westar oil & gas conference october 2008 lori bocchino wyoming oil & gas permitting and new...

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WESTAR Oil & Gas Conference October 2008 Lori Bocchino Wyoming Oil & Gas Permitting and New Rule/Policy Revisions

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WESTAR Oil & Gas ConferenceOctober 2008

Lori Bocchino

Wyoming Oil & Gas Permitting and New Rule/Policy Revisions

Current Permitting

BACT for Compressor Engines NOx

Review on a case by case basis; and have seen a range of 0.7-1.5 g/hp-hr for NOx

VOC For engines >100 hp, 0.7 g/hp-hr for VOC due to Subpart

JJJJ and ozone concernsPresumptive BACT Guidance for Wellsite

Production Facilities Statewide requirements Jonah-Pinedale area requirements Current version applies to all wells spudded or facilities

modified on/after September 1, 2007.

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Wyoming DEQ 10/08

Submission/Installation Dates

Permit Applications 90 days after First Production

Prescribed Controls 60 days after First Production Upon First Production in Jonah-Pinedale

Completion Reports 60 days after First Production

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Wyoming DEQ 10/08

First Date of Production (FDP):

The date permanent production equipment is in place and product is flowing to sales lines, gathering lines or storage tanks. Production occurring during well completion activities which is routed to temporary production equipment is considered to occur prior to the FDP. If extended periods of time pass between zone completions and production from initially completed zones is flowing to permanent production equipment, the FDP is the date when production began flowing to the permanent equipment, even though more zones will be completed later.

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Wyoming DEQ 10/08

StatewideStatewide Jonah-PinedaleJonah-Pinedale

Dehys: Projected potential emissions

≥ 5 TPY HAPs or 15 TPY VOCs

98% control w/in 60 days of FDP

Condensate tanks: Projected potential emissions

≥ 20 TPY VOC 98% control w/ in 60 days of

FDP Control may be removed after

one year if emissions have declined to < 15 TPY VOCs

BACT review required if total VOC > 15 TPY

Dehys: 98% control upon FDP

Condensate tanks: 98% control upon FDP Control may be removed after

one year if flash emissions have declined to < 15 TPY VOCs

Pneumatic Heat Trace/Hot Glycol Circulation Pumps: Discharge lines w/HC motive gas

route into fuel gas supply or to a closed/controlled system upon FDP.

BACT review required if total VOC from any source > 15 TPY

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Current BACT Guidance

Wyoming DEQ 10/08

Presumptive BACT Revisions

Identifying “Concentrated Development Areas” More strict emissions control requirements

Also, new requirements for: Drilling, Completions, Workovers Well Site Production Equipment Wellheads, Wellsites, Pipelines, Gathering System

Lines Truck Loading Best management practices to reduce well slugging

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Wyoming DEQ 10/08

Drilling, Completions, Workovers

Wyoming DEQ 10/08

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Permits for well completions/re-completions requiring “green completion” techniques.

Planned venting in preparation for and during workovers/downhole repairs must be flared or routed into a closed loop system or gathering/sales line.

(No active evaporation of fluids from “drill” pits.)

Well Site Production Equipment

Wyoming DEQ 10/08

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Produced Water Tanks NEW SITES: At sites where condensate flash must be

controlled, produced water tanks must be closed top w/vapors routed to the flash emissions control device upon start up.

MODIFIED SITES: At sites where condensate flash must be controlled, new and existing produced water tanks must be closed top and all vapors from new and existing tanks must be tied into the condensate tank emissions control upon modification to the site.

Pneumatic Pumps NEW SITES: Discharge from natural gas activated pumps must

be vented to emissions control or to a closed loop system (gas sales or collection line, fuel gas line, etc.). When routed to a fuel gas system, excess gas not used as fuel must be vented to an emissions control device.

MODIFIED SITES: New and existing natural gas-activated pumps must be controlled as above.

ELECTRIFIED NEW and MODIFIED SITES: All pumps must operate on instrument air.

Well Site Production Equipment (con’t)

Wyoming DEQ 10/08

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Pneumatic Devices NEW SITES: Install no-bleed or low-bleed devices. MODIFIED SITES: New devices must be no-bleed or low-

bleed. Existing high-bleed* devices must be retrofit/replaced with no-bleed or low-bleed.

ELECTRIFIED NEW and MODIFIED SITES: All devices must operated on instrument air.

Condensate/Oil Tanks Tank vapors controlled upon start up. Controls may be

removed after one year if VOC emissions, based on actual production rates, have declined to < 10 TPY.

Dehydration Units Reboiler still vent and glycol flash separator vapors must

be controlled upon start up.

* Natural Gas STAR Program: high-bleed = ≥ 6 scfh (50 Mcfy)

Wellheads, Wellsites, Pipelines, Gathering System Lines

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Gas associated with planned blowdown and venting episodes, including blowdown of lines to relieve fluid/ice/hydrate build-up, must be routed to a flare or closed system.

At sites where flashing emissions are controlled, vapors associated with automatic, intermittent blowdown/venting must be routed to the emissions control or to a closed system.

Truck Loading, Well Venting/Blowdown

Truck Loading Where tank emissions are controlled, route vapors

displaced during truck loading to the tank emissions control or other vapor balancing system.

Well Venting/Blowdown When the gas flow velocity from a well is not sufficient

to lift reservoir liquids, eliminate well venting and blowdown to the atmosphere in order to expel the wellbore liquids by:

Installing velocity tubing strings (smaller ID tubing) Installing plunger lift systems

When these options are not achievable, any gas vented or blown down to restore gas production must be flared or captured.

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Wyoming DEQ 10/08

Drill Rig Engine Permitting

VOLUNTARY partnership between industry and AQD. Met with several operators to see how permitting will fit

their drilling plans.BAT required in Jonah Infill ROD; permitting

required in Pinedale Anticline ROD.Not looking to control emissions every rig.Full development drilling may have different

requirements than exploratory drilling.Demonstration period for exploring different

control measures. EnCana found that switching to natural gas not only

lowered emissions, but was more economical.

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Wyoming DEQ 10/08

Sublette County Ozone Response

Wyoming DEQ 10/08

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AQD can no longer conclude that increases in NOX and/or VOC in Sublette County can be justified

Interim permitting policy has been implemented on July 21, 2008 All applications will require a demonstration that the

proposed facility will not prevent attainment or maintenance of an air quality standard

Interim Permitting Policy

Three options Modeling Offsets Alternate demonstrations

AQD expects that offsets for VOC and/or NOX emissions is the most practical demonstration

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Interim Policy (con’t.)

Offset must be in Sublette CountyOffset must be enforceable or approved by

AQDReductions must occur after 4/1/08Offset Ratios

For applications submitted prior to August 1, 2008:

1:1 offsets for NOX and VOCs For applications received after August 1, 2008:

Offset of 1.5:1 for VOC and 1.1:1 for NOX

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Other efforts in Sublette County

Wyoming DEQ 10/08

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Request for voluntary reductionsImplementation of PAPA ROD

NOX reductions required Liquids gathering required Ozone modeling and mitigation

Non-voluntary initiatives May be through nonattainment SIP Develop models then strategies

Questions?