Transcript Slide 1

Montana DEQ
Air Resources Management Bureau
Registration Section
Presented By: Mark Ewanic
Montana Petroleum Association
Annual Meeting
August 27, 2008
Billings, Montana
August 27, 2008
Outline
•
Introduction
•
Registration/Deregistration
– History
– Office & Staff
–
–
–
–
Submittal Process
New/Updated Registrations
Backlogged Registrations
Deregistrations
August 27, 2008
•
Compliance Monitoring
•
Providing Compliance Assistance
•
•
Current Status and Path Forward
Contact Information
– Compliance Determination
– Inspection Zones
– Field Approach
– Registered Facilities
– Unregistered Facilities
– Common Compliance Issues
Introduction
August 27, 2008
History
J
F
M
A
M
J
J
2006
A
S
O N
D
J
F
M
A
M
J
J
2007
A
S
O N
D
J
F
M
A
M
J
J
2008
A
S
O N
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
August 27, 2008
D
History
Jan 06 – Subchapter 16
J
F
M
A
M
J
J
2006
A
S
O N
D
J
F
M
A
M
J
J
2007
A
S
O N
D
J
F
M
A
M
J
J
2008
A
S
O N
D
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)
August 27, 2008
History
Jan 06 – Subchapter 16
J
F
M
A
M
J
J
2006
A
S
O N
D
J
F
M
A
M
J
J
2007
A
S
O N
D
J
F
M
A
M
J
J
2008
A
S
O N
Apr 06 – Subchapter 17
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
August 27, 2008
D
History
Oct 07 – Registration Section
Jan 06 – Subchapter 16
J
F
M
A
M
J
J
A
S
O N
D
2006
Apr 06 – Subchapter 17
J
F
M
A
M
J
J
2007
A
S
O N
D
J
October 2007
• Air Quality Registration Section
F
M
A
M
J
J
2008
A
S
O N
– 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
August 27, 2008
D
History
Jan 06 – Subchapter 16
J
F
M
A
M
J
J
A
S
Oct 07 – Registration Section
O N
D
2006
Apr 06 – Subchapter 17
J
F
M
A
M
J
J
2007
A
S
O N
D
J
F
M
A
M
June 08 – Field Insp/Verif
J
J
2008
A
S
O N
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
August 27, 2008
D
History
Jan 06 – Subchapter 16
J
F
M
A
M
J
J
A
S
Oct 07 – Registration Section
O N
D
2006
Apr 06 – Subchapter 17
J
F
M
A
M
J
J
S
O N
D
J
F
M
A
M
J
J
2007
2008
June 07 – Initial Facility Inspections
Present Day
• Ongoing Work
–
–
–
–
–
A
A
August 27, 2008
O N
WE ARE
HERE
Inspection reports
Contact companies with unregistered facilities
New registration/deregistration requests
Backlog
Evaluate/improve process
• Subchapter 17 rule change
S
D
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
&
Deregistration
Processes
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
Compliance
Monitoring
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
Providing
Compliance
Assistance
August 27, 2008
Registered Facilities
Field Comp.
Insp.
30-Days
Issue
Insp. Rpt.
Comp. Desk
Audit
No Further
Action
YES
In Compliance
Resolution,
More Time,
etc.
NO
Phone Call
Followed By
Report
YES
Company
Responds
NO
August 27, 2008
Warning or
Violation
Letter
Possible
Enforcement
Unregistered Facilities
No Further
Action
NO
Review
DNRC Data
???
PTE >25-tpy
???
YES
Site
Verification
Submit
Registration
Phone Call
Followed By
Letter
60-Days
Company
Responds
NO
Possible
August 27, 2008Enforcement
Request
Add. Time
YES
Submit Info.
For Not
Registering
Review
Submittal
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
TM
ThermCAM
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 Status
and
Path Forward
August 27, 2008
Registration Activity (8/26/08)
Total Registrations Submitted:
727
Total Registered Facilities:
621
Reg. Facilities Acknowledged:
(Backlog/New)
135/67
Reg. Updates Acknowledged:
145
August 27, 2008
Inspection/Verification Activity
Facility Inspections:
75
Facility Verifications:
130
August 27, 2008
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
• Emission Inventory
– Send out in December
– Report actual 2008 emissions
– Return to Department by February
• 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
Contact
Information
August 27, 2008
DEQ ARMB Registration Section
Butte, Montana Office
49 N Main, Suite B
Butte MT 59701
Tel: (406) 782-2689
Fax: (406) 782-2701
Web: http://deq.mt.gov/
August 27, 2008