Michael Hopkins Assistant Chief Permitting Ohio EPA 6146443611 Air Permitting for Oil amp Gas Well Sites Discussion Topics Basics of an oil amp gas well site Three phases of development Equipment installed ID: 765707
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Michael HopkinsAssistant Chief, PermittingOhio EPA614-644-3611 Air Permitting for Oil & Gas Well Sites
Discussion Topics Basics of an oil & gas well siteThree phases of developmentEquipment installedExemptionsPermitted sourcesStatus of GP Common Q&A2
Ohio’s Shale Plays 3
Why Now?New method to get oil and gas from rock7,000 to 10,000 feet below ground(Freshwater typically 10-1,500 feet)Could satisfy 14 years of US NG demand Also contains significant oil reserves4
Extracting Gas from ShaleThree PhasesDrillingFracturingProduction 5
Drilling PhaseDrill initial boreInsert well casingsMulti layer concrete and steelDrill rest of well (15-25 days)Turn drill and drill horizontally into shale Source: ConocoPhillips Company 6
Drilling Phase EquipmentPortable drilling rigs w/ diesel engines (3-5,000 HP TTL) Diesel compressor engines (~3,000 HP)“Construction” roadsPortable storage tanksTemporary flare to handle gas safely Lots of trucks 7
Fracturing ProcessIsolate part of horizontal wellPerforate through well casingPump high pressure fracturing fluids into well to fracture rock and insert sand 8
Fracturing ProcessPump out fluidMove to next part of well“Flow back” of fracturing fluids to storage tanks 9
Fracturing Phase EquipmentLarge diesel engines for pumping fracturing fluids (15 engines at 1,125 HP each = 17,000 HP) Temporary storage tanksLots and lots of support equipment Lots of trucks2-3 days per well10
Fracturing Phase Photo Source: Chesapeake Energy Corporation, 2008 Hydraulic Fracturing of a Marcellus Shale Well, West Virginia 11
Production PhaseInstall gas conditioning equipment, liquid storage tanks, control equipmentDesigned to control pressure, flow; remove water, remove organic liquidsEquipment generally stays staticAs gas flow changes with time, equipment may be swapped out 12
Sample Oil & Gas Site 13
Production Phase EquipmentDehydration/conditioning systemNatural gas-fired engines for compressors (up to 1800 HP total in GP)Diesel-fired engines for power generation (up to 250 HP total in GP) NG micro-turbines for power generation (2-200 kW allowed)14
Production Phase EquipmentWater and petroleum liquid storage tanks (up to fifteen 39,000 gallon tanks)Combustor/Flare (no more than 10 MMBtu/hr?) Ancillary equipment (compressors, pumps, piping, etc.) (equipment leaks)Unpaved roadways (up to 3 miles) Lots of trucks removing liquids 15
Pollutants ExpectedCriteria (NOx, PM, CO, VOC, SO2(little))Some HAPS (<10/25)AcetaldehydeFormaldehydeBenzene Ethyl benzeneN-HexaneNaphthaleneTolueneXyleneH2S (not expected in Ohio) 16
General Permit ApproachDrilling and fracturing phases are exemptProduction phase is notGP designed to cover most, but not all, well sitesCovers well site (six wells typical) Intended as a non-synthetic minor17
GP Unique FeaturesAllows installation of various size engines if combined HP limit metAllows swapping of engines w/o new permitAllows installation of various size tanks Restricts total flow to tanksRequires very basic leak detection/repair program18
GP StatusOfficial draft for comment sent outComment period ended Nov. 28Hope to have final done in 3 weeks 19
What will happen after GP is issued?Expect companies to applyExpect to find “issues” with GP (will revise/expand as needed)Expect some companies will not qualify for GP (use as template) 20
Why no permits for drilling and fracturing?Drilling and fracturing are thought of as construction activitiesLargest emitting equipment: portable enginesEngines are exempt from air permits because they are “non road engines” per 31-03/31-01 Roadways are exempt because “construction” roads (still can’t cause nuisance)Drilling engines and fracturing engines required to meet NSPSFeds proposed NSPS 21
Why didn’t we require well sites to get permits before?Well sites were smallerMinimum emissions expectedNew sites are much larger with much larger equipmentRigorous review found rules apply. 22
What should existing sites do?Two options:Wait for GPSubmit case-by-case permitSent sample letter to companies 23
What Rules May Apply?BATMACT Subpart HH, Oil & GasChapter 17NSPS Subpart JJJJ, IIII (SI, CI ICE)MACT Subpart ZZZZ (SI ICE) NSPS Kb, tanksOil and Natural Gas Sector: New Source Performance Standards and National Emission Standards for Hazardous Air Pollutants proposed rule issued August 23, 2011 24
What about ponds?Most not expected to use ponds – portable tanks insteadWater/fracturing fluids expected to be reused or disposedPonds are not covered by GPMust get case-by-case permit if need one 25
What other sources are expected?Intermediate stations: gas cleaning and compression stationsExpansion of existing compressor stationsChemical company facilities: to take gas and/or VOC liquids and process them into other materialsNG powered power stations 26
Wrap upLots of work aheadOhio EPA web site: http://www.epa.ohio.gov/shale.aspx ODNR web site: http://www.ohiodnr.com/oil/shale/tabid/23174/Default.aspx Questions? 27