Doug Deason - Annual Meeting
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Transcript of Doug Deason - Annual Meeting
Oil and Gas Air IssuesNAAQS in Transition
AIPRO - Arkansas Independent Producers and Royalty Owners
September 29, 2011
Little Rock, AR
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Discussion Topics
Federal Oil and Gas rule & NAAQS changes underway
MACT and NSPS Rulemaking
National Ambient Air Quality Standards (NAAQS)
Permits (Aggregation, PSD for SO2 and NO2 NAAQS, NEPA)
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Old NSPS
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NSPS Proposed August 23, 2011Comments due October 31, 2011
After proposal, new or modified facilities comply by 2/28/2012
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Source Applicability Proposed Control Devices
Comment
Storage tanks >=1 bbl/d throughput of condensate (≥ 40 API wt.)
>=20 bbls/d throughput of crude oil (<40 API wt.)
Construction commenced after 8/23/2011
Close tank and route vents to a VRU, combustor, or flare that achieves at least 95% emissions control.
Applies to both new and replaced storage tanks
Centrifugal Compressor
Installation commenced after 8/23/2011
Must be equipped with a dry seal
Final rule may allow for wet seal if controlled, but currently not in proposed rule. Includes compressors moved from one site to another
Reciprocating Compressor
Installation commenced after 8/23/2011
Replace rod packing every 26,000 hrs
Includes compressors moved from one site to another
Pneumatic controllers All new or replaced controllers using instrument gas.
Construction commenced after 8/23/2011
Gas plants: instrument gas is prohibited (air is ok)
All other sites: Gas driven controller bleed rate must be < 6 scfh
Natural gas is proposed as a surrogate for VOC
Oil and Gas NSPS Overview
Comments due October 31, 2011; extension request needed
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NAAQS in Transition
1997 Ozone and PM2.5 NAAQS – Largely attained nationwide
2006-Oct. PM10 and PM2.5 NAAQS - Largely attained in the eastern U.S.
2008-Mar. 75 ppb 8-Hour Ozone (Primary & Secondary ) – Now confirmed
2008-Oct Lead NAAQS Final (Primary and Secondary)
2010-Jan. NO2 NAAQS Final (Primary only) – Significant permitting issue
2010-June SO2 NAAQS Final (Primary only) – Attainment by modeling an issue.
2011- Aug. CO NAAQS Final – No proposed changes
2011- Sept. 2 Ozone reconsideration – Terminated by President Obama
2012-March NOx / SOx Secondary – Proposed no combined new form
2012- ? PM10 and PM 2.5 NAAQS (Primary and Secondary)- How much lower?
Source: EPA Information
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U.S. 2008-2010 Ozone Design Values StatusArkansas Counties(ppb)-(Crittenden-74, Polk-70, Pulaski-70, Newton-66, Washington-64)
Design values for monitors in Alaska, Hawaii, and Puerto Rico monitoring sites (not shown) were below 61 ppb
Based on 2008-2010 data retrieved from AQ S D ata M art on January 27, 2011Includes counties w ith incom plete and uncertified data
LegendN um bers of counties are in parentheses
0 - 60 ppb (60)
61 - 75 ppb (538)
76 - 84 ppb (96)
> 84 ppb (16)
In 2010, 102 Counties have Air Quality exceeding the 2008 Ozone NAAQS; NONE in Arkansas
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EPA Ozone NAAQS 2011-’12 Actions
2008 Ozone NAAQS – Applies for PSD and NEPA permitting No non-attainment designations yet ( and none expected for AR) Litigation will resume before year end;
Sept. 2, 2011 – Ozone NAAQS reconsideration ended
Uncertain date - Ozone NAAQS Implementation rules needed
Next steps- Dec. 2012 - 120 day EPA notice of intent to designate Summer 2012 – EPA non-attainment designation using YE2010 Ozone Air
Quality Data
Recommendation: AIPRO review and comment on designation process to assure attainment outcome
9Arkansas monitors attainment in Union (26 ppb) and Pulaski (15ppb)
Counties W ith Monitors Currently Violatingthe Revised Primary 1-Hour Sulfur Dioxide (SO2) Standard of 75ppb
59 of 249 m onitored counties (data in AQ S) vio la te the standard -- Based on 2007-2009 data -- D esignations w ill probably be based on 2009-2011 data
N ot show n on m ap:H aw aii C o., H IS t. C ro ix, V irg in Is lands
22 States (59 counties)with 1-9counties per state monitoring non-attainment
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SO2 NAAQS Status June 2011- State designations (AR attainment/unclassifiable statewide) Sept. 2011-EPA implementation guidance (FR with comment for states
and stakeholders) Rulemaking will follow detailing new implementation approach.
EPA’s new approach will require 100+ TPY (and perhaps smaller) sources to model attainment
Arkansas has ~24 SO2 sources above 100 TPY SO2
Feb. 2012 – EPA intent to designate issues with public comment June 2012 - EPA designation (petition for review possible) June 2013 – Attainment / unclassifiable SIP due (attainment modeling) February 2014 – Non-attainment SIPs due (attainment modeling) June 2017 – Attainment deadline
Recommendation: AIPRO review and comment on Implementation rulemaking
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Counties V io lating Existing PM 2.5 15 ug/m 3 Annual S tandardAnd Hypothetica l Low er S tandards of 13, 12, and 11 ug/m 3
D ata Source: h ttp ://w w w .epa.gov/a irtrends/va lues.htm l
6 counties v io la te 15 ug/m 3
53 additional counties v io la te 13 ug/m 3 (to ta l o f 59)
79 additional counties v io la te 12 ug/m 3 (to ta l o f 138) -- Includ ing Fairbanks N orth S tar, A laska (not show n)109 additiona l counties vio la te 11 ug/m 3 (to ta l of 247)
No Arkansas non-attainment areas; monitor upcoming PM2.5 NAAQS revision
EPA Policy AssessmentRanges
• 11-13 µg / m3
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Counties V io lating Existing PM 2.5 35 ug/m 3 24-Hour S tandardAnd H ypothetica l Lower S tandard of 30 ug/m 3
D ata Source: h ttp ://w w w .epa.gov/a irtrends/va lues.htm l
35 counties v io la te 35 ug/m 3 -- Includ ing Fairbanks N orth S tar, A laska (not show n)
79 additional counties v io la te 30 ug/m 3 (to ta l o f 114) -- Includ ing Juneau, A laska (not show n)
EPA Policy AssessmentRanges
• 30-35 µg / m3
No Arkansas non-attainment areas; monitor upcoming PM2.5 NAAQS revision
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2011 Cross State Air Pollution Rule (CSAPR)
Issued in August; limits EGU emissions to help downwind states attain the 1997 Ozone and 2006 PM 2.5 NAAQS Ozone season NOx limits begin May 2012
Ozone annual NOx limits begin January 2012
SO2 annual limits begin January 2012
Many areas of the eastern U.S. are attaining the NAAQS that the CSAPR targets
Indirect potential impacts: electricity curtailment and price increases beginning in 2012 in some states
Monitor AR utility responses closely
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ConclusionSignificant NAAQS & Oil and Gas sector rule changes underway
New EPA rules and permitting interests best addressed by expanding oil and gas sector associations (state and federal)
Changes underway bear review and comment where appropriate
Air Quality has improved significantly recently
Air Quality improvement trends will continue into the near future