22
Early engagement Stakeholder meeting Colorado Regulation 7 Oil and Gas Sector 1 January 30, 2017
Early engagement
Stakeholder meeting
Colorado Regulation 7
Oil and Gas Sector
1
January 30, 2017
• Reasons for 2017 oil and gas rulemaking
• Overview of oil and gas requirements
• Regulation Number 7
• EPA’s Oil and Gas CTG
• EPA’s oil and gas NSPS (OOOO, OOOOa)
• BLM’s venting and flaring rule
• Discussion of potential oil and gas control measures and rule revisions
• 2017 stakeholder and rulemaking timing & next steps
O&G stakeholder meeting
1/30/2017 2
• Reasons for 2017 oil and gas rulemaking
• Moderate ozone nonattainment area requirement to address CTG
• 2008 ozone NAAQS
• Corresponding alignment, clarifications, other revisions
• 2015 ozone NAAQS
O&G stakeholder meeting
1/30/2017 3
• Expedited – 2018 deadline and requirement for Legislative Review
• Develop scope/solicit input
• Develop strawman
• Develop proposal
• Rulemaking process
• 7/20/17 Request
• 10/19/17 Hearing
• Legislative Review
O&G stakeholder meeting
1/30/2017 4
O&G stakeholder meeting
1/30/2017 5
2018
Jan Mar May Jul Sep Nov Jan Mar May
Reg 7 O&G Rulemaking Kickoff
1/30/2017
Reg 7 Request for Hearing 7/20/2017
Reg 7 Hearing 10/19/2017
Submit to EPA
6/29/2018
Solicit Input
Develop Strawman
Develop Proposal
Rulemaking Process
Legislative Review
2017
Due to EPA
2019
• Regulation Number 7
• EPA’s Control Techniques Guidelines for the Oil and Natural Gas Industry (“Oil and Gas CTG”)
• EPA’s New Source Performance Standard (“NSPS OOOO”, “NSPS OOOOa”)
• BLM’s Waste Prevention, Production Subject to Royalties, and Resource Conservation (“venting and flaring rule”)
O&G stakeholder meeting
1/30/2017 6
O&G stakeholder meeting
1/30/2017 7
Regulation 7 COGCC CTG NSPS OOOO NSPS OOOOa BLM
Well completions X (oil and gas) X (gas) X (oil and gas) X (oil and gas)
Well pits X
Compressors – centrifugal
and reciprocating X (XVII) X X X X (LDAR)
Pneumatic controllers
(continuous bleed) X (XVIII) X X X X X
Pneumatic pumps X X X
Fugitive emissions – well
sites and compressor
stations
X (XVII) X X X
Condensate tanks X (XII, XVII) X X X X X
Crude oil tanks X (XVII) X X X X X
Produced water tanks X (XVII) X X X X X
Equipment leaks at natural
gas plants X (XII) X X X
Liquids unloading X (XVII) X
O&G stakeholder meeting
1/30/2017 8
O&G stakeholder meeting
1/30/2017 9
Definition Pollutant Standard Monitoring
NSPS OOOOa
Single well – conducts well completion operation following hydraulic fracturing or refracturing
GHG/VOC
Initial flowback stage to vessels, separation flowback stage to separator/vessels & wildcat/delineation or non-wildcat/delineation low pressure well – combustion device, separator
Well completion log, notification prior to well completion operation
CTG NA
COGCC Oil and gas wells Hydrocarbon gas
Green completion practices NA
BLM Well – hydraulically fractured or refractured
Gas Capture/sold, flare, use in operation, inject, OOOO/OOOOa
NA
O&G stakeholder meeting
1/30/2017 10
Definition Threshold Pollutant and control
Standard Monitoring Refract. modifies
Combustion device
NSPS OOOOa
Single storage vessel
6 tpy potential VOC emissions (controlled)
95% reduction of VOC
No detectable emissions
AVO monthly No Continuous pilot
CTG Single storage vessel
6 tpy potential VOC emissions (controlled)
95% reduction of VOC
No detectable emissions
AVO monthly No Continuous pilot
R7.XVII
Single or series of storage vessels
6 tpy actual VOC emissions (uncontrolled)
95% reduction hydrocarbon
No venting (STEM)
AVO/visual inspections at liquids loadout; IR/M21 annually, quarterly, or monthly
Yes Auto-igniter
BLM Single storage vessel
6 tpy potential VOC emissions (controlled)
Route tank vapor gas to sales line or combustion device if infeasible
NA NA NA NA
O&G stakeholder meeting
1/30/2017 11
Definition Location Pollutant Standard Monitoring
NSPS OOOOa
Single centrifugal compressor using wet seals (not at well site)
Between wellhead and distribution
VOC/GHG
95% control Records, cover and closed vent system requirements (if used), annual report
CTG
Between wellhead and transmission/storage
VOC
R7.XVII Wet seal centrifugal compressor
Hydrocarbon 95% control, unless subject to NSPS OOOO
NA
BLM “Leak component” includes openings on a compressor.
O&G stakeholder meeting
1/30/2017 12
Definition Location Pollutant Standard Monitoring
NSPS OOOOa Single
reciprocating compressor (not at well site)
Between wellhead and distribution
VOC/GHG Replace rod packing 26,000 hours or 36 months, or route to process
Records, closed vent system requirements (if used), annual report
CTG
Between wellhead and transmission/storage
VOC
R7.XVII Reciprocating compressor
Natural gas compressor station
NA
Replace rod packing 26,000 hours or 36 months, unless subject to NSPS OOOO
NA
BLM “Leak component” includes openings on a compressor.
O&G stakeholder meeting
1/30/2017 13
Definition Location Pollutant Standard Monitoring
NSPS OOOOa
Single continuous bleed natural gas driven pneumatic controller (not at gas plant) > 6 scfh & single continuous bleed natural gas driven pneumatic controller (at gas plant)
Between well to distribution
VOC/GHG
Gas plant – zero bleed; not at gas plant - < 6 scfh bleed; unless functional need
Records, annual report
CTG
Between wellhead and transmission/storage
VOC
R7.XVIII Pneumatic controllers actuated by natural gas
At/upstream of gas plants
VOC
Bleed rate < 6 scfh; no-bleed where grid power (if placed in service on/after 5/1/2014); unless safety/process need
Tag/inspect/maintain/records of high-bleed pneumatic controllers
BLM Pneumatic controller – continuous bleed rate > 6 scfh
Uses gas produced from a Federal lease
Replace with controller < 6 scfh (unless functional need or routed to flare/process)
NA
O&G stakeholder meeting
1/30/2017 14
Definition Location Pollutant Standard Monitoring
NSPS OOOOa
Single natural gas driven diaphragm pump (not at gas plant) > 90 days & single natural gas driven diaphragm pump (at gas plant)
Well site & gas plant
GHG/VOC
Gas plant – zero bleed; not at gas plant – route to 95% existing control device (document if not 95%)
Records, closed vent system requirements (if used), annual report CTG VOC
R7.XVII NA
BLM
Pneumatic diaphragm pump (operating > 90 days/yr)
Uses gas produced from Federal lease
Replace with zero emissions pump or route to process (unless functional need then route to flare/combustor)
NA
O&G stakeholder meeting
1/30/2017 15
Component Location Monitoring Frequency Leak threshold Repair & resurvey
NSPS OOOOa
Component with potential to emit fugitive emissions of methane or VOC
Well site (except only wellhead(s)) & compressor station between well and distribution
Emissions monitoring plan – OGI, EPA M21
Well site – semiannually; compressor station – quarterly
OGI – visible emission; M21 - > 500 ppm (above background)
Repair 30 days (unless infeasible/shutdown/etc) & verify 30 days
CTG Component with potential to emit fugitive emissions of VOC
Well site > 15 BOE/day (except only wellhead(s)) & gathering and boosting station between well transmission/storage
R7.XVII Pump seal, flange, pressure relief device, connector, valve
Well production facility & natural gas compressor station between well and inlet to gas plant
IR camera, EPA M21, alternative AIMM
Tiered (based on VOC emissions)
IR/AVO – detectable emissions; M21 > 2000/500 ppm hydrocarbon
Repair 5 days & verify 15 days
BLM Any component that has the potential to leak gas and can be monitored
Site /equipment to produce/treat/compress/etc gas from a Federal lease (except only wellhead or depressurized well)
OGI, portable analyzer (EPA M21), BLM approved alternative
Wellhead/other equipment – semiannual & compressor station – quarterly OR BLM alternative
OGI – visible hydrocarbon emission; portable analyzer - > 500 ppm hydrocarbon; soap solution – bubbles
Repair 30 days (unless good cause) & verify 30 days
O&G stakeholder meeting
1/30/2017 16
Component Monitoring Frequency Leak threshold Repair & resurvey
NSPS OOOOa
Group of all equipment within a process unit
LDAR program equivalent to NSPS VVa
CTG Equipment components in VOC service
LDAR program equivalent to NSPS VVa
R7.XVII Leaking equipment Comply with NSPS KKK (NSPS VV) unless subject to NSPS OOOO/OOOOa (NSPS VVa)
BLM (see previous slide)
• Well heads
• Intermittent pneumatic controllers
• Liquids unloading
• Alternative controls and monitoring
O&G stakeholder meeting
1/30/2017 17
Key differences
• Storage vessel : definition/threshold, pollutant, standard, monitoring
• Compressors, pneumatic devices, compressor stations: location, pollutant
• LDAR: pollutant, components, inspection technology/frequency, repairs, M21 threshold
O&G stakeholder meeting
1/30/2017 18
Equipment/process BLM NSPS
OOOOa CTG R7
Pollutant VOC/
HC VOC and methane
VOC HC
Well completions
Centrifugal compressors
Reciprocating compressors
Pneumatic controllers
Pneumatic pumps
LDAR – natural gas processing plants
LDAR – well sites & compressor stations
O&G stakeholder meeting
1/30/2017 19
• Provide comments
(“O&G CTG”)
• Continued stakeholder meetings
• 2017 rulemaking hearing request
O&G stakeholder meeting
1/30/2017 20
Leah Martland,
Regulatory Development – Planning and Policy Program
O&G stakeholder meeting
1/30/2017 21
• Regulation Number 7: https://www.colorado.gov/pacific/cdphe/aqcc-regs
• EPA’s Oil and Gas CTG: https://www.epa.gov/controlling-air-pollution-oil-and-natural-gas-industry/2016-control-techniques-guidelines-oil-and
• EPA’s oil and gas NSPS (OOOO, OOOOa): https://www.epa.gov/controlling-air-pollution-oil-and-natural-gas-industry/new-source-performance-standards-and#Proposed
• BLM’s venting and flaring rule: https://www.blm.gov/documents/national-office/public-room/data-0
O&G stakeholder meeting
1/30/2017 22
