Oil and Gas Air Quality Regulations and Permitting

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1 Oil and Gas Air Quality Regulations and Permitting Adam Berig Olsson Associates Colorado Springs Oil and Gas Committee Presentation February 2012

2 Who Regulates Air Quality? United States Environmental Protection Agency (EPA) Clean Air Act Colorado Department of Public Health and Environment - Air Pollution Control Division (CDPHE-APCD) State Air Quality Regulations

3 Air Pollutant Any fume, smoke, particulate matter, vapor, gas, or any combination thereof that is emitted into or otherwise enters the atmosphere Colorado Common Provisions Regulation. Regulated air pollutant, requires a finding that the pollutant endangers the public health or welfare (e.g., visibility), and/or the environment

4 Criteria Air Pollutants Those pollutants for which the U.S. EPA has established national ambient air quality standards (NAAQS) or precursors to those pollutants Includes: Carbon monoxide (CO) Nitrogen oxides (NO x, as a direct emission and a precursor to ozone) Certain sulfur compounds Particulate Matter (PM 10, PM 2.5, total suspended particulate matter) Ozone (O 3, controlled by regulating the precursors) Volatile Organic Compounds (VOC, as a precursor to ozone) Lead

5 Non-criteria Air Pollutants Reportable or regulated pollutants that are not criteria pollutants (there is no EPA ambient standard or NAAQS) Includes Hazardous Air Pollutants (HAPs) pollutants that present a threat of adverse human health effects or adverse environmental effects and that has been listed pursuant to Section 112 of the Federal Act, or Section of the state Act. Relevant examples are: Benzene (and related compounds toluene, ethylbenzene, and xylenes BTEX) Formaldehyde Methanol A few non-criteria pollutants are not HAPs, such as Nicotine Ammonia All Colorado Non-criteria pollutants are listed in Appendix B, Part A, Regulation No. 3 of the AQCC

6 Greenhouse Gases (GHG) Includes Carbon Dioxide (CO 2 ), Methane (CH 4 ), Nitrous oxide (N 2 O), and a few others irrelevant to Natural Gas Operators Mandatory reporting of 2011 emissions for Natural Gas Operators this year Tailoring Rule will begin requiring largest emitters to use best practices to minimize emissions through Title V and PSD permits

7 CDPHE-APCD Air Quality Regulations Regulation Number 3 - Stationary Source Permitting and Air Pollutant Emission Notice Requirements Regulation Number 7 - Control of Ozone Via Ozone Precursors (Emissions of Volatile Organic Compounds and Nitrogen Oxides

8 Permitting Process Emissions are assessed Regulatory analysis is completed Applicable requirements identified Application completed and submitted to the CDPHE-APCD Permit is Issued to Company Company operates equipment according to permit requirements

9 Oil and Gas Operations Exploration and Production E&P Well site Tanks, small engines, heaters, flares Compressor Stations Gas Processing Plants Refineries

10 Permit Types Air Pollution Emission Notices (APENs) Required of every source with actual annual emissions above de-minimus thresholds, 2 TPY for most criteria pollutants Minor source permits Construction Permits True minor Synthetic minor Major Source Permits (Title V) PSD Permit

11 O&G Permit Application Permit applicants must submit: A Construction Permit Application Completeness Checklist; All APEN filing fees with the permit application; Equipment specific Air Pollutant Emissions Notices (APEN); A Company Contact Information Form; A Facility Wide Emissions Inventory form; Supporting documentation of emissions calculations; An ambient air impact analysis; An Operating & Maintenance Plan; A process flow diagram, process description, and plot plan; A Regulatory Analysis.

12 O&G Permitting Process The Oil and Gas permit process materials can found here

13 Questions?

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