Discuss the types of emissions associated with the production of oil and gas. Discuss regulating agencies as of 2010, such as WY, ND, MT, EPA.

1. Regulating Oil and GasRegulating Oil and Gas
Air Production EmissionsAir Production Emissions
By: Bret Gallo, Project Environmental Engineer
Bison Engineering, Inc.
Energy Development Conference
Fort Belknap Indian Community
August 18, 2010

2. OutlineOutline
 IntroductionIntroduction
 Typical facility equipmentTypical facility equipment
 Potential to EmitPotential to Emit
 Permitting/Registering O&G Wells in the RockiesPermitting/Registering O&G Wells in the Rockies
 Calculating Flashing EmissionsCalculating Flashing Emissions
 ConclusionConclusion

3. IntroductionIntroduction
Emissions from oil & gas production facilities inEmissions from oil & gas production facilities in
the Rockies are now being focused on bythe Rockies are now being focused on by
regulating agencies due to increased productionregulating agencies due to increased production
and environmental concerns.and environmental concerns.
 What are theWhat are the RockyRocky’’ss states/EPA doing?states/EPA doing?
 What are the current issues?What are the current issues?
 What does the future hold?What does the future hold?

4. Typical O&G Well FacilityTypical O&G Well Facility

5. Determining Potential to Emit (PTE)Determining Potential to Emit (PTE)
What are the emitting units??What are the emitting units??
 Internal Combustion EnginesInternal Combustion Engines
((ICEsICEs))
–– Lifting unit engineLifting unit engine
–– Recycling pump engineRecycling pump engine
–– Others???Others???
 Natural Gas BurnersNatural Gas Burners
–– HeaterHeater TreaterTreater (Separator)(Separator)
HeaterHeater
 Produced Oil and WaterProduced Oil and Water
Storage TanksStorage Tanks
 Flares/SmokelessFlares/Smokeless
CombustorsCombustors
 Vented GasVented Gas
 Truck Loading LossesTruck Loading Losses
 Fugitive Equipment LeaksFugitive Equipment Leaks
–– Valves, flanges, pneumaticsValves, flanges, pneumatics
 Fugitive Dust EmissionsFugitive Dust Emissions
(Vehicles)(Vehicles)

6. Typical Emitting UnitsTypical Emitting Units

7. Emission Calculation Methods for PTEEmission Calculation Methods for PTE
 Based on max daily operational capacityBased on max daily operational capacity (production)(production)
 Internal Combustion EnginesInternal Combustion Engines & Nat. Gas Burners& Nat. Gas Burners
–– Yearly hrs, max. design capacity, and APYearly hrs, max. design capacity, and AP--42 factors42 factors
 Produced Oil Storage TanksProduced Oil Storage Tanks
–– FlashingFlashing, working, and breathing losses, working, and breathing losses
–– E&PE&P TANKsTANKs Version 2 ModelVersion 2 Model (most widely accepted and used)(most widely accepted and used)
 Low pressure extended hydrocarbon oil analyses (C10+ w/ BTEX)Low pressure extended hydrocarbon oil analyses (C10+ w/ BTEX)

8. Emission Calculation Methods ContEmission Calculation Methods Cont……....
 Produced Water Storage TanksProduced Water Storage Tanks
–– Tanks 4.09d (assume it is all oil)Tanks 4.09d (assume it is all oil)
–– APAP--42 Factors42 Factors
–– EPAEPA--450/3450/3--8585--001a001a –– VOC Emissions from Petroleum RefineryVOC Emissions from Petroleum Refinery
Wastewater SystemsWastewater Systems
–– EPA WATER9 ProgramEPA WATER9 Program
 Produced GasProduced Gas
–– Assume a minimum of 500 hrs/yr emergency flaring or ventingAssume a minimum of 500 hrs/yr emergency flaring or venting
 Truck Loading LossesTruck Loading Losses
–– Production rate and APProduction rate and AP--42 Factors42 Factors
 Fugitive EmissionsFugitive Emissions
–– APAP--42 factors42 factors

9. Rocky Mountain States Air ProgramsRocky Mountain States Air Programs
Minor Source & PreMinor Source & Pre--construction Permitsconstruction Permits
 COLORADOCOLORADO
–– Equipment specific permitsEquipment specific permits (equipment specific)(equipment specific)
–– Area specific regulationsArea specific regulations (except on Tribal Lands)(except on Tribal Lands)
 WYOMINGWYOMING
–– Applicable: Constructed/modified after May 29, 1974Applicable: Constructed/modified after May 29, 1974
–– Area specific regulations, e.g., JonahArea specific regulations, e.g., Jonah--Pinedale AreaPinedale Area
(except on Tribal Lands)(except on Tribal Lands)
*Note:*Note:
Permits/RegistrationsPermits/Registrations DO NOTDO NOT allow facilities toallow facilities to
opt out of the Title V Operating or PSD Programsopt out of the Title V Operating or PSD Programs

10. RM States Air Programs ContinuedRM States Air Programs Continued
 MONTANAMONTANA
–– O&G Well Registration (equivalent to MT Minor SourceO&G Well Registration (equivalent to MT Minor Source
Permit)Permit)
–– Applicable: Constructed/modified after March 16, 1979Applicable: Constructed/modified after March 16, 1979
–– StateState--wide regulationswide regulations (except on Tribal Lands)(except on Tribal Lands)
 NORTH DAKOTANORTH DAKOTA
–– O&G Well RegistrationO&G Well Registration
–– Applicable: Constructed/modified after July 1, 1987Applicable: Constructed/modified after July 1, 1987
–– Ongoing development of air quality regulations, controls,Ongoing development of air quality regulations, controls,
emissions estimates and limitsemissions estimates and limits
–– StateState--wide regulationswide regulations (including on Tribal Lands)(including on Tribal Lands)
*Note:*Note:
Permits/RegistrationsPermits/Registrations DO NOTDO NOT allow facilities toallow facilities to
opt out of the Title V Operating or PSD Programsopt out of the Title V Operating or PSD Programs

11. Emissions from O&G Wells on Tribal LandsEmissions from O&G Wells on Tribal Lands
EPA Region 8 has jurisdictionEPA Region 8 has jurisdiction
Applicable Air Permitting ProgramsApplicable Air Permitting Programs
–– Major Source PSD Program (Major Source PSD Program (≥≥250250 tpytpy))
–– Major Source Title V Operating Program (Major Source Title V Operating Program (≥≥100100 tpytpy))
 ((HAPsHAPs thresholds)thresholds)
No Minor Source/PreNo Minor Source/Pre--Construction Permitting ProgramConstruction Permitting Program
–– (No method of having acquiring a(No method of having acquiring a ““synthetic minorsynthetic minor”” status)status)
–– POSSIBLY implemented early 2011POSSIBLY implemented early 2011
Under 100Under 100 tpytpy PTE, you are not required to have any permit;PTE, you are not required to have any permit;
HOWEVER, must still be in compliance with specificHOWEVER, must still be in compliance with specific
federal requirements!federal requirements!

12. Emissions from O&G Wells on Tribal LandsEmissions from O&G Wells on Tribal Lands
Use ofUse of ““Transition PolicyTransition Policy”” Memo (March 7, 1999)Memo (March 7, 1999)
for O&G Production Facilitiesfor O&G Production Facilities
–– IFIF facility would be subject to Title V Operating Programfacility would be subject to Title V Operating Program
–– Federally enforceable credit for controls that reduce emissionsFederally enforceable credit for controls that reduce emissions
below 50below 50 tpytpy (50% of major source Title V threshold)(50% of major source Title V threshold)
–– Notify EPA with 1 year after production startsNotify EPA with 1 year after production starts
 Title V Operating Permit application is required after 1 year ofTitle V Operating Permit application is required after 1 year of
operationoperation
–– Calculate emissions on annual basisCalculate emissions on annual basis
 Same emission calculation methodologies as previously describedSame emission calculation methodologies as previously described
–– KEEP ANNUAL EMISSIONS RECORDS ONSITE!!!KEEP ANNUAL EMISSIONS RECORDS ONSITE!!!

13. Estimating Flashing EmissionsEstimating Flashing Emissions
Lack of accurately estimating flashing emissions!Lack of accurately estimating flashing emissions!
 +95%+95% of O&G facilityof O&G facility’’s emissionss emissions
 Lack of direct measurement dataLack of direct measurement data
 Lack of standardized method of flashing emissionsLack of standardized method of flashing emissions
calculation/modelingcalculation/modeling
 Lack of standardized oil sample collection & analysisLack of standardized oil sample collection & analysis
–– E&PE&P TANKsTANKs most widely used; however, conservativemost widely used; however, conservative
(over(over--predicts)predicts)
Agency and industry collaboration neededAgency and industry collaboration needed
for more accurate results!!for more accurate results!!

14. ConclusionConclusion
 Better understanding of accurate emissions is aBetter understanding of accurate emissions is a
must!must!
 Emissions estimation methods AND applicable airEmissions estimation methods AND applicable air
quality regulations must be as standardized asquality regulations must be as standardized as
possible across state and tribal borders.possible across state and tribal borders.
 Regulations are continually changing at a fast pace!Regulations are continually changing at a fast pace!
–– Proposed lowered NAAQSProposed lowered NAAQS
–– Increased number of facilitiesIncreased number of facilities
–– GHG ReportingGHG Reporting
–– Many new and innovative control devicesMany new and innovative control devices

15. Questions??Questions??
Bret Gallo, Project EngineerBret Gallo, Project Engineer
Bison Engineering, Inc.Bison Engineering, Inc.
1400 111400 11thth AvenueAvenue
Helena, MT 59601Helena, MT 59601
(406) 442(406) 442--57685768
bret@bisonbret@bison--eng.comeng.com