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The Private Sector: How we are currently involved with the States and Tribes

The Private Sector: How we are currently involved with the States and Tribes. Joshua B. Epel, Esq. Duke Energy Field Services, LP August 25, 2005. Legend. DEFS Plants. #. DEFS Gathering Area. DEFS Midstream Operations. DEFS Profile. DEFS operates in 3 WRAP states and 4 non-WRAP states.

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The Private Sector: How we are currently involved with the States and Tribes

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  1. The Private Sector: How we are currently involved with the States and Tribes Joshua B. Epel, Esq. Duke Energy Field Services, LP August 25, 2005

  2. Legend DEFS Plants # DEFS Gathering Area DEFS Midstream Operations

  3. DEFS Profile • DEFS operates in 3 WRAP states and 4 non-WRAP states. • DEFS fleet deploys 2.1MM horsepower at 850 facilities (2,500 engines). • DEFS utilizes 41 amine units in 6 states to remove impurities, including CO2. • DEFS manages about 58,000 miles of pipelines, all containing methane.

  4. DEFS interacts with Multiple State Agencies • 8 separate state agencies on air permitting issues (and compliance with EPA regulations) • 11 Agencies on emergency venting and flaring (OCD, TRRC, etc.) • 6 Departments and the OPS on pipeline compliance

  5. DEFS must address compliance obligations consistently • Title V Permitting • Since 2001, DEFS has reduced the number of Title V facilities from 330 to 150—primarily through installation of catalytic converters on hundreds of engines. • DEFS has controlled or is managing “flash” emissions at all of its facilities. • DEFS is working with all state agencies to ensure the accuracy of its LDAR program.

  6. Compliance obligations, cont’d • Meeting these obligations requires training hundreds of employees in programs and processes. • Meeting compliance obligations requires the evaluation and re-engineering at hundreds of facilities.

  7. Innovative Approaches-CO2 Sequestration • DEFS installed an acid gas injection well at its Artesia facility - with mixed results. • DEFS is permitting another acid gas injection well - requiring interaction with multiple state agencies.

  8. A Cooperative Model • A State, Regional, or Federal program should promote innovation—either through direct incentives or removing regulatory barriers. • Identify CO2 injection formations and develop a CO2 reduction permit where facilities can use the formation when siting facilities. • State financial incentives to promote geological sequestration opportunities.

  9. Conclusion

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