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Montana DEQAir Resources Management
Bureau
Registration Section
Montana Petroleum AssociationAnnual MeetingAugust 27, 2008Billings, Montana
Presented By: Mark Ewanic
August 27, 2008
August 27, 2008
Outline• Introduction
– History– Office & Staff
• Registration/Deregistration– Submittal Process– New/Updated Registrations– Backlogged Registrations– Deregistrations
• Compliance Monitoring– Compliance Determination– Inspection Zones– Field Approach
• Providing Compliance Assistance– Registered Facilities– Unregistered Facilities– Common Compliance Issues
• Current Status and Path Forward
• Contact Information
August 27, 2008
Introduction
August 27, 2008
History
Before January 2006– Department had 600+ MAQP applications from
oil or gas well facilities– Majority of facilities already
constructed/operating without MAQP– Not feasible to utilize existing Department staff
to issue the MAQPs within statutory time frames
J F M A M J J A S O N D
2006J F M A M J J A S O N D
2007J F M A M J J A S O N D
2008
August 27, 2008
History
January 2006• ARM Title 17, Chapter 8, Subchapter 16
– Oil or gas well facilities can construct/operate prior to issuance of MAQP
– Must comply with requirements of Subchapter 16
– Must have submitted application prior to January 3, 2006, or within 60 days after well completion date (whichever was later)
J F M A M J J A S O N D
2006J F M A M J J A S O N D
2007J F M A M J J A S O N D
2008
Jan 06 – Subchapter 16
August 27, 2008
History
April 2006• ARM Title 17, Chapter 8, Subchapter 17
– Allow oil or gas well facilities to register with the Department in lieu of obtaining MAQP
• Supply requested registration information• Follow fee, operating, emission control, inspection and
repair, and recordkeeping and reporting requirements
J F M A M J J A S O N D
2006J F M A M J J A S O N D
2007J F M A M J J A S O N D
2008
Jan 06 – Subchapter 16
Apr 06 – Subchapter 17
August 27, 2008
History
October 2007• Air Quality Registration Section
– Office established and staffed– Began acknowledging backlog– Acknowledge new registration/deregistration
requests– Identify/contact facilities that may be required
to be either permitted or registered but have not submitted an application
J F M A M J J A S O N D
2006J F M A M J J A S O N D
2007J F M A M J J A S O N D
2008
Jan 06 – Subchapter 16
Apr 06 – Subchapter 17
Oct 07 – Registration Section
August 27, 2008
History
June 2008• Initial Field Inspections and Verifications
– Compliance inspections on Registered facilities– Verify status of unregistered facilities that may
require MAQP or registration– Provide compliance assistance
J F M A M J J A S O N D
2006J F M A M J J A S O N D
2007J F M A M J J A S O N D
2008
Jan 06 – Subchapter 16
Apr 06 – Subchapter 17
Oct 07 – Registration Section
June 08 – Field Insp/Verif
August 27, 2008
History
Present Day• Ongoing Work
– Inspection reports– Contact companies with unregistered facilities– New registration/deregistration requests– Backlog– Evaluate/improve process
• Subchapter 17 rule change
J F M A M J J A S O N D
2006J F M A M J J A S O N D
2007J F M A M J J A S O N D
2008
Jan 06 – Subchapter 16
Apr 06 – Subchapter 17
Oct 07 – Registration Section
June 07 – Initial Facility Inspections
WE ARE HERE
August 27, 2008
Purpose of Registration• Provide oil or gas well facilities with an
alternative to MAQP– More operational flexibility
• Register 60-days after well completion• Notify within 15-days after change
– Reduced administrative burden• No application• No public notice• No BACT analysis• No notification prior to change
August 27, 2008
Reg. Section Office & Staff• Office - Butte, Montana• Staff
– 1 Supervisor• Dave Aquirre
– 3 Full-Time Staff• Mark Peterson• Eileen Steilman• Mark Ewanic
– 2 Student Interns• Karen Gillespie• Whitney Walsh
August 27, 2008
Registration&
DeregistrationProcesses
August 27, 2008
Registration Submittal Process
• Facility Eligibility
• Registration Form– Inventory of emitters– Quantify emissions
• Registration & Operation Fees
August 27, 2008
Oil or Gas Well Facility Eligibility
• Meets definition of oil or gas well facility– 75-2-103(13), MCA
• Subject to requirements of ARM 17.8.743– PTE > 25-tpy any airborne
pollutant– Modified after 11/23/68
and PTE increase >25-tpy
• NOT subject to ARM Title 17, Chapter 8, Subchapter 12 (Title V Source)
August 27, 2008
Registration Form
• Available online– (http://deq.mt.gov/AirQuality/airForms.asp)
• Owner & Facility Information– Contact– Location– Emitting Units– Emission Controls– Uncontrolled/Controlled Emissions
• Electronic or hard copies
August 27, 2008
Registration & Operation Fee
• Registration Fee– $500 per newly
registered facility– Registration request is
incomplete until fee is paid
• No fee when submitting facility update
• Annual Operation Fee– $600 per registered
facility
August 27, 2008
Registration Acknowledgement
• Completeness Review
• Compliance Review Desk Audit
• Acknowledgment Letter
August 27, 2008
Completeness Review
• Facility is eligible for registration?
• Registration Process and Information is complete?
• Registration Fee has been received?
• Department requests additional information if necessary
August 27, 2008
Compliance Review Desk Audit
• Completed prior to registration acknowledgement
• Does not delay registration– Potential compliance issues
identified– Provides compliance
assistance
August 27, 2008
Acknowledgement Letter
• New facilities – Within 30-days of receiving completed Registration Form
• Backlog - 25% each calendar year beginning in 2008
August 27, 2008
Deregistration Request• Letter to Department
– Justification for deregistration• Department may request additional
information– Quantify all emissions (e.g., fugitives)– Emission calculations using more appropriate
software– Source specific inputs
• Updated production• Separator temperature and pressure• Site specific oil and/or gas analytical data
• Plan Ahead– Submit in time to deregister by March 1– Be aware of issues that my delay
acknowledgement
August 27, 2008
Deregistration Acknowledgement
• Review similar to compliance review desk audit
• Respond to deregistration requests within 30-days of receiving completed request
August 27, 2008
ComplianceMonitoring
August 27, 2008
Compliance Determination• Initial compliance review desk audit
– Completed when Registration is acknowledged
• Field inspection– Standardized field observations sheet– Compliance review desk audit upon
return to office
• Documentation– Standardized inspection reports– Supplemental CD
• Digital photos• Video from IR camera
August 27, 2008
Inspection Zones
• Divided counties with oil or gas well facilities
• Full-time staff members assigned zones– Complete field inspections – Registered– Complete field verifications –
Unregistered
August 27, 2008
Inspection Zones - Inspectors
August 27, 2008
Inspection Zones - Facilities
August 27, 2008
Inspection Zones – Richland County
August 27, 2008
Current Field Approach• Focusing on
companies/facilities that did not comply with the ARM– Focus on unregistered
facilities potentially needing to be registered
– Conduct compliance field inspections on registered sources in same area
August 27, 2008
ProvidingComplianceAssistance
August 27, 2008
Registered FacilitiesField
Comp. Insp.
Comp. Desk Audit
Issue Insp. Rpt.
30-Days
In Compliance
No Further Action
YES
NO
Phone Call Followed By
Report
Warning or Violation
Letter
Possible Enforceme
nt
Company Responds
YES
NO
Resolution, More
Time, etc.
60-Days
August 27, 2008
Unregistered Facilities
Review DNRC Data
???PTE >25-tpy
???
Phone Call Followed By
Letter
No Further Action
Company Responds
Site Verificatio
n
NO
YES
60-Days
NO YES
Possible Enforceme
nt
Request Add. Time
Submit Registration
Submit Info. For Not
Registering
Review Submittal
August 27, 2008
Common Compliance Issues• Controlling emissions
– Tank emissions not controlled• Flare, VRU, etc.
– Flare not working properly (i.e., combusting produced gas and/or tank gas)
– Leaks detected
• H2S detected– Strong odor but no air quality analysis– Must comply with ARM 17.8.210
• Notification of change(s) to registration information– Addition of emitter– Change to emission controls
August 27, 2008
ThermCAMTM GasFindIR Camera
• Detect hydrocarbon emissions– Cost savings to industry
• Leaks in produced gas line• Leaks in vapor recovery unit
– Assistance with site maintenance
• Leaking thief hatches (faulty seal)
• Flares not operating
• Repair leaking VOC equipment (ARM 17.8.1712)
August 27, 2008
Current Statusand
Path Forward
August 27, 2008
Registration Activity (8/26/08)Total Registrations Submitted: 727
Total Registered Facilities: 621
Reg. Facilities Acknowledged: 135/67 (Backlog/New)
Reg. Updates Acknowledged:145
August 27, 2008
Inspection/Verification Activity
Facility Inspections:75
Facility Verifications: 130
August 27, 2008
• Emission Inventory– Send out in December– Report actual 2008 emissions– Return to Department by February
Upcoming Activity• Rule Changes – Subchapter 17
– Addition of BACT requirements for larger internal combustion engines
– Emission control requirements of Subchapter 16 match Subchapter 17
– Notification requirements
• Registration Form Format– Working on ExcelTM version– Link calculation sheets
August 27, 2008
Things To Remember• Not required to register in
lieu of MAQP• No fee for submitting an
update• Registering by facility
versus by well• PTE should reflect
maximum potential production
• March 1 deadline for deregistration
And when in doubt...
August 27, 2008
ContactInformation
August 27, 2008
DEQ ARMB Registration Section
Butte, Montana Office49 N Main, Suite BButte MT 59701
Tel: (406) 782-2689Fax: (406) 782-2701Web: http://deq.mt.gov/