1 From Federal to State: New Air Rules for the Oil and Gas Sector Air Focused Oil & Natural Gas Regulation Update 21st Annual AWMA/NYWEA Joint Seminar Ona Papageorgiou, P.E. February 14, 2018 Division of Air Resources
2 Presentation Overview 1. Federal and state regulatory requirements 2. Oil & Natural Gas Sector Review 3. Oil & Natural Gas Air Emissions and Inventory 4. New Oil & Natural Gas Regulatory Proposals
3 The Clean Air Act I. Attainment of NAAQS II. Mobile Sources III. Air Toxics IV. Acid Deposition Control V. Operating Permits VI. Stratospheric Ozone VII. Enforcement
4 Title I Regulating Title I Sets standards for • Defines Attainment and Non-attainment Areas “criteria Pollutants” • New Source Performance Standards (NSPS) Particulate Matter (PM10) • New Source Review (NSR) for Large Sulfur Dioxide (SO2) Increases Nitrogen Oxides (NOx) Volatile Organic Compounds (VOC) • Control Technique Guidelines (CTGs) Carbon Monoxide (CO) Developed for Category Sources Lead (Pb) • Reasonably Available Control Technology (RACT)
5 Title III Regulating Title III Sets standards for • CAA requires EPA to develop standards for Hazardous Air Pollutants (HAPS ) HAPs (NESHAPs) EPA Established List Of 187 Hazardous Air • Regulated by “source categories” that Pollutants (HAPs) produce one or more HAPs Examples: Perchloroethylene (dry cleaning) • Control requirements are called Maximum Methylene chloride (solvent/paint stripper) Achievable Control Technology (MACT) Benzene (petroleum product)
6 Generally: Source Category (Industry Type) Pollutant Emissions (amount) Applicable Rule Example: Natural Gas Industry VOCs Area Source (minor) NSPS Subpart OOOOa
7 CAA to State Regulation Sets National Ambient Clean Air Act Air Quality Standards Requires States to National Ambient Air Attain Specific Levels of Quality Standards Criteria Air Pollutants A State Implementation If NAAQS are Not Met Plan (SIP) Must be then that State is in Developed non ‐ attainment
8 Types of Regulations New Source Performance Standards (NSPS) • Applies to new sources only Control Technique Guidelines (CTG) • Applies to existing sources • Applies only to States with non-attainment areas or that are in the Ozone Transport Region • Establishes minimum controls/requirements
9 Non-attainment area Areas in the United States that do not meet the national ambient air quality standard (NAAQS) for a criteria pollutant. Detected and recorded through a monitoring network.
10 Ozone Transport Region
11 Healthy lung tissue Air Pollutants Oil & Natural Gas sector regulations covered today: • 2 pollutants: volatile organic compounds & methane Ozone impacted • VOCs mix with NOx to form ozone unhealthy lung tissue • Methane is a potent greenhouse gas
12 Checkpoint We’ve reviewed how federal laws flow into state regulations. Now for a little oil and natural gas review…
13 1821: First 1626: Gas seeps, 1863: First oil commercial natural Lake Erie well drilled in gas well drilled 1627: Oil Seeps, Allegany County near Fredonia Cuba, NY
14 New York State Wells • 12,943 Wells reported in 2016 • Est. 75,000 Wells since 1820’s • Oil & gas produced in 2014 valued at ~ $101.5 million • ~ $3.04 million generated for local gov’t taxes • ~ $12.69 million royalties for landowners Source: http://www.dec.ny.gov/about/36033.html
15 Source: Wyoming State Geological Survey
16 Semantics “Fracking” Hydraulic fracturing High volume hydraulic fracturing Conventional Unconventional
17 Source: Wyoming State Geological Survey
18
19 Production Trends in New York State New York State Oil & Gas Production 1980 ‐ 2016 60000 1200 50000 1000 40000 800 Oil (1,000 bbl) Gas (mmcf) 30000 600 20000 400 10000 200 0 0 1979 1984 1989 1994 1999 2004 2009 2014 Year Gas (mmcf) Oil (1,000 bbl)
20 Checkpoint We’ve reviewed the oil and natural gas sector a bit. Now let’s focus on air emissions inventory and how that impacts regulation…
21 U.S. Methane Emissions by Source Source: EPA NSTAR, 2013
22 U.S. Oil & Gas Sector Emissions Source: EPA NGSTAR, 2014
23 Types of emissions Point Source emissions are Nonpoint source emissions collected under Title V of the require engineering judgment Clean Air Act and emission factors
24 Air Pollution Calculation Basics Activity rate may be: • Number of units • Fuel production • Well count Emission factor is developed through data collection
25 pneumatic valves… Let’s zoom in on Example:
26 Zoom In…
27 Zoom In…
28 Pneumatic Valves
29 Back to the inventory basics
30 Pneumatic Inventory � ���������,�����,� � � ���������,� � � ���� Where: E pneumatic,TOTAL,j = Total pneumatic device emissions of pollutant j in the county [ton/yr] E pneumatic,j = pneumatic device emissions of pollutant j for a type of well (oil/gas) [ton/yr] N well = total number of active gas (or oil) wells in county
31 Pneumatic Inventory Development
32 Why Inventory? Inventory Rules
33 The Path from Inventory to Regulation Progress/ Inform Inventory Modeling Growth Policy STATE ATTAINMENT NONPOINT COUNTY BASIN SCC SCC_DESC POLLUTANT STATUS EMISSIONS TPY FIPS 36017 ATTAINMENT Appalachian Basin 2310021300 PNEUMATIC DEVICES 100414 0.000623068 36017 ATTAINMENT Appalachian Basin 2310021300 PNEUMATIC DEVICES 108883 0.009813922 36017 ATTAINMENT Appalachian Basin 2310021300 PNEUMATIC DEVICES 1330207 0.002785622 36017 ATTAINMENT Appalachian Basin 2310021300 PNEUMATIC DEVICES 71432 0.011006722 36017 ATTAINMENT Appalachian Basin 2310021300 PNEUMATIC DEVICES 7783064 0.000147540 36017 ATTAINMENT Appalachian Basin 2310021300 PNEUMATIC DEVICES CH4 8.703950882 36017 ATTAINMENT Appalachian Basin 2310021300 PNEUMATIC DEVICES CO2 0.423936725
34 The Path from Inventory to Regulation Progress/ Inform Inventory Modeling Growth Policy Ambient air conditions 2008 Standard (buffalo area) 0.075ppm # of exceedances
35 The Path from Inventory to Regulation Progress/ Inform Inventory Modeling Growth Policy
36 The Inventory to Regulation Path Progress/ Inform Inventory Modeling Growth Policy
37 Checkpoint We’ve reviewed the impact air emission inventories have on regulations. Now let’s see what is going on with oil and natural gas regulation…
38 EPA’s suite of regulations for Oil & Natural Gas • June 3, 2016: New Source Performance Standard, NSPS OOOOa • June 3, 2016: Source Determination Rule • October 19, 2016: Control Technique Guideline (CTG)
39 NSPS OOOO & NSPS OOOOa NSPS OOOO • 2012 • VOC only NSPS OOOOa • 2016 • Methane and VOC • Expands regulation to other segments & processes
40 2016 NSPS OOOOa Revisions • Now includes oil well sites • Regulates methane • Extends requirements to “downstream” NG equipment Find and repair leaks Green completions for oil wells Limit emissions from new and modified pneumatic pumps Limit emissions from compressors Limit emissions from pneumatic controllers
41 2016 NSPS Revisions Comments • Some changes were made due to comments: Fixed schedule for monitoring leaks Allows alternative approaches to finding leaks Offers opportunity to use emerging and innovative technology to monitor leaks Phases in some requirements
42 Drain vent from single compressor
43 pressure relief valve thief hatch opened on relieving glycol pressure dehydrator regenerator stream pressure spark arrestor relief valve on dehydrator venting on top of knockout tank relieving condensate pressure storage tank
44 What is the driver? EPA published “Control Techniques Guidelines for the Oil and Natural Gas Industry” on October 20, 2016.
45 Oil & Natural Gas CTG EPA published “Control Techniques Guidelines for the Oil and Natural Gas Industry” on October 20, 2016. Sets RACT for VOC emissions from select oil and natural gas industry emission sources. CAA section 182(b)(2) gives states two years after the issuance of a CTG to put in place State Implementation Plan (SIP) revisions to address RACT for sources covered by that new CTG. Deadline: October 20, 2018
46 NYS Methane Reduction Plan • Released in May of 2017 • Suite of 25 actions to reduce methane emissions across New York State. Source: https://www.governor.ny.gov/news/governor ‐ cuomo ‐ releases ‐ plan ‐ cut ‐ methane ‐ emissions
47 Consideration other than RACT Information request Investigate other activities such as metering stations Other?
48 NSPS OOOOa: Where does it apply? Onshore only • Oil Production • NG Production • NG Processing • NG Transmission and Storage
49 Summary 1. Federal and State Regulatory Process 2. Oil & Natural Gas Sector Review 3. Oil & Natural Gas Air Emissions and Inventory 4. New Oil & Natural Gas Regulatory Proposals
50 Questions? Discussion
Recommend
More recommend
