Air Permitting Issues Surrounding Natural Gas Compressor Stations. West Virginia Division of Air Quality

Similar documents
Class II General Permit G35-C Registration to (Construct, Modify, etc.)

Oil and Gas Air Quality Regulations and Permitting

Garry Kaufman Colorado Air Pollution Control Division May 14, 2014

Air Quality Regulation of the Oil and Gas Production Sector in Colorado and Beyond. Garry Kaufman Holland & Hart LLP

Oil and Natural Gas Sector: Standards of Performance for Crude Oil and Natural Gas Production, Transmission, and Distribution.

Site Identification No.: AAO Application No.:

Highlights of Colorado s New Oil and Gas Hydrocarbon Emission Reduction Rules - Adopted February 2014

ENGINEERING EVALUATION/FACT SHEET

Addressing Air Emissions from Marcellus Shale Natural Gas Production. Joe Osborne Lauren Burge Group Against Smog & Pollution Pittsburgh, PA

Statement of Basis SCA Tissue North America, LLC

Tesoro Savage Vancouver Energy Distribution Terminal August 2013 Application No Page 2-162

Air Permitting in Colorado. Martha Hyder Wind River Environmental Group LLC September 2013

REGULATORY ANALYSIS. February 11, Colorado Department of Public Health and Environment

FAC 7.1: Generators. EPA Impacts on Emergency Gensets for 2015 Installations

NSPS Subpart OOOO: Applicability and Compliance Basics

West Virginia Department of Environmental Protection Division of Air Quality. Fact Sheet

EPA Requirements for Diesel Standby Engines In Data Centers. Bob Stelzer / CTO / Safety Power Inc. For 7x24 Fall 2014 Conference. 1.

Colorado s Recent Efforts to Address Hydrocarbons from Oil and Gas Operations

Developing Colorado s s Oil and Gas Emissions Controls Overview of the Process and Requirements

Emissions from Natural Gas Production in the Barnett Shale Area and Opportunities for Cost Effective Improvements

Approval Order: New Approval Order for a Produced Water Treatment Facility Project Number: N

Air Permit Application Volume II Warren County Combined-Cycle Project

Colorado Oil and Gas Emissions Rules

PENNSYLVANIA DEPARTMENT OF ENVIRONMENTAL PROTECTION

Control Device Requirements Charts For Oil and Gas Handling and Production Facilities

(Adopted July 7, 1989)(Amended December 7, 1990) (Amended May 13, 1994) FUGITIVE EMISSIONS OF VOLATILE ORGANIC COMPOUNDS

Emissions from Natural Gas Production in the Barnett Shale Area and Opportunities for Cost-Effective Improvements

Regulatory Impact Analysis

COLORADO REGULATION 7

(b) One (1) natural gas-fired boiler identified as B1, with a maximum heat input rate of 4.6 million (MM) British thermal units (Btu) per hour;

THE BASICS Q: What is VOC? Q: What are flashing losses/voc emissions from hydrocarbon storage tanks? - 1 -

MEMORANDUM March 7, Phillip Fielder, P.E., Permits and Engineering Group Manager

Addition of general construction conditions applicable to the portable emergency turbine because they were omitted from the original Part 70 Permit.

DRAFT AIR QUALITY MANAGEMENT IN GARFIELD COUNTY: COLORADO S MOST ACTIVE ENERGY DEVELOPMENT REGION

Addition of general construction conditions applicable to the portable emergency turbine because they were omitted from the original Part 70 Permit.

State of New Jersey. General Permit. For. Boilers and Heaters [Individually Less Than 10 MMBTU/HR]

Characterization of Greenhouse Gas Emissions Involved in Oil and Gas Exploration and Production Operations

Potential to Emit A Guide for Small Businesses

ENVIRONMENTAL STANDARDS FOR PETROLEUM OIL REFINERIES EMISSIONS. Standards for emissions from furnaces, boilers and Power Plant

Fixing the Leaks: What Would it Cost to Clean Up Natural Gas Leaks?

Air Quality Issues in Natural Gas Systems

FINAL UPDATES TO REQUIREMENTS FOR STORAGE TANKS USED IN OIL AND NATURAL GAS PRODUCTION AND TRANSMISSION

Texas Commission on Environmental Quality Emissions Banking and Trading Programs. Office of Air Air Quality Division

DRAFT White Paper Asphalt (non-permitted) Strategy Evaluation Portland Air Toxics Solutions

Subpart I Delaware. 40 CFR Ch. I ( Edition) (10) Amendments to Section V (Surveillance)

Source: EIA Natural Gas Issues and Trends 1998

Wolverine Clean Energy Venture

COLORADO APCD IR Camera Survey Program Guidance/Protocol (rev. 11/8/11)

Implementation Question and Answer Document. for

Industries. March Prepared for Environmental Defense Fund 257 Park Avenue South New York, NY 10010

Pennsylvania Marcellus Shale Short- Term Ambient Air Sampling Project

COMMONWEALTH OF MASSACHUSETTS DEPARTMENT OF ENVIRONMENTAL PROTECTION 310 CMR 7.00 AIR POLLUTION CONTROL REGULATIONS

State of the Art (SOTA) Manual for Boilers and Process Heaters

Assessment of Air Emissions Martin Marietta Materials Facilities on Highway 34, Weld County, Colorado Project No.:

BP Texas City Refinery

Air Quality in San Diego 2013 Annual Report

Industry Description and Practices. Waste Characteristics

Gas Leak Detection and Visualization.

Moving Targets: How Ever Changing Air Quality Regulations are Driving Process Decisions

Notice of Construction Application for Landfill Gas to Pipeline Gas Treatment Facility

Natural Gas Dehydrator Optimization

Air Pollution s, 1950s. Air Pollution Laws 1950s

Point Source Emission Inventory For Non-Electric Companies in Georgia

Enclosed are the General Permits issued pursuant to our review of your applications (General Permit No. GPEG-101, GPEG-102 and GPEG-103).

THE DETECTION OF GREENHOUSE GASES

Certified Mail 6/23/2014. Nathan Wheldon Humphreys Compressor Station 1515 Arapahoe St Tower 1, Suite 1600 Denver, CO 80202

Population Density, Traffic Density and Nitrogen Oxides (NOx) Emission Air Pollution Density in Major Metropolitan Areas of the United States

NEW Connections. Appendix B Air Quality

Air Quality From a State Perspective

Environmental Management EU 304

Standardized Process for the Development of Military-Unique Emissions Factors

Birmingham City University / Students Union Aspects and Impacts Register. Waste. Impacts description

PART 70 PERMIT TO OPERATE

GO GREEN AND SAVE GREEN

The proposed Project would be constructed in portions of Montana, South Dakota, Nebraska, Kansas, Oklahoma, and Texas.

GO GREEN AND SAVE GREEN

Reproduction of Permit Terms and Conditions

STATE OF MISSOURI, DEPARTMENT OF NATURAL RESOURCES MISSOURI AIR CONSERVATION COMMISSION PERMIT TO CONSTRUCT

RAILROAD COMMISSION OF TEXAS APPENDIX C LIST OF E&P WASTES: EXEMPT AND NONEXEMPT

Emission Reduction Techniques for Oil and Gas Activities. U.S. Forest Service 2011

Clean Up Your Fleet. Introducing a practical approach to cleaner, more efficient fleet operation

TECHNICAL SUPPORT DOCUMENT FOR. AIR EMISSION GENERAL PERMIT: PART 70 LOW-EMITTING FACILITY GENERAL PERMIT April 30, 2015

SEATTLE STEAM COMPANY COMBINED HEAT AND POWER AT POST AVENUE IN DOWNTOWN SEATTLE, WASHINGTON

Expansion Pitfalls, Permitting and Compliance A Case Study

Holcim EMR List of EN Standards and VDI Guidelines usable for Discontinuous Measurements in Cement Plants

Assessing the Changes Required by the Industrial Boiler MACT Regulations

POTENTIAL TO EMIT SUMMARY FIBERIGHT, LLC HAMPDEN, MAINE

Leaking Profits. The U.S. Oil and Gas Industry Can Reduce Pollution, Conserve Resources, and Make Money by Preventing Methane Waste.

Description of Thermal Oxidizers

How To Make Calcium Carbide

Emission Facts. The amount of pollution that a vehicle emits and the rate at which

Leak Detection and Repair. A Best Practices Guide

Part 4: How to Avoid Being a Title V Major Source

1 March Al Dussinger Embrace Home Loans 25 Enterprise Center Middletown, RI Dear Mr. Dussinger,

Partnering with Nature for a Cleaner Tomorrow

Rule Overview Regulation No.3, 6 and 7

ADEM Form /10 m5

4. The role of fleets and fleet managers

Enclosed is a General Permit issued pursuant to our review of your application (General Permit No. GPEG-235).

of Upstream Oil and Gas Activities in the Rocky Mountain States

Transcription:

Air Permitting Issues Surrounding Natural Gas Compressor Stations West Virginia Division of Air Quality

Air Quality Permits are Required for the Following The source is subject to any substantive requirement Discharges > 144 lbs per/day, 6 lbs per/hr, 10 tons per/yr, of any regulated air pollutant Discharges more than 2 pounds per hour or 5 tons per year of hazardous air pollutants Discharges any toxic air pollutant(s) in an amount greater than Table 45-13A

The Permitting Process Applicant submits the necessary application forms to the Division of Air Quality (DAQ). Application is reviewed for completeness and applicant is notified of any deficiencies. Application undergoes a technical review to determine which air quality rules apply.

The Permitting Process (cont d.) If the application meets all applicable air quality rules, the DAQ publishes a notice of intent to approve the draft permit which provides for a 30 day public comment period. A copy of the engineering evaluation and draft permit is available for public review. Any received comments are reviewed and addressed by the DAQ. Final permit decision is made.

What is a natural gas production site? Located at an existing OOG permitted well pad Gathers gas from all of the well heads on the site and prepares the gas for use by removing unwanted liquids and other impurities. Equipment generally found at these sites include Compressors Gas production units Heater-treaters Low-pressure towers Vapor combustors Condensate & storage tanks

Equipment

What is a natural gas compressor station? The compressor station is the engine that powers a natural gas pipeline. The compressor station compresses the natural gas (pumping up its pressure) thereby providing energy to move the gas through the pipeline. Natural gas companies install compressor stations along a pipeline route. The size of the station and the number of compressors varies, based on the diameter of the pipe and the volume of gas to be moved.

Construction Stormwater Permitting

Types of Pollutants Combustion Sources Nitrogen Oxides, Carbon Monoxide, Volatile Organic Compounds, Sulfur Dioxide, Particulate Matter. Sources of combustion include engines, emergency generators, reboilers and hot oil heaters.

Types of Pollutants (cont d.) Natural Gas Dehydration Volatile Organic Compounds, Benzene, Toluene, Ethylbenzene, Xylene, trace amounts of other constituents. In the dehydration process, gas passes through a contactor vessel where water is absorbed.

Types of Pollutants (cont d.) Tanks Volatile Organic Compounds. Condensate dropout from produced water and other pipeline fluids are stored in storage tanks and transported off-site.

What Rules Apply? EPA s operating and construction permit rules West Virginia s pre-construction permit rules National Emissions Standard for Hazardous Air Pollutants (NESHAPs) New Source Performance Standards (NSPS) Greenhouse Gas Reporting

What Rules May Apply? Rule Sources Pollutants Requirement 45CSR13 45CSR2 Criteria pollutants emitted above 6 pph and 10 tpy. HAPs emitted above 2 pph or 5 tpy. Hot Oil Heater, Reboiler Criteria Pollutants (Nitrogen Oxides (NO x ), Carbon Monoxide (CO), Volatile Organic Compounds (VOC), Sulfur Dioxide (SO 2 ), Particulate Matter (PM)), Hazardous Air Pollutants (HAPs) PM 45CSR6 Flare PM Required to obtain air quality permit. Visible emission readings, particulate matter emission limits. Particulate matter emission limits. Temporary flares meeting specific requirements are exempt from this rule. 40CFR60.18 Flare VOC 98% destruction efficiency of VOC emissions. 40CFR60 Subparts K, Ka, Kb Storage Tanks VOC Prescribed control devices on storage tanks to reduce VOC emissions. 40CFR60 Must meet the emission control limits for NO x and SO 2. Must conduct performance testing. Gas Turbines NO Subpart GG x, SO 2 40CFR60 Subpart KKK 40CFR60 Subpart LLL Natural Gas Processing Plants Natural Gas Sweetening Plants VOC SO 2 Must conduct Leak Detection and Repair (LDAR) on all processing equipment to reduce VOC emissions. Must conduct appropriate testing and monitoring to show compliance of SO 2 limit for the gas sweetening facility.

What Rules May Apply? (cont d.) 40CFR60 Subpart IIII 40CFR60 Subpart JJJJ 40CFR60 Subpart KKKK 40CFR60 Subpart OOOO 40CFR63 Subpart H 40CFR63 Subpart HH 40CFR63 Subpart VV 40CFR63 Subpart HHH Diesel Fired Engines Natural Gas Fired Engines VOC, NO x, CO, PM VOC, NO x, CO Gas Turbines NO x, SO 2 Gas Wells, Compressors, Pneumatic Controllers, Storage Vessels, Sweetening Units Equipment Leaks Tanks, Equipment Leaks, Glycol Dehydration Units at Production Facilities Oil-Water Separators Glycol Dehydration Unit VOC, SO 2 HAPs HAPs HAPs HAPs Emission limits that may require the use of air pollution control devices. Must conduct performance testing. Emission limits that may require the use of air pollution control devices. Must conduct performance testing. Must meet the emission control limits for NO x and SO 2. Must conduct performance testing. Must meet the emission control limits for VOC and SO 2. Must conduct appropriate testing, monitoring and recordkeeping. Varies depending upon source category. Must control HAP emissions from tanks, equipment leaks, and glycol dehydration units. Must conduct appropriate testing, monitoring and recordkeeping. Varies depending upon source category. Must conduct appropriate testing, monitoring and recordkeeping. Must control HAP emissions from glycol dehydration units. Must conduct appropriate testing, monitoring and recordkeeping.

What Rules May Apply? (cont d.) 40CFR63 Subpart YYYY 40CFR63 Subpart ZZZZ Gas Turbines Reciprocating Internal Combustion Engines HAPs HAPs Must control HAP emissions from stationary gas turbines. Must conduct appropriate testing, monitoring and recordkeeping. Emission limits that may require the use of air pollution control devices. Must conduct appropriate testing, monitoring and recordkeeping.

Questions about DEP Considering Cumulative Impacts Q: Why doesn t DEP consider the combined effects from multiple facilities/activities located in the same geographical area emitting: < 144 lbs per/day, 6 lbs per/hr, 10 tons per/yr? A: DEP does consider it, to some degree. 1) Statewide Ambient Monitoring Network Six principal pollutants: 1. ground-level ozone 2. particulate matter 3. sulfur dioxide 4. carbon monoxide 5. nitrogen dioxide 6. lead. 2) DEP must have Legislative Authority 3) WVDEP reports to USEPA

Working with EPA Q: What happens if WV fails to meet AQ standards? A: EPA designates the region as a nonattainment area DEP is then required to develop a state implementation plan to achieve and maintain air quality standards in that area. State implementation plans must be approved by EPA. In addition: EPA must conduct periodic reviews to determine whether AQ standards should be revised. EPA is in the process now and expects to see more green completions, giving us a 95% reduction in VOC emissions Estimated revenues from selling the gas that currently goes to waste are expected to offset the costs of compliance, EPA s analysis of the rules show cost savings of $11 to $19 million when the rules are fully implemented in 2015.

A Work in Progress Report from EPA s Office of Inspector General February 20, 2013 EPA Needs to Improve Air Emissions Data for the Oil and Natural Gas Production Sector www.epa.gov

Thank You Questions.Comments...Complaints? John M.S. King Environmental Resources Analyst Office of Environmental Advocate 2311 Ohio Ave Suite E. Parkersburg, WV 26101 Cell: 304-382-8666 Toll Free: 1-800-654-5227 John.M.S.King@wv.gov