Perspectives on Environmental Challenges Relating to Oil and Gas Development William C. Allison V Director, Air Pollution Control Division Colorado Department of Public Health and Environment October 24, 2011
Jan 14, 2016
Perspectives on Environmental Challenges Relating to Oil and Gas Development
William C. Allison VDirector, Air Pollution Control Division
Colorado Department of Public Health and Environment
October 24, 2011
Oil and Gas Regulation in Colorado
• Drilling activities governed by Colorado Oil and Gas Conservation Commission (COGCC).
• Air quality matters governed by Colorado APCD • 2008 legislation promotes agency collaboration on many
O&G matters, including odor, citizen complaints, environmental performance, etc.
• Strong O&G focal point north of Denver area (Denver-Julesburg Basin) and on Western Slope of Colorado (Piceance Basin)
45,956
22,500
24,500
26,500
28,500
30,500
32,500
34,500
36,500
38,500
40,500
42,500
44,500
46,500
48,500
JAN
200
2A
PR
JUL
OC
TJA
N 2
003
AP
RJU
LO
CT
JAN
200
4A
PR
JUL
OC
TJA
N 2
005
AP
RJU
LO
CT
JAN
200
6A
PR
JUL
YO
CT
JAN
200
7A
PR
JUL
YO
CT
JAN
200
8A
PR
JUL
YO
CT
JAN
200
9A
PR
JUL
YO
CT
JAN
201
0A
PR
JUL
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CT
JAN
201
1A
PR
JUL
Y
NU
MB
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OF
AC
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COLORADO MONTHLY ACTIVE WELL COUNT09-07-11
1529
22732007
2245
2917
4323
5904
6368
8027
5159
5996
3157
125 242 312560
890
1762
2773
3649
5007
3585
4194
1918
0
1000
2000
3000
4000
5000
6000
7000
8000
9000
2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011
Num
ber
of A
pplic
atio
ns F
or
Per
mit
s T
o D
rill
Number of Oil and Gas Well Permits For Wells Drilled Directionally From Common Well Pads in Colorado
09-07-11
Total APDS
APDs For Directional Wells From Common Well Pads
Relative VOC Contribution from the Oil and Gas Sector(Anthropogenic sources)
Nine county upper front range ozone non-attainment area (2010)
Colorado Clean Air, Clean Jobs Act
• Legislation passed in 2010 • Designed to promote retirement of older coal-
fired EGUs• Promotes natural gas and other sources• 70,000 tons of NOx and SOx reductions
Concerns Relating to O&G Activity
• Permits • Enforcement• Health Effects• Air Quality • Water Quality• Fracking / Water Usage• Wildlife
• ~3,360 permit applications received in 2010– Represents ~ 70% increase since 2008
• APCD is implementing various mechanisms to
address permit volumes – Temporary engineers (brings engineers corps to 11+)– New permitting tools being developed (e.g., engine
general permit)– Expanded permit templates and standardized language to
speed permitting
APCD Oil and Gas Permitting
APCD Oil & Gas Inspections/Enforcement
• 336 inspections for 2010/2011 inspection period
• Ozone non-attainment area a priority
• Oil and Gas industry significant portion of non-compliance in Colorado
Recent Steps Taken To Address Oil and Gas Industry Impacts in Colorado
• 2008 - 2009 Overhaul of COGCC Rules
• 2007 - 2008 Revisions to AQCC oil and gas rules
• Condensate Tanks in NAASystem must be controlled by at least 90% during 2011 ozone season
• Reciprocating Internal Combustion Engines (RICE) Stringent statewide emission standards meant to mirror NSPS JJJJ requirements.
2011 Ozone Planning
Identified 26 separate strategies, including:• Condensate/crude/produced water tanks• Dehydrators• Drill rigs• Fugitive leaks• Green completions• Electronic surveillance programs for condensate tanks
Disclosure of fracking fluids
COGCC fracking rules currently undergoing STRONGER review
Recent Steps (cont.)
Division Innovations to Address Oil and Gas Workload Issues
• Self-Certification of Condensate Tanks- Three county pilot project
• Electronic Surveillance System (ESS) Pilot Project- Early notification of problems with auto-igniters at ESS-equipped tanks
• Development of various General Permits
Regulatory Activities: EPA
• EPA Oil and Gas Rules – Proposed rules published in Federal Register on 8/23/11– APCD presently reviewing extensive set of rules
• Package has revisions to NSPS KKK, NSPS LLL, MACT HH, and MACT HHH; and, has new NSPS OOOO
• NSPS OOOO:– Focus on wellhead emissions (fracking) – Requires green completions and/or flaring for most wells– Also requires controls on compressors, pneumatics, storage
tanks, sweetening units, and onshore natural gas processing plants
Regulatory Activities: Aggregation
• Colorado is front and center with aggregation due to Anadarko’s Frederick Compressor Station
• EPA ultimately concurred with Colorado’s determination
• Colorado successfully continues to build our permitting record on potential aggregated sources– Continue to use the “three-part” test to assess
aggregation, as appropriate
Closing Remarks for Oil and Gas
• O&G largest single sector for APCD- VOC Emissions- Air Permitting- Compliance/ Enforcement
• Oil and gas-related activities remain significant
• Colorado rising to challenge to address this important source category
For More Information
http://www.cdphe.state.co.us/ap/oilgas.html
http://cogcc.state.co.us/
http://fracfocus.org/