Top 10 Air Quality Issues for the Oil and Gas Industry in 2013

TOP 10 AIR QUALITY ISSUES FOR THE OIL AND GAS INDUSTRY IN 2013

Agenda • Well Completion Requirements of 40 CFR Part 60 Subpart OOOO -

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

• Final Revisions to Pennsylvania General Permit (GP-5) - Natural Gas Production and/or Processing Facilities

• 40 CFR Part 98 Subpart W - Petroleum and Natural Gas Systems • Aggregation of Emissions for New Source Review and Title V Applicability • 40 CFR part 63 Subpart ZZZZ - National Emissions Standards for Hazardous

Air Pollutants for Stationary Reciprocating Internal Combustion Engines • Proposed Revisions to PADEP Document No. 275-2101-003: Air Quality

Permit Exemptions

NSPS RULES FOR

NATURAL GAS WELL COMPLETIONS

Ron Cusano SCHNADER HARRISON SEGAL &

LEWIS LLP

I. Final NSPS and NESHAPS / Oil and Gas Sector (the “Final Rule”)

A. Promulgated on August 16, 2012 [77 Fed. Reg. 49490 (August 16, 2012)].

I. Final NSPS and NESHAPS / Oil and Gas Sector (the “Final Rule”)

A. Promulgated on August 16, 2012 [77 Fed. Reg. 49490 (August 16, 2012)].

B. NSPS applies to numerous categories of sources in addition to gas well completions.

II. Statutory Authority and Requirements for NSPS

A. Before listing a category of stationary sources EPA must find that emissions from the source category cause or contribute significantly to air pollution which endangers public health or welfare. Section 111(b)(1)(A) of the Clean Air Act (the “CAA” or “Act”); 42 U.S.C. §7411(b)(1)(A).

B. Best System of Emission Reduction (“BSER”): BSER must be cost effective and must have been adequately demonstrated. Section 111(a)(1), 42 U.S.C. §7411(a)(1).

III. Well Completion Rules

A. PaDEP Proposed Revisions to Plan Approval and Operating Permit Exemption List (42 Pa.B. 742) February 2, 2013 B. Applicability and Definitions (Well Completion Rules)

1. Apply to every gas well affected facility that is fractured or refractured after October 15, 2012. (40 C.F.R. §60.5375).


2. “Gas well affected facility … is a single natural gas well”. (40 C.F.R. §60.5365).



3. “Gas well” or “natural gas well” - “an on-shore well drilled principally for production of natural gas”. (40 C.F.R. §60.5430).




4. Apply to conventionally drilled gas wells.




4. Apply to conventionally drilled gas wells.

5. “Delineation well” - “a well drilled in order to determine the boundary of a field or producing reservoir.” (40 C.F.R. §5430).

6. “Wildcat well” - “a well outside known fields or the first well drilled in an oil or gas field where no other oil and gas production exists.” (40 C.F.R. §5430).


7. “Low pressure gas well” “means a well with reservoir pressure and vertical well depth such that 0.445 times the reservoir pressure (in psia) minus 0.038 times the vertical well depth (in feet) minus 67.578 psia is less than the flow line pressure at the sales meter.” (40 C.F.R. §60.5430).


7. “Low pressure gas well” “means a well with reservoir pressure and vertical well depth such that 0.445 times the reservoir pressure (in psia) minus 0.038 times the vertical well depth (in feet) minus 67.578 psia is less than the flow line pressure at the sales meter.” (40 C.F.R. §60.5430).

8. Reduced emissions completion means gas that would otherwise be vented must be captured, cleaned and directed to the flowline, re-injected into the well or another well, used on-site as a fuel source, or used for other useful purpose without emission to the atmosphere. (40 C.F.R. §60.5430).

B. Standards

Well Category

Completion Requirements

Wildcat, delineation and low pressure wells fractured or refractured after October 15, 2012

Route emissions to completion combustion device [40 C.F.R. §60.5375(f)].

Other gas wells fractured or refractured prior to January 1, 2015

Route emissions to completion combustion device [40 C.F.R. §60.5375(a)(3) and (4)].

Gas wells fractured or refractured after January 1, 2015

Use REC and route emissions to completion combustion device [40 C.F.R. §60.5375(a)(1)-(4)].

There are three subcategories of gas well affected facilities for purposes of the regulation. They are wildcat, delineation and low pressure wells fractured or refractured after October 15, 2012; all other gas wells fractured or refractured prior to January 1, 2015; and all other gas wells fractured or refractured after January 1, 2015. (77 Fed. Reg. 49497).

1. Do the well completion requirements meet BSER?

2. Exception to flaring which applies, “in conditions that may result in a fire hazard or explosion or where high heat emissions from a completion combustion device may negatively impact tundra, permafrost or waterways”. [40 C.F.R. §60.5375(a)(3)].



3. Owners and operators also have “a general duty to safely maximize resource recovery and minimize releases to the atmosphere during flowback and subsequent recovery." [40 C.F.R. §60.5375(a)(4)].



3. Owners and operators also have “a general duty to safely maximize resource recovery and minimize releases to the atmosphere during flowback and subsequent recovery." [40 C.F.R. §60.5375(a)(4)].

4. Is there a duty to cut trees to remove the risk of fire?


C. Other Requirements 1. Owners and operators of gas wells “must submit annual reports containing the information specified in …” the regulations. [40 C.F.R. §60.5420(b)].


2. The annual report must contain “[r]ecords of deviations in cases where well completion operations with hydraulic fracturing were not performed in compliance with the requirements specified in §60.5375”. [(40 C.F.R. §60.5420(c)(1)].


2. The annual report must contain “[r]ecords of deviations in cases where well completion operations with hydraulic fracturing were not performed in compliance with the requirements specified in §60.5375”. [(40 C.F.R. §60.5420(c)(1)].

3. Each annual report must contain, “a certification by a responsible official of truth, accuracy and completeness”. [40 C.F.R. §60.5420(h)(iv)].

IV. IPAA and PIOGA Petition for Review and Joinder in Petition for Administrative Reconsideration

A. On October 15, 2012, IPAA and PIOGA petitioned the United States Court of Appeals for the District of Columbia Circuit for review of the Final Rule.

IV. IPAA and PIOGA Petitions for Review and Administrative Reconsideration

A. On October 15, 2012, IPAA and PIOGA petitioned the United States Court of Appeals for the District of Columbia Circuit for review of the Final Rule.

B. At the same time, IPAA and PIOGA joined in a pending Petition for Administrative Reconsideration.

1. The pending Petition sought reconsideration of EPA’s low pressure well definition as well as other aspects of the Final Rule.

C. Petition for Administrative Reconsideration

1. EPA did not sufficiently vet the definition of low pressure well and adopted the definition without input from Industry.

C. Petition for Administrative Reconsideration

1. EPA did not sufficiently vet the definition of low pressure well and adopted the definition without input from Industry.

2. EPA’s cost benefit analysis is flawed because EPA relied upon its Natural Gas STAR Program which grossly over-predicted emissions from well completions.

3. Meeting with EPA.

a. EPA has agreed to meet with IPAA, PIOGA and others concerning their pending Petition for Administrative Reconsideration.

b. Meeting is expected to occur in the next two to three months.

d. Jim has also authored an article which will be appearing in the next issue of the PIOGA Newsletter detailing the petitions and the meeting. Persons with information that may be helpful to the cause are encouraged to submit such information to James D. Elliott (717-791-2012), [email protected]; or Ron Cusano (412-577-5203), [email protected].

c. Jim Elliott of Spillman, Thomas & Battle, PLLC is coordinating the meeting.

mailto:[email protected]


e. Lastly, while these developments are positive I must caution that EPA may in the end deny the Petition for Reconsideration or grant the Petition, but decide not to change the Final Rule. Further, even if EPA does decide to make changes it is doubtful that final action on those changes will occur any time soon. EPA is currently projecting that final action on any NSPS Petition for Reconsideration that it grants will not occur before November of 2014. In the meantime, the current rules remain in effect and must be complied with.

GENERAL PLAN APPROVAL AND/OR GENERAL OPERATING PERMIT

BAQ-GPA/GP-5 Natural Gas Compression and/or Processing

Facilities

Roy Rakiewicz, All4 Inc. [email protected]


What is a General Permit? • Authorized by Section 504(d) of the Federal Clean Air Act (CAA),

Section 6.1 of the Pennsylvania Air Pollution Control Act, and 25 Pa. Code §127.611

• General Permits (GP) may be established – If PADEP “determines that sources in the category are similar and can

be adequately regulated using standardized specifications and conditions”

• PADEP has issued multiple General Plan Approvals and General Operating Permits to specific categories of sources in Pennsylvania

• Benefits include pre-approved conditions and expeditious review and approval (i.e., 30 days)

• General Permit (GP-5) covers Natural Gas Compression and/or Processing Facilities

• The use of GP-5 is optional for facilities that meet applicability criteria

Brief History of GP-5 • Previous (original from March 10, 1997) - GP-5

for Natural Gas, Coal Bed Methane, or GOB Gas Production or Recovery Facilities

• Proposed March 3, 2012 - GP-5 for Natural Gas Production and/or Processing Facilities

• Final February 2, 2013 - GP-5 for Gas Compression and/or Processing Facilities

GP-5 Review/Revision Process • Published in March 2012 for public comment • Significant public interest • PADEP revised GP-5 in response to numerous public

comments • Final GP-5 February 2, 2013 • Extensive revisions to final GP-5, several substantial

Final GP-5 Exclusions • Wellheads (proposed new exemption No. 38) • Sources located at Title V facilities • Major new source review (NSR) sources • Engines/turbines used as a “peak shaving engine

generator” or source participating in an Emergency and Economic Load Response Program

• Any engine or turbine that is used on a natural gas transmission line

• Cannot limit PTE of individual units

Final GP-5 Additions • All potentially applicable Federal emission

standards • Natural gas compression/processing facilities • Equipment (turbines, compressors, pneumatic

devices, sweetening units, etc.) • $1,700 application fee • Annual emission limits

Federal Standards Incorporated in GP-5 • Standards of Performance for New Stationary Sources (NSPS)

– 40 CFR Part 60, Subpart JJJJ – Internal Combustion Engines (ICE) – 40 CFR Part 60, Subpart Kb – Liquid Storage Vessels (tanks) – 40 CFR Part 60, Subpart KKK – Equipment Leaks of VOC – 40 CFR Part 60, Subpart KKKK – Combustion Turbines – 40 CFR Part 60, Subpart LLL – Onshore Natural Gas Processing; SO2 Emissions

(Sweetening Units) – 40 CFR Part 60, Subpart OOOO – Crude Oil and Natural Gas Production, Transmission,

and Distribution

• National Emission Standards for Hazardous Air Pollutants (NESHAP) – 40 CFR Part 63, Subpart HH – Oil and Natural Gas Production Facilities (glycol

dehydrators) – 40 CFR Part 63, Subpart ZZZZ – Stationary Reciprocating Internal Combustion Engines

(RICE)

Other Key GP-5 Revisions • Emissions recordkeeping requirements to track actual

emissions on a rolling 12-month basis • Only two definitions

– Natural gas compression and/or processing facility – Coal bed methane

• Engine emission limits/testing for PM and SO2 deleted • Single Source Determination forms required • Most engine emission limits have been revised (i.e.,

lowered)

Why Multiple/Different Standards? • Pennsylvania regulations require best available

technology (BAT) for new sources • GP-5 is predominantly for new sources • BAT can be (and often is) more stringent than

NSPS/NESHAPS limits • GP-5 includes such emissions limits that PADEP

established as BAT • NSPS/NESHAP limits do not go away

GP-5 Coverage • Internal Combustion Engines (ICE) • Combustion Turbines • Compressors • Storage Vessels • Pneumatic Devices • Natural Gas Processing Operations • Glycol Dehydrators • Sweetening Units • Equipment Leaks/Fugitive Emissions

Existing ICE • Continue to comply with the following emissions

standards: – 2.0 g NOX /bhp-hr – 2.0 g CO /bhp-hr – 2.0 g NMHC /bhp-hr

• Comply with (as applicable): – 40 CFR Part 60, Subpart JJJJ (NSPS) – 40 CFR Part 63, Subpart ZZZZ (NESHAP).

Lean/Rich Burn ICE < 100 BHP

“Old” GP-5 40 CFR 60 Subpart JJJJ

“New” GP-5 BAT

NOX Exempt Combined NOX and HC limit

2.0 g/hp-hr

CO Exempt 4.85 g/hp-hr 2.0 g/hp-hr

NMNEHC Exempt Combined NOX and HC limit

No Limits

Formaldehyde No Limits No Limits No Limits

Lean Burn ICE > 100 < 500 BHP


“New” GP-5 BAT

NOX 2.0 g/hp-hr 1.0 g/hp-hr 1.0 g/hp-hr

CO 2.0 g/hp-hr 2.0 g/hp-hr 2.0 g/hp-hr

NMNEHC 2.0 g/hp-hr 0.7 g/hp-hr 0.7 g/hp-hr


Lean Burn ICE >500 BHP


40 CFR 63 Subpart ZZZZ

“New” GP-5 BAT

NOX 2.0 g/hp-hr 1.0 g/hp-hr N/A 0.5 g/hp-hr

CO 2.0 g/hp-hr 2.0 g/hp-hr 47 ppmvd @ 15% O2 or 93%

reduction

47 ppmvd @ 15% O2 or 93%

reduction

NMNEHC 2.0 g/hp-hr 0.7 g/hp-hr N/A 0.25 g/hp-hr

Formaldehyde No Limits No Limits N/A 0.05 g/hp-hr

Rich Burn ICE > 100 < 500 BHP


“New” GP-5 BAT

NOX 2.0 g/hp-hr 1.0 g/hp-hr 0.25 g/hp-hr

CO 2.0 g/hp-hr 2.0 g/hp-hr 0.3 g/hp-hr

NMNEHC 2.0 g/hp-hr 0.7 g/hp-hr 0.2 g/hp-hr


Rich Burn ICE >500 BHP


40 CFR 63 Subpart ZZZZ

“New” GP-5 BAT

NOX 2.0 g/hp-hr 1.0 g/hp-hr N/A 0.2 g/hp-hr

CO 2.0 g/hp-hr 2.0 g/hp-hr N/A 0.3 g/hp-hr

NMNEHC 2.0 g/hp-hr 0.7 g/hp-hr N/A 0.2 g/hp-hr

Formaldehyde No Limits No Limits 2.7 ppmvd @ 15% O2 or 76%

reduction

2.7 ppmvd @ 15% O2 or 76%

reduction

Simple Cycle Turbines <1,000 BHP

• Exempt pursuant to Technical Guidance Document #275-2101-003

Simple Cycle Turbines > 1,000 <5,000 BHP

“Old” GP-5 40 CFR 60 Subpart KKKK

“New” GP-5 BAT

NOX N/A 100 ppmvd @ 15% O2

25 ppmvd @ 15% O2

CO N/A No Limits 25 ppmvd @ 15% O2

NMNEHC N/A No Limits 9 ppmvd @ 15% O2

Formaldehyde N/A No Limits No Limits

PM N/A No Limits 0.03 lb/MMBtu

Simple Cycle Turbines > 5,000 <15,000 BHP “Old” GP-5 40 CFR 60

Subpart KKKK “New” GP-5

BAT

NOX N/A 25 to 100 ppmvd @ 15% O2

15 ppmvd @ 15% O2

CO N/A No Limits 25 ppmvd @ 15% O2

NMNEHC N/A No Limits 9 ppmvd @ 15% O2



Simple Cycle Turbines > 15,000 BHP “Old” GP-5 40 CFR 60

Subpart KKKK “New” GP-5

BAT

NOX N/A 25 to 15 ppmvd @ 15% O2

15 ppmvd @ 15% O2

CO N/A No Limits 10 ppmvd @ 15% O2 or 93%

reduction

NMNEHC N/A No Limits 5 ppmvd @ 15% O2 or 50%

reduction



BAT-Equivalent Incorporated Standards • Compressors

– 40 CFR Part 60, Subpart OOOO • Storage Vessels/Storage Tanks

– 40 CFR Part 60, Subpart OOOO • Pneumatic Devices

– 40 CFR Part 60, Subpart OOOO • Natural Gas Processing Operations

– 40 CFR Part, 60 Subpart KKK • Sweetening Units

– 40 CFR Part 60, Subpart LLL

Existing Glycol Dehydrators • Existing glycol dehydrators (authorized to

operate under a previous GP-5) – Comply with 40 CFR Part 60, Subpart HH – Comply with the emission standards and other

requirements established in previous GP-5

New Glycol Dehydrators • Located at natural gas compression and/or processing

facilities – Comply with 40 CFR Part 63, Subpart HH

• Not subject to 40 CFR Part 63, Subpart HH with uncontrolled PTE of VOC > 5 tpy – Controlled either by at least 95% with a condenser, a flare or other

air cleaning device • Not subject to 40 CFR Part 63, Subpart HH with uncontrolled

PTE of VOC < 5 tpy – Comply with the visible emissions, malodor, and recordkeeping

requirements

Equipment Leak Provisions • Federal equipment leak provisions as applicable

– 40 CFR Part 60, Subparts KKK and OOOO – 40 CFR Part 63, Subpart HH

• Monthly leak detection and repair program (LDAR) – Audible, visual, and olfactory (AVO) inspection

• Quarterly LDAR fugitive leak inspection – Forward looking infrared (FLIR) cameras or – Other approved devices

• Detected leaks must be repaired: – As expeditiously as practicable – But no later than 15 days after detection

• All leaks and associated repairs must be recorded

Key Points • GP-5 is not a comprehensive document

– Applicable NSPS/NESHAP are all incorporated by reference – Sources will need to be aware of all compliance obligations

• Multiple standards apply – Standards may differ (e.g., BAT vs. NSPS ICE standards) – Monitoring, recordkeeping, reporting, and notification

requirements differ • Completion of single source questionaire required • GP-5 not applicable to major sources

– Mandatory rolling 12-month emissions tracking to demonstrate on-going minor source status

• Proceed with caution!

Federal Greenhouse Gas (GHG) Reporting Rule:

40 CFR Part 98, Subpart W Petroleum and Natural Gas Systems

Meghan Schulz, All4 Inc.

[email protected]


Federal GHG Reporting Rule Basics • First promulgated in 2009; first reporting year 2010

– Subpart W promulgated in 2010; first reporting year 2011

• Frequently amended – now up to Subpart UU • What is Carbon Dioxide Equivalent (CO2e)?

• Petroleum & natural gas facilities emitting 25,000+ metric tons/year CO2e must report

i

n

ii GWPGHGeCO ×=∑

=12

Pollutant Global Warming Potential (GWP) CO2 1 CH4 21 N2O 310

From EPA’s “Facility Level Information on GreenHouse gases Tool” (FLIGHT)…

… 46 Pennsylvania facilities reported under Subpart W in 2011.

GHG Reporting Rule Basics • Affected facilities required to develop a GHG Monitoring Plan • Reporting due by March 31st of each year unless otherwise noted • Must use EPA’s electronic GHG Reporting Tool (e-GGRT)

– https://ghgreporting.epa.gov/ghg/login.do – User registration required

https://ghgreporting.epa.gov/ghg/login.do

Subpart W: Petroleum and Natural Gas Systems Applies to the following industry segments: • Onshore Petroleum and Natural Gas Production

– All equipment on/associated with a single well-pad • Onshore Natural Gas Processing

– Separation of natural gas liquids (NGLs) from produced natural gas • Offshore Petroleum and Natural Gas Production • Onshore Natural Gas Transmission Compression • Underground Natural Gas Storage • Liquefied Natural Gas (LNG) Storage • LNG Import and Export Equipment • Natural Gas Distribution

RY 2011 Information from EPA’s “Facility Level Information on

GreenHouse gases Tool” (FLIGHT)

Subpart W: Definition of “Facility” • Facility with respect to onshore petroleum and natural gas production for

purposes of reporting under this subpart and for the corresponding subpart A requirements means: – all petroleum or natural gas equipment on a single well-pad or associated with

a single well-pad and CO2 EOR operations that are under common ownership or common control including leased, rented, or contracted activities by an onshore petroleum and natural gas production owner or operator and that are located in a single hydrocarbon basin as defined in § 98.238.

– Where a person or entity owns or operates more than one well in a basin, then all onshore petroleum and natural gas production equipment associated with all wells that the person or entity owns or operates in the basin would be considered one facility.

Subpart W: GHGs to be Reported

• Equipment leaks and vented CO2 and CH4 emissions

• CO2, CH4, N2O emissions from flares • CO2, CH4, and N2O combustion emissions

– Combustion emission calculation methodology depends on your industry segment

Subpart W: Calculating Emissions Source Type Engineering

Estimate Direct

Measurement

Leak Detection and Leaker Emission

Factor

Equipment Count and Population Emission Factor

Natural gas pneumatic device venting X

Natural gas driven pneumatic pump venting X

Well venting for liquids unloading X X

Gas well venting during completions without hydraulic fracturing

X

Gas well venting during completions with hydraulic fracturing

X X

Source: EPA’s “Overview of Subpart W” webinar, June 19, 2012

Subpart W: Reporting

• Must download a Excel Reporting Form for each industry segment.

ALL4’s GHG Reporting Expertise • Applicability Analysis

• Monitoring Plans • Emissions Inventories

• e-GGRT Submittals • Reporting Follow-up

Thank you!

Aggregation of Emissions for New Source Review and Title V Applicability

Levi Jones

SCHNADER HARRISON SEGAL & LEWIS LLP

“Major Stationary Source”

“Facility” Defined

The Wehrum Memo January 2007

Page 3: “Given the diverse nature of the oil and gas activities, we believe that proximity is the most informative factor in making source determinations for these industries.”

Footnote 16: “In making major stationary source determinations for this industry, some southern States apply a rule that generally results in separating pollutant-emitting activities located outside a 1/4 mile radius.”



The McCarthy Memo September 2009

Page 2: “After conducting the necessary analysis, it may be that, in some cases, ‘proximity’ may serve as the overwhelming factor in a permitting authority’s source determination decision. However, such a conclusion can only be justified through reasoned decision making after examining whether other factors are relevant to the analysis.”

Summit Petroleum Corporation v. EPA

“We conclude that both the dictionary definition and etymological history of the term ‘adjacent,’ as well as applicable case law, support Summit’s position.”

“The EPA does not cite, nor could we locate, any authority suggesting that the term ‘adjacent’ invokes an assessment of the functional relationship between two activities.”

“We are particularly struck by API’s final observation—that the EPA’s source determination in this case is an ironic showcase of the very fears that caused the agency not to adopt a functional relatedness test for source determinations in the first instance.”

Judge Suhrheinrich

The Page Memo December 2012

85

“Outside the 6th Circuit, at this time, the EPA does not intend to change its longstanding practice of considering interrelatedness in the EPA permitting actions in other jurisdictions.”

86

Pennsylvania DEP Guidance October 2012

87

Page 7: “The application of the quarter-mile or less rule of thumb takes a ‘common sense approach’ to determining if sources are located on adjacent or contiguous properties and does not aggregate pollutant-emitting activities that as a group would not fit within the ordinary meaning of ‘building,’ ‘structure,’ ‘facility,’ or ‘installation.’”

88

EPA Comments to PADEP Guidance

89

“totally ignores the real problem, which is that DEP refuses to aggregate emissions results. So if there are 10 compressors right next to one another, DEP monitors emissions of each one separately, even though the combined emissions of all 10 are coming in through your kitchen window.”

State Rep. Jesse White (D - Washington County)

40 CFR Part 63 Subpart ZZZZ - RICE MACT



• 40 CFR Part 63, Subpart ZZZZ – – Regulates existing, new, and reconstructed stationary

RICE, both compression ignition (CI) and spark ignition (SI). – Section 112 of the CAA, focused on HAP.

• 40 CFR Part 60, Subpart IIII and JJJJ – – Regulates new, modified, and reconstructed stationary

RICE, compression ignition (CI) (Subpart IIII) and spark ignition (SI) (Subpart JJJJ).

– Section 111 of the CAA, focused on criteria pollutants.

RICE Regulatory Overview

RICE MACT/NSPS History

2004 … 2008 2009 2010 2011 2012

1/18/2008 – Revised RICE MACT (New, ≤500 hp, Major

and New, All hp, Area) 3/3/2010 – Revised RICE MACT

and NSPS (CI) (CI RICE)

8/20/2010 – Revised RICE MACT NSPS (SI) (SI RICE)

2013

5/3/2013 – CI RICE Compliance Date

10/19/2013 –SI RICE Compliance Date

TODAY 6/15/2004 – Original RICE MACT (New and Existing, >500 hp, Major)

• Stationary RICE - not mobile, not non-road. • Non-road engines are:

– Self-propelled (tractors, bulldozers, etc.) . – Propelled while performing their function (lawnmowers).

• Portable or transportable (has wheels, on a skid, cartable, trailer mounted, etc.). – Portable non-road RICE become stationary if located

onsite more than 12 consecutive months.

What’s a Stationary RICE

• SI – Spark Ignition: – Gas (gasoline, natural gas, propane, landfill gas,

digester gas, etc.) • Other types of SI RICE:

– 2SLB: 2-stroke lean burn. – 4SLB: 4 stroke lean burn. – 4SRB: 4-stroke rich burn. – LFG/DG: Landfill gas/digester gas.

Key RICE Terms

• Area Sources of HAP (i.e., not a major source). – Comply with RICE MACT, by complying with the NSPS – Any new or reconstructed (i.e., after June 12, 2006)

RICE at an area source (regardless of capacity) complies with the RICE MACT by complying with the NSPS for SI RICE (i.e., 40 CFR Part 60, Subpart JJJJ).

Not Everyone is Impacted

Determining Applicability Facility HAP Status – Area vs. Major Site Rated Capacity – Brake Horsepower

(bhp)

RICE Construction Status – Existing, New, or Reconstructed

RICE Fuel Type – CI vs. SI

Construction Date Fire Pump RICE – Yes/No?

Manufacture Date

Peak Saving RICE – Yes/No?

RICE Usage Status – Emergency vs. Nonemergency

Historic Operation – Hours Per Year

• Emission Limits – Carbon monoxide (CO) or formaldehyde (CH2O) (or THC as a

substitute for CH2O) • Notification requirements • Initial and ongoing testing requirements • Monitoring, reporting, and recordkeeping requirements • Fuel requirements • Work practice standards • Generally applicable requirements

Potential Requirements

Emission Limits Existing RICE Located at Area Sources

Site-Rated Capacity

RICE Type Nonemergency RICE

Emergency or Black Start RICE CI SI 2SLB SI 4SLB SI 4SRB SI LFG/DG

≤300 Management Practice Standards

Management Practice Standards




Management Practice Standards 300-500 CO 49 ppm or

70% CO Reduction CO 47 ppm or

93% CO Reduction CH2O 2.7 ppm or

76% CH2O Reduction

>500 CO 23 ppm or 70% CO Reduction

• RICE Subject to an emission limit also subject to: – Testing Requirements:

• Perform an initial performance test • Perform subsequent performance tests.

– Operating Limitations: • Catalyst pressure drop and inlet temperature.

– Related monitoring, reporting, and recordkeeping requirements.

– Notification Requirements. • Initial notification (due date has passed for existing RICE)

– Compliance reports (semiannual or annual) – Fuel requirements

Ongoing Compliance

Ongoing Compliance RICE not subject to an emission limit also subject to:

• Work Practice or Management Practice Standards: Change oil/air filter, inspect air filter and or spark plugs, hoses/belts at

prescribed operating hour intervals Operate/maintain engine per manufacturer’s instructions or owner-

developed maintenance plan May use oil analysis program as an alternative to prescribed oil changes

• Records of maintenance. • No notifications necessary (for the most part) • Fuel requirement

• RICE units vulnerable • Review the RICE MACT and the RICE NSPS • Know your RICE units • Determine your key criteria • Decipher your applicable NESHAP/NSPS

requirements • Take appropriate action

Key Points

• Align your existing maintenance and work practices with those RICE MACT practices that apply – Communicate with RICE maintenance companies

to facilitate this alignment • Be ready to comply with your SI RICE by

October 19, 2013

Key Points

Proposed Revisions to PADEP Permit Exemption List



Current Exemption No. 38 • Oil and gas exploration and production facilities and operations that

include wells and associated equipment and processes used either to: a) drill or alter oil and gas wells; b) extract, process and deliver crude oil and natural gas to the point of lease custody transfer; c) plug abandoned wells and restore well sites, or d) treat and dispose of associated wastes. This includes petroleum liquid storage tanks which are used to store produced crude oil and condensate prior to lease custody transfer (Multiple sources within this subcategory may be exempt from plan approval requirements.). This category does not include gas compressor station engines equal to or greater than 100 HP or gas extraction wells at landfills.

• A true blanket exemption

Proposed Conditional Exemption No. 38 • (i) Wells, wellheads, and associated

equipment subject to 40 CFR Part 60 Subpart OOOO provided the exemption criteria specified in Paragraphs iii, iv, v, vi and vii as applicable are met

• (ii) Conventional wells, wellheads and associated equipment

Proposed Conditional Exemption No. 38 • (iii) Leak Detection and Repair

– Initial leak survey (60 days after completion) – Annual leak survey – Forward looking infrared (FLIR) or other approved device – For all leaks:

• Quantification of leaks • Repair of leaks as expeditiously as practical, no later than 30 days

– No detectable organic emissions consistent with 40 CFR Part 60 Subpart OOOO, or

– Less than a concentration of 2.5% methane – All leaks and repairs must be recorded.

Proposed Conditional Exemption No. 38 • (iv) Storage vessels/storage tanks equipped with VOC

emission controls achieving emission reduction of 95% or greater – Compliance shall be demonstrated in accordance with 40 CFR

Part 60 Subpart OOOO (Uncontrolled PTE > 6 TPY) • (v) Combined VOC emissions from all the sources at the

facility must be less than 2.7 tons on a 12-month rolling basis – HAP emissions less than 1,000 lbs. of a single HAP or one ton of

a combination of HAPs in any consecutive 12-month period – Emission criteria exclude emissions from well heads meeting

the exemption criteria specified in Paragraphs iii (fugitive leaks), iv (NSPS tanks) or vi (flaring) – leaving only non NSPS tanks (< 6 TPY uncontrolled VOC PTE)

Exemption No. 38 • (vi) Flaring operations used at a wellhead subject to 40

CFR Part 60 Subpart OOOO requirements • (vii) Combined NOX emissions from the stationary

internal combustion engines at a facility – less than 100 lbs. /hr., 1000 lbs. /day, – 2.75 tons per ozone season, and – 6.6 tons per year on a 12-month rolling basis – Emission criteria do not include emissions from sources

which are approved by plan approvals/GPs • (viii) Non-road engines as defined in 40 CFR, Part 89.

Exemption No. 38 • Comply with all applicable requirements

including notification, recordkeeping, and reporting requirements as specified in 40 CFR Part 60 Subpart OOOO

• Demonstrate compliance with the exemption criteria using any generally accepted model or calculation methodology within 180 days of after the well completion or installation of a source

Key Points • Proposed conditional exemption No. 38 is more

of a general permit than an exemption • Comments are due March 19, 2013 • Overall complicated for an exemption, but not

terrible • Review the proposed exemption and identify

specific points or technical issues and related hardships

• Prepare public comments or contribute to public comments being prepared by PIOGA

Top 10 Air Quality Issues for the Oil and Gas Industry in 2013

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