Date:         Tuesday, February 21st, 6:00 p.m.

Topic:       Air Issues Surrounding Oil and Gas Operations

Speakers:  Hal Winslow and Jacki Malone, Aquonix, Inc

Location:   Wrigley's Sports Bar, 18200 W Colfax Ave, Golden

Cost:        Members $20;   Non members $25;   Students & Unemployed $10

                Add $5 for attending meeting without RSVP

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Abstract and Biography

Oil and gas operators around the country are facing a multitude of changes associated with air emissions from their facilities. Operators should be aware of the various air regulations as they plan drilling operations, and must determine whether (and when) they are required to register or apply for a permit with Federal, Tribal, state or local agencies. In particular, three recent regulations come to mind for the discussion of air issues surrounding oil and gas operations.

Under 40 CFR Parts 49 and 51, the EPA promulgated (on August 30, 2011) a Federal Implementation Plan (FIP) under the Clean Air Act for Indian Country. This regulation affects all tribal lands throughout the Unites States and carries with it some serious pre-planning tactic for all operators. The FIP details the New Source Review (NSR) regulations for the protection of air resources in Indian Country and applies to new and modified minor stationary sources and to minor modifications at existing major sources throughout Indian Country in both attainment and nonattainment areas. Among the requirements for existing operations, one of the more challenging aspects of this rule require operators to obtain a pre-construction permit prior to commencing construction.

The EPA has issued the Mandatory Reporting of Greenhouse Gases Rule, referred to as 40 CFR Part 98, that affects most industries in regards to reporting greenhouse gases resulting from operations. In particular to the oil and gas industry, Subpart A and W of the Rule provide requirements and implementation for the calculation and reporting of CO2, CH4 and N2O. The final rule amendments to Subpart A and Subpart W were published on December 23, 2011, and while the amendments did not change the overall requirements of the Rule, they improved clarity and consistency across the calculation, monitoring and data reporting requirements. Aquionix will be speaking to a broad review of the various paragraphs within Subpart A and W, as well as any of the significant changes that were finalized in December 2011.

The New Source Performance Standards (NSPS) and National Emission Standards for Hazardous Air Pollutants for the oil and natural gas sector, while not yet final, carry some significant implications for the industry. Generally, the NSPS Rule requires sources to perform initial performance testing and to demonstrate continuous compliance during operations. Of note in the proposed Rule for the oil and gas sector is the stated requirement to have a flare on emissions from crude oil storage tanks would introduce a federally enforceable mechanism for requiring such devices for oil and gas operations. This required element will broadly affect oil and gas operations, and while it will minimize the need for pre-construction permits (see #1 above), it does not incorporate any required elements for flaring of wellhead gas which is ultimately the largest source of emissions from a facility. The Rule’s intended promulgation date is April 3, 2012 pending EPA’s response to comments.

Mr. Winslow has over 20 years of experience providing integrated environmental, safety and health services and products for large and small regulated clients in manufacturing, brewing, mining, oil and gas, utilities and services sectors. He has been an integral part in the development and implementation of client data systems to support compliance and risk management programs. More specifically, Hal’s experience includes in providing support and guidance for regulated operators in the interpretation and implementation of hazardous materials programs, design and execution of training programs for hazardous waste generators, emergency response plan development, and implementation of the Aquionix software management program.

Ms. Malone achieved a Bachelor of Science degree from Colorado State University in 2001 where she majored in environmental engineering. Her experience includes site-specific remedial technology evaluation, selection and design, remedial system O&M, project and environmental management for multi-facility oil and gas operations, and evaluation of compliance with regulatory requirements. Most recently, she has been involved in the air permitting and compliance aspect of the oil and gas industry, including the recently promulgated New Source Review for Indian Country regulations and the Greenhouse Gas Reporting Rule.