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Doug Deason - Annual Meeting


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Doug Deason - Annual Meeting

  1. 1. Oil and Gas Air Issues NAAQS in TransitionAIPRO - Arkansas Independent Producers and Royalty OwnersSeptember 29, 2011Little Rock, AR
  2. 2. Discussion TopicsFederal Oil and Gas rule & NAAQS changes underway MACT and NSPS Rulemaking National Ambient Air Quality Standards (NAAQS) Permits (Aggregation, PSD for SO2 and NO2 NAAQS, NEPA) 2
  3. 3. Old NSPS 3
  4. 4. NSPS Proposed August 23, 2011 Comments due October 31, 2011After proposal, new or modified facilities comply by 2/28/20124
  5. 5. Oil and Gas NSPS Overview Source Applicability Proposed Control Comment Devices Storage tanks >=1 bbl/d throughput of Close tank and route Applies to both new and replaced storage tanks condensate (≥ vents to a VRU, 40 API wt.) combustor, or >=20 bbls/d throughput flare that of crude oil (<40 achieves at least API wt.) 95% emissions Construction control. commenced after 8/23/2011 Centrifugal Installation commenced Must be equipped with a Final rule may allow for wet seal if controlled, but Compressor after 8/23/2011 dry seal currently not in proposed rule. Includes compressors moved from one site to another Reciprocating Installation commenced Replace rod packing Includes compressors moved from one site to another Compressor after 8/23/2011 every 26,000 hrs Pneumatic controllers All new or replaced Gas plants: instrument Natural gas is proposed as a surrogate for VOC controllers using gas is prohibited instrument gas. (air is ok) Construction All other sites: Gas driven commenced controller bleed after 8/23/2011 rate must be < 6 scfh 5Comments due October 31, 2011; extension request needed
  6. 6. NAAQS in Transition 1997 Ozone and PM2.5 NAAQS – Largely attained nationwide 2006-Oct. PM10 and PM2.5 NAAQS - Largely attained in the eastern U.S. 2008-Mar. 75 ppb 8-Hour Ozone (Primary & Secondary ) – Now confirmed 2008-Oct Lead NAAQS Final (Primary and Secondary) 2010-Jan. NO2 NAAQS Final (Primary only) – Significant permitting issue 2010-June SO2 NAAQS Final (Primary only) – Attainment by modeling an issue. 2011- Aug. CO NAAQS Final – No proposed changes 2011- Sept. 2 Ozone reconsideration – Terminated by President Obama 2012-March NOx / SOx Secondary – Proposed no combined new form 2012- ? PM10 and PM 2.5 NAAQS (Primary and Secondary)- How much lower? Source: EPA Information 6
  7. 7. U.S. 2008-2010 Ozone Design Values Status Arkansas Counties(ppb)-(Crittenden-74, Polk-70, Pulaski-70, Newton- 66, Washington-64) Based on 2008-2010 data retrieved from AQS Data Mart on January 27, 2011 Includes counties with incomplete and uncertified data Design values for monitors in Alaska, Hawaii, and Puerto Rico Legend monitoring sites (not shown) were Numbers of counties are in parentheses below 61 ppb 0 - 60 ppb (60) 61 - 75 ppb (538) 76 - 84 ppb (96) > 84 ppb (16)In 2010, 102 Counties have Air Quality exceeding the 2008 Ozone NAAQS; NONE in Arkansas 7
  8. 8. EPA Ozone NAAQS 2011-’12 Actions  2008 Ozone NAAQS –  Applies for PSD and NEPA permitting  No non-attainment designations yet ( and none expected for AR)  Litigation will resume before year end;  Sept. 2, 2011 – Ozone NAAQS reconsideration ended  Uncertain date - Ozone NAAQS Implementation rules needed  Next steps-  Dec. 2012 - 120 day EPA notice of intent to designate  Summer 2012 – EPA non-attainment designation using YE2010 Ozone Air Quality DataRecommendation: AIPRO review and comment on designation process 8to assure attainment outcome
  9. 9. Counties With Monitors Currently Violating the Revised Primary 1-Hour Sulfur Dioxide (SO2) Standard of 75ppb Not shown on map: Hawaii Co., HI St. Croix, Virgin Islands 22 States (59 counties) with 1-9 59 of 249 monitored counties (data in AQS) violate the standard counties per state -- Based on 2007-2009 data monitoring -- Designations will probably be based on 2009-2011 data non-attainment Arkansas monitors attainment in Union (26 ppb) and Pulaski (15ppb) 9
  10. 10. SO2 NAAQS Status  June 2011- State designations (AR attainment/unclassifiable statewide)  Sept. 2011-EPA implementation guidance (FR with comment for states and stakeholders)  Rulemaking will follow detailing new implementation approach.  EPA’s new approach will require 100+ TPY (and perhaps smaller) sources to model attainment  Arkansas has ~24 SO2 sources above 100 TPY SO2  Feb. 2012 – EPA intent to designate issues with public comment  June 2012 - EPA designation (petition for review possible)  June 2013 – Attainment / unclassifiable SIP due (attainment modeling)  February 2014 – Non-attainment SIPs due (attainment modeling)  June 2017 – Attainment deadlineRecommendation: AIPRO review and comment on Implementation rulemaking10
  11. 11. Counties Violating Existing PM2.5 15 ug/m3 Annual Standard And Hypothetical Lower Standards of 13, 12, and 11 ug/m3 Data Source: EPA Policy Assessment Ranges 6 counties violate 15 ug/m3 53 additional counties violate 13 ug/m3 (total of 59) • 11-13 µg / m3 79 additional counties violate 12 ug/m3 (total of 138) -- Including Fairbanks North Star, Alaska (not shown) 109 additional counties violate 11 ug/m3 (total of 247)No Arkansas non-attainment areas; monitor upcoming PM2.5 NAAQS revision11
  12. 12. Counties Violating Existing PM2.5 35 ug/m3 24-Hour Standard And Hypothetical Lower Standard of 30 ug/m3 Data Source: EPA Policy Assessment 35 counties violate 35 ug/m3 Ranges -- Including Fairbanks North Star, Alaska (not shown) 79 additional counties violate 30 ug/m3 (total of 114) • 30-35 µg / m3 -- Including Juneau, Alaska (not shown) 12No Arkansas non-attainment areas; monitor upcoming PM2.5 NAAQS revision
  13. 13. 2011 Cross State Air Pollution Rule (CSAPR)  Issued in August; limits EGU emissions to help downwind states attain the 1997 Ozone and 2006 PM 2.5 NAAQS  Ozone season NOx limits begin May 2012  Ozone annual NOx limits begin January 2012  SO2 annual limits begin January 2012  Many areas of the eastern U.S. are attaining the NAAQS that the CSAPR targets  Indirect potential impacts: electricity curtailment and price increases beginning in 2012 in some statesMonitor AR utility responses closely 13
  14. 14. ConclusionSignificant NAAQS & Oil and Gas sector rule changes underway New EPA rules and permitting interests best addressed by expanding oil and gas sector associations (state and federal) Changes underway bear review and comment where appropriate Air Quality has improved significantly recently Air Quality improvement trends will continue into the near future 14