Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution (40 CFR 60, Subpart OOOO) Air Quality Compliance

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1 Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution (40 CFR 60, Subpart OOOO) Air Quality Compliance By: Emily Ohde Division of Compliance Assistance KOGA Annual Conference July 17, 2014

2 Objectives 40 CFR 60, Subpart OOOO, Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution Hydraulically Fractured Natural Gas Wells Storage Vessels: crude oil, condensate, intermediate hydrocarbon liquids or produced water Annual Reporting Kentucky Air Quality Permitting Summary Resources (1)

3 Tell me more NEW SOURCE PERFORMANCE STANDARDS

4 New Source Performance Standards Affected Facility Natural Gas Well Applicability of 40 CFR 60, Subpart OOOO Production (Well Site) Gathering Gas Processing Centrifugal Compressors X X Reciprocating Compressors X X Pneumatic Controller X X X X Transmission Storage Vessels X X X X Equipment Leaks Sweetening Units X X (4)

5 Well Completion Operations HYDRAULICALLY FRACTURED NATURAL GAS WELLS (40 CFR 60, Subpart OOOO)

6 Well Completion Operations Applicability An hydraulically fractured well principally for the production of natural gas Conventional and horizontal wells Construction, modification or reconstruction after Aug. 23, 2011 Refracturing (6)

7 Well Completion Operations Wildcat: Types of Wells Outside known fields or the first well drilled in an O&G field where no other O&G production exists Delineation: Determine the boundary of a field or producing reservoir Low pressure wells: Reservoir pressure and vertical depth such that times the reservoir pressure (psia) minus times the vertical well depth (feet) minus psia is less than the flow line pressure at the sale meter (7)

8 Well Completion Operations Notification Requirement Submission of a Flowback Notification no later than two days prior to well completion. Anticipated date of well completion operation; Owner or operator contact information; API well number; Well location; Planned date for beginning of flowback; Certified by the owner or operator (responsible official) of the facility. Well Location: Latitude and longitude coordinates for each well in decimal degrees to an accuracy and precision of five (5) decimals of a degree using the North American Datum of 1983 (8)

9 Well Completion Operations Notification Requirement Kentucky Division for Air Quality: Form DEP 5034 Available at dep.ky.gov/formslibrary under Air Quality Compliance Assistance EPA Region IV: Provide required information E mail the notification to: r4wellcompletion@epa.gov (9)

10 Well Completion Operations Control Measures Hydraulically Fractured Well Completion Start Date Control Measure Natural gas wells Prior to Jan. 1, 2015 Completion Combustion Device Natural gas wells On or After: Jan. 1, 2015 Reduced Emissions Completions Wildcat, delineation or low pressure wells On or After: Jan. 1, 2015 Completion Combustion Device (10)

11 Well Completion Operations Control Measures, Cont. General duty to maximize resource recovery and minimize release to the atmosphere during flowback and subsequent recovery Route salable gas to the gas flow line as soon as practicable (11)

12 Well Completion Operations Completion Combustion Device (CCD) Any ignition device, installed horizontally or vertically, used in exploration and production operations to combust otherwise vented emissions from completions. Combustion as a safety hazard or prohibited by state or local regulations CCD is not a flare Thermal oxidation system using an open (without enclosure) flame. Flares are subject to requirements under 40 CFR (12)

13 Well Completion Operations Reduced Emissions Completions Recovered liquids are routed into storage vessels or re injected Recovered gases are directed to the flow line or collection system, re injected, used an on site fuel source or used in place of purchased fuel or raw material with no direct release to the atmosphere Capture and make available for use or sale Route salable gas to flow line as soon as practicable (13)

14 Well Completion Operations (14) Daily Logs Location of the well (5 decimal degrees); API well number; Duration of flowback; Duration of recovery to the flow line, combustion and/or venting (if applicable); Reasons for venting in lieu of capture or combustion (if applicable); and Records of deviations in cases where well completion operations with hydraulic fracturing were not performed in compliance (if applicable). Duration shall be specified in hours of time. You may use a digital photograph in lieu of the records described here, but you must retain the records of the digital photograph as specified in 40 CFR (a)(4).

15 Well Completion Operations Claims of Exception Location of the well (5 decimal degrees); API well number; Specific exception claimed; Starting date and ending date for the period the well operated under the exception; and Explanation of why the well meets the claimed exception. (15)

16 Well Completion Operations Recordkeeping Copy of Flowback Notification Daily log of the well completion operations Claims of Exception Copy of the Initial and Subsequent Annual Reports (16)

17 Post-Drilling Operations STORAGE VESSELS (40 CFR 60, Subpart OOOO)

18 Contains Crude oil Condensate Division of Compliance Assistance Storage Vessels Intermediate hydrocarbons Produced water AND Potential to emit 6 tons VOC /year Applicability NOT Applicable Fuel or chemical injection tanks Skid mounted or permanently mobile (<180 days) Process vessels (surge control, bottoms receiver, knockout) (18)

19 Storage Vessels Classification Construction, modification or reconstruction Group 1 Group 2 Aug. 23, 2011 April 12, 2013 (19)

20 Storage Vessels Control Measures Initial Compliance: Group 1 By April 15, 2015 After Aug. 23, 2011 On or before April 12, 2013 Group 2 By April 15, 2014 or within 60 days of startup After April 12, 2013 (20)

21 Storage Vessels Control Requirements If Potential to Emit 6 ton VOC /year (individual vessel) Reduce VOC emissions by 95.0 percent with use of a control device or floating roof Using a control device closed vent system Group 2: April 15, 2014 or within 60 days of start up Allows for 30 days to calculate emissions and 30 days (or 60 days from startup) to meet control requirements. (21)

22 Storage Vessels Alternative Emission Limit Demonstrate that the storage vessel uncontrolled actual emissions are < 4 ton VOC /year Monthly records are required Conduct 12 month rolling total of actual emissions If emissions increase (at or above 4 ton VOC /year), meet 95.0 percent reduction within 30 days. If associated with fracture or refracture, must meet 95.0 percent reduction as soon as liquids from the occurrence are routed to the storage vessel. (22)

23 Storage Vessels Production Decrease? Control equipment may be removed after 12 consecutive months in which uncontrolled actual emissions are < 4 ton VOC /year Maintain monthly recordkeeping If emissions increase (at or above 4 ton VOC /year), meet 95.0 percent reduction within 30 days. If associated with fracture or refracture, must meet 95.0 percent reduction as soon as liquids from the occurrence are routed to the storage vessel. (23)

24 Storage Vessels Assessing Potential Emissions Using accepted model or calculation method Ex. EPA Tanks Maximum Average Daily Throughput for a 30 day period of production prior to the applicable emission deadline (24)

25 Storage Vessels Assessing Potential Emissions Maximum Average Daily Throughput (30 day period) Day bbl Day bbl day period = 450 bbl 15 bbl/day Maximum Average (25)

26 Storage Vessels Assessing Potential Emissions Maximum Average Daily Throughput: Guidance indicates that <20 bpd crude oil or <1 bpd condensate will likely be <6 ton VOC /year Emissions are impacted by: Temperature and pressure of separator Tank size Liquid vapor pressure Flow rate Calculate using an accepted model/method (26)

27 Storage Vessel Notification Within the Initial Annual Report, identify each Group 1 storage vessel. Subsequent annual reports shall include all Group 2 storage vessels. Latitude and Longitude coordinates to 5 decimal degrees (27)

28 Storage Vessel Recordkeeping Documentation identifying each storage vessel, including location, for which construction, modification or reconstruction commenced during the reporting period and the date of occurrence; Documentation of the VOC emission rate determination; Records of deviations that occurred during the reporting period; Notification identifying each Group 1 and Group 2 storage vessel affected facility in the initial and subsequent annual reports; (28)

29 Storage Vessel Recordkeeping, cont. Statement that you have met the control requirements outlined for your storage vessels; Documentation of any storage vessel that is removed from service during the reporting period; Documentation of any storage vessels for which operation resumes during the reporting period; and Copies of any performance tests conducted in accordance with 40 CFR Maintain records on site or at a local office for a minimum of 5 years. (29)

30 Affected Facilities ANNUAL REPORTS (40 CFR 60, Subpart OOOO)

31 Annual Reports Affected Facilities Company name and address of the affected facility; An identification of each affected facility being included in the annual report; Beginning and ending dates of the reporting period; and Certification by a responsible official of truth, accuracy and completeness. This certification shall state that, based on information and belief formed after reasonable inquiry, the statements and information in the document are true, accurate and complete. Recordkeeping as defined for the affected facility (31)

32 Annual Reports Initial Annual Report Initial Annual Report due no later than 90 days after the end of the initial compliance period Compliance period began Oct. 15, 2012 due Jan for prior Oct Oct period Otherwise, compliance period is upon start up due no more than one year later, within 90 days of start up Well Completion Operations ONLY Initial compliance period begins upon startup of a well completion and ends no later than two (2) years after the initial startup date. May be less than one full year. (32)

33 Annual Reports Subsequent Annual Reports Registered Sources Due no later than the same date each year Permitted Sources Due no later than the same date each year Coincide with Title V reporting requirements Indicated under emission point reporting requirements in the source s issued permit (33)

34 Electronically Division of Compliance Assistance Annual Reports Submission to Kentucky Entitle: 40 CFR 60, Subpart OOOO Annual Report. Mail Division for Air Quality Program Planning and Administration Branch 200 Fair Oaks Lane, 1st Floor Frankfort, KY (34)

35 Annual Reports Submission to EPA Region IV Mail Air, Pesticides and Toxics Management Division Attn: Beverly Banister, Director US EPA Region 4, Atlanta Federal Center 61 Forsyth Street, S.W. Atlanta, GA (35)

36 Sourcewide Assessments AIR PERMITTING

37 Air Permitting Rules and Regulations Kentucky Air Quality Regulations Title 401 Kentucky Administrative Regulations (KAR) Chapters Federally Enforceable Regulations New Source Performance Standards (NSPS) National Emission Standards for Hazardous Air Pollutants (NESHAP) (37)

38 Air Permitting Terms Affected Facility An apparatus, building, operation, road or other entity or series of entities that emits or may emit an air contaminant into the outdoor atmosphere (401 KAR 52:001(4)) Source One (1) or more affected facilities contained within a given contiguous property line, which means the property is separated only by a public thoroughfare, stream or other right of way (401 KAR 52:001(65)) Potential to Emit Maximum capacity of a stationary source to emit a pollutant under its physical and operational design (401 KAR 52:001(56)) (38)

39 Air Permitting No registration or permit is required if PTE is <2 tpy of a Hazardous Air Pollutant (HAP) <5 tpy of combined HAPs <10 tpy of a Regulated Air Pollutant (RAP), and tpy: Tons per year i.e. VOC, NO X, CO, PM, SO 2 The source is not subject to an NSPS or NESHAP. Registration (401 KAR 52:070) State Origin Permit (401 KAR 52:040) Federally Enforceable State Operating Permit (401 KAR 52:030) Title V Permit (401 KAR 52:020) Prevention of Significant Deterioration (401 KAR 51:017) (39)

40 Air Permitting How does air permitting relate to NSPS applicability?? S O U R C E NSPS AF AF AF NSPS AF AF PTE Permit or Registration (40)

41 Quick Overview SUMMARY (40 CFR 60, Subpart OOOO)

42 Summary Well Completion-Affected Facilities Flowback Notification Keep records Daily log Claims of exception Submit Initial and Subsequent Annual Reports (42)

43 Summary Affected Facilities Sourcewide potential emissions assessment Review for other NSPS or NESHAPs that may apply Submit air quality registration or permit application Keep records Submit Initial and Subsequent Annual Reports, including storage vessel notifications (43)

44 Summary NO Affected Facilities Sourcewide potential emissions assessment Review for other NSPS or NESHAPs that may apply Submit air quality registration or permit application, as required Keep records (44)

45 Resources Electronic Code of Federal Regulations Ky. Division of Compliance Assistance Compliance Guide Ky. Division of Oil and Gas Operator Manual nual.pdf EPA Oil and Natural Gas Air Pollution Standards Storage Vessel Emission EPA Tanks Example Annual Report Template Colorado AP/CBON/ (45)

46 Contacts Division of Compliance Assistance DCA.ky.gov Division for Air Quality Air.ky.gov