Discuss the air permitting (or registering process) in Montana, compared to other states in 2010.

1. Oil & Gas Well
Facility Air Quality
Permitting/Registrations
By: Bret Gallo, Bison Engineering, Inc.

2. Outline
 Introduction
 Potential to Emit
 Registration Process
 Registration Requirements
 Deregistration Process
 Permitting on Tribal Lands
 Permitting/Registering O&G Wells in North Dakota and Wyoming
 Conclusion

3. Introduction
 Definition of an Oil or Gas Well Facility
 What is a Registration?
 History of rules for MT Registrations
 Who needs a MAQP/Registration?

4. Oil or Gas Well Facility Defined
Means a well that produces oil or natural gas.
The term includes:
– Equipment associated with the well and used for the purpose of
producing, treating, separating, or storing
oil, natural gas, or other liquids produced by the well;
and
– A group of wells under common ownership or control
that produce oil or natural gas and that share
common equipment used for the purpose of
producing, treating, separating, or storing oil, natural
gas, or other liquids produced by the wells.

5. What is a Registration?
 Option for O&G well facilities to use rather than obtaining a
Montana Air Quality Permit
– Follow requirements in Rule ARM Title 17, Chapter 8, Subchapter 17
(Registration of Air Contaminant Sources)*
– No public notice
– No BACT analysis
– No need for modification fees, just a 15 day notification
 The process of identifying equipment, processes, and emissions
(PTE and controlled) for the DEQ according to the provisions of
ARM Title 17, Chapter 8, Subchapter 17.
*Note: Registration does not allow facilities to opt out of the Title V Operating
Program if controlled emissions are ≥ 100 tpy or a facility emits ≥ 10 tpy single
HAP or ≥ 25 tpy all HAPs.

6. History of Rules
 Spring of 2004: DEQ became aware many O&G
well facilities exceeded the PTE threshold
requiring a Montana Air Quality Permit (MAQP).
 Requested operators to analyze their facilities.
 January 2006: DEQ was overrun with hundreds
MAQP applications for existing and proposed
O&G well facilities.
 April 2006: Administrative Rules of Montana
(ARM) Title 17, Chapter 8, Subchapter 17,
Registration of Air Contaminant Sources was
finalized.

7. Who needs an MAQP/Registration
 Any O&G well facility constructed after
11/23/1968
– If PTE ≥ 25 tpy any criteria pollutant
 Constructed prior to 11/23/1968 if a
modification increases PTE ≥ 25
– More onsite equipment, recompletions, etc.

8. Determining PTE
What are the emitting units?
 Internal Combustion
Engines (ICEs)
– Lifting unit engine
– Recycling pump engine
– Others???
 Natural Gas Burners
– Heater Treater (Separator)
Heater
 Produced Oil and Water
Storage Tanks
 Emergency flaring/venting
 Flares/Smokeless
Combustors
 Vented Gas
 Truck Loading Losses
 Fugitive Equipment Leaks
– Valves, flanges, pnumatics
 Fugitive Dust Emissions
(Vehicles)

9. Typical O&G Well Facility

10. Typical Emitting Units

11. Emission Calculation Methods for PTE
 Based on max daily operational capacity
– (oil, gas, and water production: previous 6 month max)
 Internal Combustion Engines
– 8,760 hrs and manufacturer’s guaranteed max design capacity (hp)
– AP-42 factors or mfg guaranteed factors
 Nat. Gas Burners
– 8,760 hrs, max size of burner (Btu/hr) and AP-42 factors
 Produced Oil Storage Tanks
– Flashing, working, and breathing losses (accounts for +90% of total facility
emissions)
– E&P Tanks Version 2 Model (Recommended by both federal and state agencies)
 Inputs can be high pressure oil samples, low pressure oil samples, or gas samples
– Use a BTEX low pressure extended hydrocarbon analyses from produced oil
 If not available, may use DEQ provided “representative” analysis from another well.

12. Emission Calculation Methods Cont…..
 Produced Water Storage Tanks
– Tanks 4.09d (assume it is all oil)
– AP-42 Chapter 7: Liquid Storage Tanks
 (need physical and chemical properties)
– EPA-450/3-85-001a – Volatile Organic Compound Emissions from Petroleum
Refinery Wastewater Systems - Background Information for Proposed Standards
 (1.95E-5 ton VOC/bbl water produced…greatly over predicts)
– EPA WATER9 Program
 (need physical and chemical properties)
 Produced Gas
– If sent to pipeline, must assume a minimum of 500 hrs/yr emergency flaring or
venting
– If all is flared, must assume a minimum of 500 hrs/yr emergency venting
 Truck Loading Losses
– Production rate and AP-42 Chapter 5.2 – Transportation and Marketing of Petroleum
Liquids
 Fugitive Emissions
– AP-42 factors

13. Requirement for Registering
 Must register within 60 days of well completion date
 Required controls must be installed at time of registration
– Any emitting unit with a PTE ≥ 15 tpy must be controlled
 Captured and sent to pipleline or combusted in flare/smokeless
combustor
– Federal and State required controls
 Catalytic oxidizers, AFR controllers, etc.
 Submit Complete Registration Form
– Emissions inventory, E&P Tanks Summary, Oil and Gas
samples, plot plan, and map
– Currently $500 fee
 Ambient air quality analysis (if H2S is detected)
– Demonstrate compliance with H2S and SO2 standards
 SCREEN3 can be used, lower standards….maybe AERMOD??

14. General Requirements
Emissions Control:
 Pipeline or flare
control (≥95%) if over
15 tpy emitted
 Loading/unloading
using submerged fill
 Rich Burn Engines
> 85 hp: NSCR
 Lean Burn Engines
> 85 hp: O-Catalyst
Inspection & Repair
 Inspect monthly
 Repair within 5 days
 Shut down after 15 days
and repair
Recordkeeping/Reporting
 Monthly inspection
reports
 Keep for 5 years

15. Deregistration Process
Typically due to decline in facility production
 Must submit full emissions evaluation
– Same methods of calculation at original
registration
– Must use a BTEX low pressure oil extended
hydrocarbon analysis from the deregistered
facility, not a “representative” analysis
 Must be no older than 3 years
– No fee to deregister a facility