Complying with NSPS Regulations Governing Air Emissions from Natural Gas Well Sites

Transcription

1 Complying with NSPS Regulations Governing Air Emissions from Natural Gas Well Sites 28 January 2014 Prepared for ASTM Workshop on Site Characterization and Monitoring Related to Hydraulic Fracturing Activities

2 Recent EPA Regulations Affect Hydrofracking Operations Three Related Regulations New Source Performance Standards (NSPS) 40 CFR Part 60, Subpart OOOO Standards of Performance for Crude Oil and Natural Gas Production, Transmission, and Distribution National Emission Standards for Hazardous Air Pollutants (NESHAPS) 40 CFR Part 63, Subpart HH Oil and Natural Gas Production NESHAP 40 CFR part 63, Subpart HHH Natural Gas Transmission and Storage NESHAP 2

3 EPA s View of the Oil & Gas Industry Source: 3

4 Subpart OOOO Applies to Several Oil & Gas Operations NSPS Subpart OOOO Source Gas Well Centrifugal Compressors Reciprocating Compressors Pneumatic Controllers Well Site Gathering Gas Processing Transmission Storage Vessels Equipment Leaks Sweetening Units 4

5 Sets Four Requirements for Gas Wellheads Beginning 1/1/2015 (1/2) 1. Reduced Emissions Completion (REC) For duration of flowback: Route recovered liquids to storage vessel or re-inject recovered liquids into a well and Route recovered gas into a gas flow line or collection system or re-inject into a well, Use recovered gas as on-site fuel source, or Use recovered gas for another useful purpose that a purchased fuel or raw material would serve with no direct release to the atmosphere 5

6 Sets Four Requirements for Gas Wellheads Beginning 1/1/2015 (1/2) 2. All salable gas must be directed to flow line as soon as practicable. 3. Flowback emissions that cannot be directed to the transmission system must be captured and directed to a completion combustion device. 4. General duty to maximize resource recovery and minimize atmospheric releases during flowback & recovery. Note: 1&3 are the requirements for wells drilled after 8/23/

7 Requires Control of VOC Emissions from Storage Vessels Two categories of storage vessels Group 1: placed in service 8/23/11-4/11/13 Group 2: placed in service on/after 4/12/13 VOC emissions must be maintained below 6 tpy or they must be controlled Control means 95% reduction Group 1 vessels must comply by 4/15/15 Group 2 vessels must comply by 4/15/14 Alternate emission limits Reduce tank emissions 95% Demonstrate less than 4 tpy without control for 12 months 7

8 Describes Performance Requirements for Vessel Control Systems Control devices can be vendor certified Individual testing of vendor certified units is not required and operated such that: Inlet gas flow is equal to or less than design A pilot flame must be present at all times of operation No visible emissions by Method

9 Requires Control of VOC Emissions from Pneumatic Controllers For pneumatic controllers between the wellhead and gas processing plant constructed on or after 10/15/13, bleed rate must be less than 6 scfh 9

10 Establishes Detailed Recordkeeping and Reporting Requirements (1/2) In summary, facility must maintain info about the well and regulated equipment For gas wellheads: location API well number duration of flowback duration of recovery to the flow line duration of combustion duration of venting reasons for venting digital photo with latitude and longitude 10

11 Details Recordkeeping and Reporting Requirements (2/2) In summary, facility must maintain info about the well and regulated equipment For storage tanks: Identification, location information Documentation of emissions calculations Control device design and performance test data, if applicable For pneumatic controllers: Identification, location, date of installation, and manufacturer s specifications 11

12 OOOO Compliance Demonstration Requirements for Wells Are Challenging In most cases, there are no emission testing requirements. There are significant notification, recordkeeping, and reporting requirements for wells, storage vessels, and pneumatic controllers. Documentation must support tank emissions calculations and selection and use of control equipment. 12

13 Contact Information David L. Elam, Jr. TRC Environmental Corporation 5540 Centerview Drive Suite 100 Raleigh, NC