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. LOOK FOR OPPORTUNITIES TO GATHER DATA ONCE
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• Several regulatory programs may use the
same data for compliance demonstrations
 Emissions inventories and greenhouse gas
reporting
 Greenhouse gas measurements and leak
detection and repair programs
• Take a comprehensive look at all data
needs, and capture the data one time
 Data historians
 Environmental information management systems
 Databases
 Spreadsheets
SPE-173588-MS • Implementing New State and Federal Air Regulatory Programs – A Systematic Approach to Compliance • Jay Christopher

13. COMPLEXITY OF YOUR APPROACH DEPENDS ON YOUR EXISTING
SYSTEMS, OPERATIONS, AND PHILOSOPHY
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• Some environmental data management systems are great
 Do they fit with your existing systems?
 Do they cover the breadth of your operations?
 Can it store the records you need?
 Most importantly – do you have a champion to drive
implementation and continuing use?
• Sometimes a less exotic approach works perfectly
The most critical point is that you establish a systematic
approach to compliance, and that you incorporate sustaining
that system in your plan
SPE-173588-MS • Implementing New State and Federal Air Regulatory Programs – A Systematic Approach to Compliance • Jay Christopher

14. Acknowledgements / Thank You / Questions
Jay Christopher, Trihydro Corporation
jchristopher@trihydro.com
Slide 14