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Montana DEQ Air Resources Management Bureau Registration Section

Montana DEQ Air Resources Management Bureau Registration Section. Presented By: Mark Ewanic. Montana Petroleum Association Annual Meeting August 27, 2008 Billings, Montana. Outline. Introduction History Office & Staff Registration/Deregistration Submittal Process

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Montana DEQ Air Resources Management Bureau Registration Section

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  1. Montana DEQAir Resources Management BureauRegistration Section Presented By: Mark Ewanic Montana Petroleum Association Annual Meeting August 27, 2008 Billings, Montana

  2. Outline • Introduction • History • Office & Staff • Registration/Deregistration • Submittal Process • New/Updated Registrations • Backlogged Registrations • Deregistrations • Compliance Monitoring • Compliance Determination • Inspection Zones • Field Approach • Providing Compliance Assistance • Registered Facilities • Unregistered Facilities • Common Compliance Issues • Current Status and Path Forward • Contact Information

  3. Introduction

  4. F A M J J A S O N D F A M J J A S O N D F A M J J A S O N D J M J M J M 2006 2007 2008 History 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

  5. Jan 06 – Subchapter 16 F A M J J A S O N D F A M J J A S O N D F A M J J A S O N D J M J M J M 2006 2007 2008 History 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)

  6. F A M J J A S O N D F A M J J A S O N D F A M J J A S O N D J M J M J M 2006 2007 2008 Apr 06 – Subchapter 17 History Jan 06 – Subchapter 16 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

  7. Oct 07 – Registration Section F A M J J A S O N D F A M J J A S O N D F A M J J A S O N D J M J M J M 2006 2007 2008 History Jan 06 – Subchapter 16 October 2007 • Air Quality Registration Section • 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 Apr 06 – Subchapter 17

  8. F A M J J A S O N D F A M J J A S O N D F A M J J A S O N D J M J M J M 2006 2007 2008 June 08 – Field Insp/Verif History Jan 06 – Subchapter 16 Oct 07 – Registration Section 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 Apr 06 – Subchapter 17

  9. F A M J J A S O N D F A M J J A S O N D F A M J J A S O N D J M J M J M 2006 2007 2008 WE ARE HERE History Jan 06 – Subchapter 16 Oct 07 – Registration Section Present Day • Ongoing Work • Inspection reports • Contact companies with unregistered facilities • New registration/deregistration requests • Backlog • Evaluate/improve process • Subchapter 17 rule change June 07 – Initial Facility Inspections Apr 06 – Subchapter 17

  10. 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

  11. 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

  12. Registration&DeregistrationProcesses

  13. Registration Submittal Process • Facility Eligibility • Registration Form • Inventory of emitters • Quantify emissions • Registration & Operation Fees

  14. 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)

  15. 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

  16. 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

  17. Registration Acknowledgement • Completeness Review • Compliance Review Desk Audit • Acknowledgment Letter

  18. Completeness Review • Facility is eligible for registration? • Registration Process and Information is complete? • Registration Fee has been received? • Department requests additional information if necessary

  19. Compliance Review Desk Audit • Completed prior to registration acknowledgement • Does not delay registration • Potential compliance issues identified • Provides compliance assistance

  20. Acknowledgement Letter • Backlog - 25% each calendar year beginning in 2008 • New facilities – Within 30-days of receiving completed Registration Form

  21. 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

  22. Deregistration Acknowledgement • Review similar to compliance review desk audit • Respond to deregistration requests within 30-days of receiving completed request

  23. ComplianceMonitoring

  24. 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

  25. Inspection Zones • Divided counties with oil or gas well facilities • Full-time staff members assigned zones • Complete field inspections – Registered • Complete field verifications – Unregistered

  26. Inspection Zones - Inspectors

  27. Inspection Zones - Facilities

  28. Inspection Zones – Richland County

  29. 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

  30. ProvidingComplianceAssistance

  31. YES YES In Compliance NO NO Registered Facilities 30-Days Field Comp. Insp. Issue Insp. Rpt. No Further Action Comp. Desk Audit Resolution, More Time, etc. Phone Call Followed By Report 60-Days Company Responds Warning or Violation Letter Possible Enforcement

  32. ??? PTE >25-tpy ??? NO NO YES 60-Days Company Responds YES Submit Registration Submit Info. For Not Registering Request Add. Time Unregistered Facilities No Further Action Review DNRC Data Site Verification Phone Call Followed By Letter Review Submittal Possible Enforcement

  33. 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

  34. ThermCAMTM 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)

  35. Current StatusandPath Forward

  36. Registration Activity (8/26/08) Total Registrations Submitted: 727 Total Registered Facilities: 621 Reg. Facilities Acknowledged: 135/67 (Backlog/New) Reg. Updates Acknowledged: 145

  37. Inspection/Verification Activity Facility Inspections: 75 Facility Verifications: 130

  38. 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

  39. 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...

  40. ContactInformation

  41. 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/

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