NDDH O&G Air Permitting Guidance

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North Dakota Department of Health (NDDH) May 2011 final oil and gas permitting and compliance guidance including emission inventory spreadsheets that all operators must use:

• Memo
• Guidance document
• Emissions calculation spreadsheet

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Bakken Breakout 2011

Stories about Bakken Field oil production. (Blog title is the link.) Bison ad on page 25.

Oil and Gas Enviornmental Implications -- R8 EPA 2008 Report

EPA's view of air, water, and solid waste impacts from the industry and discussions of federal, state, and regional efforts to reduce impacts. Billed as a working draft.

An Assessment of the Environmental Implications of Oil and Gas Production: A Regional Case Study

Wyoming 3-Year Emissions Inventory

Wyoming DEQ website for emission inventory information:
http://deq.state.wy.us/aqd/ei.asp

Here's the introduction with my assumed updates inserted:

In accordance with 40 CFR part 51, Subpart A, states are required to report total state-wide emissions to the United States Environmental Protection Agency (EPA) every three years. Calendar year 2008 [2011] marks the third [fourth] year for the reporting period for which emission inventories are required to be collected by each state and submitted to EPA for the National Emissions Inventory. As such, the Wyoming Department of Environmental Quality (DEQ), Air Quality Division (AQD) is requiring each minor source located in the state of Wyoming to complete an air emissions inventory for calendar year 2008 [2011]. The completed 2008 [2011] Annual Minor Source inventory should be returned to the AQD no later than September 15, 2009 [presumably 2012]. This emission inventory information is required to be submitted to the Division, pursuant to W.S. 35-11-110(a)(vii).

WDEQ recently conducted a series of workshops around the state to share information about completing inventories for O&G sources. I e-mailed Scott Faber asking for presentation materials from these sessions. Here's his reply:

Kevin,

At the workshops, we had an introductory powerpoint presentation that gave some general background information on emission inventories, and then we went through the minor source inventory forms (spreadsheets). We will be posting the powerpoint presentation on our website in the coming weeks, and the tri-annual minor source inventory forms for 2008 are still posted on our website at http://deq.state.wy.us/aqd/ei.asp. You can look over those forms to see what kind of emissions information we will be requesting for 2011, and we will post the forms for 2011 later next year when we have made some updates to them. The main change being that we will be asking for PM2.5 emissions along with PM10.

GHG Reporting, Subpart W, Petroleum and Natural Gas Systems

Final rule published 11/8/10; published in Federal Register 11/30.
Final Rule

Here's an overview article published March 2011 in the Air Pollution Consultant on-line magazine (available through Cyber Regs). (Added 6/14/11, KMM)


All the Part 98 subparts are collected here:
GHG Reporting Rule Web Site

Here's the text relating monitoring and QA/QC requirements (§98.234):

The GHG emissions data for petroleum and natural gas emissions sources must be quality assured as applicable as specified in this section. Offshore petroleum and natural gas production facilities shall adhere to the monitoring and QA/QC requirements as set forth in 30 CFR 250.

(a) You must use any of the methods described as follows in this paragraph to conduct leak detection(s) of equipment leaks and through-valve leakage from all source types listed in §98.233(k), (o), (p) and (q) that occur during a calendar year, except as provided in paragraph (a)(4) of this section [which requires optical imaging for inaccessible areas as defined].

(1) Optical gas imaging instrument. Use an optical gas imaging instrument for equipment leak detection in accordance with 40 CFR part 60, subpart A, §60.18(i)(1) and (2) of the Alternative work practice for monitoring equipment leaks [This is italicised in the original. It would seem to refer to some document, but word searching this rule yielded no other occurrence.]. Any emissions detected by the optical gas imaging instrument is a leak unless screened with Method 21 (40 CFR part 60, appendix A-7) monitoring, in which case 10,000 ppm or greater is designated a leak. In addition, you must operate the optical gas imaging instrument to image the source types required by this subpart in accordance with the instrument manufacturer’s operating parameters.

(2) Method 21. Use the equipment leak detection methods in 40 CFR part 60, appendix A-7, Method 21. If using Method 21 monitoring, if an instrument reading of 10,000 ppm or greater is measured, a leak is detected. Inaccessible emissions sources, as defined in 40 CFR part 60, are not exempt from this subpart. Owners or operators must use alternative leak detection devices as described in paragraph(a)(1) of this section to monitor inaccessible equipment leaks or vented emissions.

(3) Infrared laser beam illuminated instrument. Use an infrared laser beam illuminated instrument for equipment leak detection. Any emissions detected by the infrared laser beam illuminated instrument is a leak unless screened with Method 21 monitoring, in which case 10,000 ppm or greater is designated a leak. In addition, you must operate the infrared laser beam illuminated instrument to detect the source types required by this subpart in accordance with the instrument manufacturer’s operating parameters.

(4) Optical gas imaging instrument. An optical gas imaging instrument must be used for all source types that are inaccessible and cannot be monitored without elevating the monitoring personnel more than 2 meters above a support surface.

(5) Acoustic leak detection device. Use the acoustic leak detection device to detect through-valve leakage. When using the acoustic leak detection device to quantify the through-valve leakage, you must use the instrument manufacturer’s calculation methods to quantify the through-valve leak. When using the acoustic leak detection device, if a leak of 3.1 scf per hour or greater is calculated, a leak is detected. In addition, you must operate the acoustic leak detection device to monitor the source valves required by this subpart in accordance with the instrument manufacturer’s operating parameters.

Comments:

• Is acoustic leak detection (5) limited to only a subset of required monitoring? Appears that way.
• It looks like (4) is an extension of (1) and indicates that, in some cases, using a camera is the only option.

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"Running With Oil" Stories About North Dakota's Oil Boom

""Running with Oil,” a series of reports on North Dakota’s booming oil industry, appeared Aug. 15 through Aug. 22 2010 in the North Dakota newspapers of Forum Communications Co.: The Dickinson Press, The Forum of Fargo-Moorhead, the Grand Forks Herald and the Jamestown Sun. Each day of the series is archived on this site. Choose the day you'd like to view from the navigation bar above." (Click on title to go to home page.)

North Dakota O&G Map

Zoom in to location of any well or gas plant within the state.

Oil & Gas Regulation Developments

“A recently created task force in EPA Region III is exploring options to use existing tools such as targeted enforcement and permit objections to impose stricter environmental protection standards on fossil fuel extraction in the key energy states of Pennsylvania, Virginia and West Virginia -- which include growing natural gas drilling operations and a heavy coal mining presence.”

EPA Resource Extraction Task Force article


An article from InsideEPA.com focusing on Texas vs. EPA differences in aggregating O&G facilities. It includes a link to TCEQ’s proposed rule (also linked below) which contains a wealth of information about O&G field operations and much detail regarding proposed regulations. There’s a lot there in 121 pages. One thing I noted that seemed a little strange is that any refined modeling would be done using ISC.

Proposed TCEQ OG Rules Article

TCEQ proposed OG rules

Oil Production Air Registration and Permitting - General

MDEQ and MPA training presentation, August 2009:

MDEQ O&G Permitting and Registration Training Presentation, 8/2009

Montana Oil and Gas Registration & Compliance Flow Chart

Bret prepared this for some of his clients, July 2010:

Flow Chart

Tank Flashing Emissions - New Mexico guidelines

Tank Flashing Emissions Guidelines, New Mexico