AIR QUALITY REGULATION OF OIL AND GAS DEVELOPMENT

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COURSE
AIR QUALITY REGULATION OF
OIL AND GAS DEVELOPMENT:
OVERVIEW AND UPDATES
November 10-11, 2016
Hyatt Place Dallas/North Galleria
Dallas, TX
EUCI is authorized by
IACET to offer 1.5 CEUs
for the course.
AIR QUALITY REGULATION OF OIL AND GAS DEVELOPMENT: OVERVIEW AND UPDATES
November 10-11, 2016 | Dallas, TX
OVERVIEW
On May 12, 2016, the EPA Administrator signed nearly 1000 pages of new federal rules affecting the industry, and the EPA is
amending federal New Source Performance Standards (NSPS) to include standards for reducing methane as well as VOCs (volatile
organic compounds) emissions across the oil and natural gas source category. Moreover, EPA has also announced plans to
regulate not only the thousands of newly affected facilities, but additional regulations are also under development for the millions
of existing facilities.
These new rules and regulations are leaving many utility professionals asking; What are these new requirements? Who must
comply with which rules? How can you make the necessary technical and regulatory determinations? When do the various
deadlines come due? This 2-day course will describe these new and emerging rules, will help you to understand and prepare
for these complex regulations and discuss the various software packages for estimating emissions from storage tanks, glycol
dehydrators, and other such emissions sources. Attendees will also be provided with an opportunity to learn about some of the
compliance issues they are likely to encounter during implementation.
LEARNING OUTCOMES
• Define Subpart OOOO, including the 2011 proposal and 2012 “final” rule
• Discuss how this applies to all hydraulically fractured gas wells, both new wells and existing wells that are fractured or refractured
• Review the facilities affected by Subpart OOOO
• Define key terms as they relate to 2012 NESHAP [Part 63]
• Discuss 2013, 2014 and 2015 amendments
• Review the alternative emission limits
• List the facilities affected by HH & HHH NESHAPs
• Describe key implementation issues with NESHAPs and subsequent amendments
• Discuss key implementation issues with NSPS and subsequent amendments
• Describe the definitions and applicability of Subpart W pertaining to oil and gas sites
• Define and discuss Subpart UU
• Examine the pros and cons of Screen 3 vs. other models for air dispersion modeling
• Discuss the effects and impacts of EPA Air Quality Regulations on oil and gas production enhancement techniques
WHO SHOULD ATTEND
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Oil & natural gas industry professionals, engineers & consultants
Energy industry attorneys, legal staff, compliance officers & project managers
Oil & natural gas field services managers and site directors
Oil & gas production enhancement services professionals & personnel
Oil & gas automation professionals & engineers
Procurement professionals, coordinators & personnel
Drilling engineers & drilling site managers
Environmental engineers, mechanical engineers, petroleum engineers
Environmental, Health, & Safety (EHS) advisors & EHS field coordinators
Natural gas processing plant professionals & personnel
Pipeline engineers and distribution system professionals & personnel
Petroleum & natural gas exploration & production professionals & personnel
Petroleum & natural gas midstream operations professionals & personnel
Leak Detection & Repair (LDAR) Personnel
Facility owners, engineers and management personnel who need a basic understanding of applicable air quality regulations pertaining to oil & gas ops
• CEOs, CFOs, finance professionals, who desire more information on air regulatory issues that can affect oil & gas capital and operating costs
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AIR QUALITY REGULATION OF OIL AND GAS DEVELOPMENT: OVERVIEW AND UPDATES
November 10-11, 2016 | Dallas, TX
AGENDA
THURSDAY, NOVEMBER 10, 2016
8:00 – 8:30 am
Registration and Continental Breakfast
8:30 am – 5:00 pm
Course Timing
12:00 – 1:00 pm
Group Luncheon
Introduction and Overview
• Industry Overview
• Typical Emissions Sources from Oil & Natural Gas Facilities
History of Oil & Gas Rulemaking
• New Source Performance Standards (NSPS)
o Regulate criteria pollutants and precursors from new, modified and reconstructed sources
o NSPS must reflect “best system of emission reductions”
o Section 111(b) of Clean Air Act (CAA)
• National Emission Standards for Hazardous Air Pollutants (NESHAPs)
o Technology-based standards
o HAP pollutants of primary concern to oil and natural gas sector
o Section 112 of the CAA; Requires risk and technology review (RTR)
• Subpart OOOO
o 2011 Proposal
o 2012 “Final” Rule
- Section 111(b) of Clean Air Act (CAA)
o Applicability to well sites, gathering/boosting facilities, compressors, storage vessels, natural gas processing plants, pneumatic controllers, storage, etc.
o Rule timeline, primary impacts of the rule; storage vessels: EPA “significantly underestimated” the number of affected storage tanks. Group 1 vs. Group 2
2012 NESHAPs [Part 63]
• Oil and Natural Gas Production (Subpart HH)
o Glycol dehydrators – LDAR, Storage Vessels, and discuss available and acceptable software for
calculating emissions
• Natural Gas Transmission & Storage (Subpart HHH)
o Glycol dehydrators, new standards for small dehydrators
• Revisions Rollout (NSPS & NESHAP separately)
o (NSPS-1 Storage vessel implementation revisions, NSPS-1.5 time-critical clarification of well
completion requirements, NSPS-2 remaining issues, NESHAP)
• 2013 NESHAP Amendments
• Alternative Emission Limits
• 2014 Amendments
o New effective date
o Production phase
o Storage vessels
o Vapor recovery
o Thief hatch
o Rod packing
o Equipment leaks
o Responsible official
o Affirmative defense
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AIR QUALITY REGULATION OF OIL AND GAS DEVELOPMENT: OVERVIEW AND UPDATES
November 10-11, 2016 | Dallas, TX
AGENDA
FRIDAY, NOVEMBER 11, 2016
8:00 – 8:30 am
Registration and Continental Breakfast
8:30 am – 5:00 pm
Course Timing
12:00 – 1:00 pm
Group Luncheon
2015 Amendments
Subpart OOOOa (Methane Rules)
• 2013 – Climate Action Plan
o Completions and ongoing production
o Leaks, liquids unloading, pneumatic devices
• Aug 18, 2015 – Rule Proposal
o Proposed rule
o Comments & changes
o Draft Control Techniques Guideline (CTG)
o Proposed Aggregation Rule (proximity vs. interrelatedness)
• May 12, 2016 (Signed) – Final Rule
o Final Rule (Pub. FedReg June 3, 2016)
o ICR for existing sources
o Finalize Aggregation Rule
o Final FIP for Indian Country minor sources
o Final CTG - expected 2016
Comparison to 2012 VOC Rule
• Emissions Points:
o Well completions and recompletions
o Fugitive emissions
o Pneumatic pumps
o Pneumatic controllers
o Reciprocating compressors
o Centrifugal compressors
• Inclusion of Oil Wells Completed Using Hydraulic Fracturing
o Definition & field keys for distinguishing gas well vs. oil well
o 2012 Rule requires RECs for “predominantly” gas wells
o Exclusions based on GOR – gas to oil ratio & technical infeasibility
o REC + Combustion device
o Exploratory & low pressure wells, etc.
• Expanded LDAR
o Role of OGI technology
o Conventional Method 21 Techniques
• Summary of Other Changes
o Additional restrictions on compressors, controllers and pumps
o Expanded coverage to limit emissions from equipment used at natural gas compressor stations and gas storage facilities (i.e., compressors & pneumatic controllers not covered in 2012
VOC rule.)
o Some sources subject to 2012 NSPS rule and also covered by 2016 rule
o Provisions for re-completion wells to avoid NSPS modification
o RECs + combustion
o Post – 2015 notification, recordkeeping, and reporting, etc.
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AIR QUALITY REGULATION OF OIL AND GAS DEVELOPMENT: OVERVIEW AND UPDATES
November 10-11, 2016 | Dallas, TX
AGENDA
FRIDAY, NOVEMBER 11, 2016 (CONTINUED)
Subpart W
• Greenhouse Gas
o Utilizing EPA’s calculation tool for onshore petroleum and natural gas production
• Definitions & applicability to oil and gas sites and to the GHG reporting tool
• Acid gas removal units (40 CFR 98.233(d))
• Conversions to CO2e, associated gas venting and flaring (40 CFR 98.233(m)), sold, vented, flared gas
• Natural gas characteristics compared to associated gas
• Wellhead gas-liquid separators
• Well venting for liquids unloading (40 CFR 98.233(f ))
• EPA Guidance - GHG emissions from liquids unloading
• Calculating annual natural gas emissions from well venting for liquids unloading with and
without plunger lifts
• Flaring and venting; calculating volume of gas flared and venting for emergency purposes, etc.
Subpart UU
• Injection of CO2 underground for enhanced oil and gas recovery
• Underground Injection Control (UIC) Class II wells, facilities that inject CO2 underground for
enhanced oil and gas recovery (ER), acid gas injection, carbon storage research and development (R&D), or for any other purpose other than geologic sequestration
• Utilizing screen 3 vs. other models for air dispersion modeling
Review & Questions
INSTRUCTOR
Martin E. Rock P.E., J.D., LEED-AP
President and Senior Principal/OMNI Professional Environmental
Mr. Rock is a registered professional engineer with three engineering degrees, including an M.S. in environmental engineering. He
is also a licensed attorney. Earlier in his career, his prior positions include serving as Vice President & General Counsel with Palmetto Engineering Corporation in Columbia, South Carolina, and serving as Staff Counsel at South Carolina Department of Health
& Environmental Control (SC-DEHC). Martin is admitted to the bar in the state of Georgia, and he is registered as a professional
engineer in five states. He is a recipient of the American Jurisprudence Award for Law and The Environment and was selected as an
“Outstanding Essayist” by the Association of Trial Lawyers of America (ATLA).
He is active in the AIChE (American Institute of Chemical Engineers) and he served as President and Board Chairman of the ISPE
(which is the leading, global not-for-profit society serving the pharmaceutical/biotech sector) Carolina-South Atlantic Chapter
[covering a 6-state service region] during 2006-2007 and earned the highest recognition, Platinum Grand Award for Innovation &
Leadership, during his year as Chairman. He also serves on the Energy, Environmental, Health & Safety (EEHS) Steering Committee of the North Carolina Manufacturing Alliance (NCMA, formerly MCIC). He is also active in Toastmasters International and has
earned the Advanced Communicator Gold (ACG) certification.
Martin is an experienced instructor having conducted professional seminars, webinars, classroom training, mock trials and panel
discussions for major universities and corporate clients; in-house training for Fortune 50 corporations, State & Federal regulatory
agencies (including US DOE, and US EPA), and other professional organizations. Mr. Rock is a graduate of the University of Michigan, College of Engineering, and of the Lumpkin School of Law at the University of Georgia-Athens (UGA). While at UGA, he served
on the editorial board of the Georgia Journal of International & Comparative Law. He also developed a comprehensive environmental compliance manual for the Savannah River Site (SRS) as a consultant for the U.S. Department of Energy and he wrote
Model Legislation for the State of South Carolina Legislature & the South Carolina Governor’s Task Force.
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AIR QUALITY REGULATION OF OIL AND GAS DEVELOPMENT: OVERVIEW AND UPDATES
November 10-11, 2016 | Dallas, TX
INSTRUCTIONAL METHODS
This program will PowerPoint Presentations, group discussions, as well as active participation.
REQUIREMENTS FOR SUCCESSFUL COMPLETION
Participants must sign in/out each day and be in attendance for the entirety of the course to be eligible for continuing education
credit.
IACET CREDITS
EUCI has been accredited as an Authorized Provider by the International Association for Continuing Education
and Training (IACET). In obtaining this accreditation, EUCI has demonstrated that it complies with the AN-SI/
IACET Standard which is recognized internationally as a standard of good practice. As a result of their Au-thorized
Provider status, EUCI is authorized to offer IACET CEUs for its progr ams that qualify under the AN-SI/IACET
Standard.
EUCI is authorized by IACET to offer 1.5 CEUs for the course.
PROCEEDINGS
The proceedings of the course will be published, and one copy will be distributed to each registrant at the course.
EVENT LOCATION
A room block has been reserved at the Hyatt Place Dallas/North Galleria, 5229 Spring Valley Road, Dallas, TX 75154, for the nights
of November 9-10, 2016 . Room rates are $135, plus applicable tax. Call 1-972-716-2001 for reservations and mention the EUCI
event to get the group rate. The cutoff date to receive the group rate is October 12, 2016 but as there are a limited number of
rooms available at this rate, the room block may close sooner. Please make your reservations early.
REGISTER 3, SEND THE 4TH FREE
Any organization wishing to send multiple attendees to these courses may send 1 FREE for every 3 delegates registered. Please
note that all registrations must be made at the s ame time to qualify.
PAGE 6
Please make checks payable to: “PMA"
EVENT LOCATION
A room block has been reserved at the Hyatt Place Dallas/
North Galleria, 5229 Spring Valley Road, Dallas, TX 75154,
for the nights of November 9-10, 2016 . Room rates
are $135, plus applicable tax. Call 1-972-716-2001 for
reservations and mention the EUCI event to get the group
rate. The cutoff date to receive the group rate is October
12, 2016 but as there are a limited number of rooms
available at this rate, the room block may close sooner.
Please make your reservations early.
PLEASE SELECT
AIR QUALITY REGULATION OF OIL AND GAS
DEVELOPMENT: OVERVIEW AND UPDATES
November 10-11, 2016 : US $1495
Early bird on or before October 21, 2016: US $1295
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Your registration may be transferred to a member of your organization up to 24 hours in advance of the event. Cancellations must be received on or before October
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