The oil and gas sector has seen massive regulatory change since 2016, particularly with respect to air compliance requirements.  Regulations have issued, withdrawn, and modified by multiple regulatory agencies.  In addition, challenges to some of these regulations have been made in the courts.  The end result is a confusing mix of regulations, policies and expectations.

This workshop will provide some clarity and direction about what the oil and gas sector should be doing now.  While not providing formal legal guidance, the workshop will address the compliance challenges confronting upstream and midstream oil and gas companies in meeting EPA and BLM regulations, as well as some evolving issues at the State level.  We will particularly focus on EPA’s New Source Performance Standard (NSPS) OOOOa requirements around the implementation of a volatile organic compound (VOC) and methane leak detection and repair (LDAR) monitoring and reporting program as well as associated with the final Bureau of Land Management (BLM) venting and flaring rule (e.g., Waste Prevention) requirements.  We will also provide some insights and approaches to recordkeeping and reporting approaches under these programs.

Instructors

Johnny Vermillion and Leah Pullin, Spirit Environmental

The primary focus of this course is to gain a better understanding of the complexities of Major New Source Review. It was designed to provide an open forum for those who already have considerable air permitting experience. We encourage the audience to interact with the trainers and other attendees and to share experiences on some of the nuances of air permitting policy, regulations, and guidance.  Included scenarios will provide a framework to explore and discuss some of the “grey areas” that can make air permitting challenging.

Topics Covered

Recent Federal NSR Policy Shifts
Federal NSR Applicability Determinations
Demand Growth Exclusion (What Could Have Been Accommodated)
Permit Application Requirements and Procedures
Dispersion Modeling for the Permit Manager
Other PSD Requirements (Visibility, etc.)
Plant-wide Applicability Limit Permits
Nonattainment NSR
Minor Source Permitting

In order to comply with the Petroleum Refinery NESHAPS Fenceline monitoring provisions (40 CFR 63.658), many refineries have implemented ambient air monitoring networks around their site fencelines. If the annual monitored benzene concentration exceeds the action level specified in the rule, then the rule requires the site conduct a root cause analysis and develop and implement a corrective action plan to bring the benzene concentrations below the action level.

The rule explains WHAT to do, but HOW do you conduct the analysis, develop a plan, and test the plan to make sure it is going to satisfy the requirements of the rule?

In this two-hour training course, we will take you, step-by-step, through a proven systematic and reproducible process of identifying which emission sources are causing unacceptable concentrations and whether the corrective actions proposed will be effective.

The course covers current EPCRA applicability and reporting requirements, including multiple chemical lists, applicability thresholds, required reporting, deadlines, available reporting tools, and mandatory documentation. Practical applications of the requirements are provided for various industry sectors and for Federal agencies. Illustrative scenarios are presented on industrial and Federal agency reporting under EPCRA Section 313 to provide a clear understanding of where to focus attention and how to apply the complex guidance of the Toxic Release Inventory (TRI) requirements to actual facility operations.

In this 4-hour, to-the-point workshop, you will be presented with all the information needed to complete nearly every dispersion modeling analysis you will ever perform in your career. We will list which model programs are needed, what data is required for those programs, where to find those data, and how to manipulate the data to construct your input files to get the model running so you can get your job done. We will also cover tips and techniques to help you streamline your workflow.

No matter which software interface you use, or don’t use at all, this course will provide you a thorough understanding of what information goes into the model, what happens internally to the information, and what the results mean.

Heater and boiler tuning is not a new practice, but with the advent of 40 CFR 63 Subpart DDDDD, or the Industrial, Commercial, and Institutional (ICI) Heater and Boiler MACT Rule, it is required for all affected major source facilities. Despite the initial belief that MACT DDDDD is just another costly EPA regulation, implementation of the work practice standard has provided a wealth of information substantiating that regular heater and boiler tune-ups can save significant costs through improvements in fuel efficiency, energy reduction credits, and safety. More notably, there is a simple payback on the tune-up services within months. Heater and boiler tuning has been described as part science and part intimate knowledge of the equipment’s operational characteristics and process needs. And while many facilities believe their heaters and boilers to be well optimized, compliance tuning efforts have revealed that this is not always the case. Course instructors have a combined, 60-plus years of tuning and environmental regulatory experience which they will share with attendees to better educate industry on the importance of combustion optimization and to help align the efforts of operations/process and environmental departments on practices that benefit both.

In this course, attendees will:

Review the subpart DDDDD Heater and Boiler MACT Regulation;
Cover the technical aspects of combustion tuning;
Review key aspects of combustion engineering and burner performance;
Address the regulatory compliance requirements for tune ups;
Look at MACT DDDDD case studies for which regularly occurring tune ups have been performed;
Discuss the benefits of heater and boiler tuning including cost savings, energy reduction credits, safety, and alignment with organizational values;
Summarize a host of other thermal energy systems that are also beneficial to assess for energy efficiency improvements.

Instructors: Johnny Vermillion, PE, Shagun Bhat, PhD, and Robert Osborn – Spirit Environmental

This course is designed to provide additional information to those who already know the basics.  Trainers will dive deeper into topics related to air permitting, Major NSR applicability, and air dispersion modeling along with sharing their own experiences over the years.  They will also discuss air permitting policy and approaches to help you gain a better understanding of the air permitting world.