Upload
buikhue
View
219
Download
0
Embed Size (px)
Citation preview
About Devon
• Founded as a private company in 1971
• Became a public company in 1988
• Has grown from 185 employees in 1981 to 5,000 employees today
• Active driller in Oklahoma
NYSE: DVN www.devonenergy.com page 2
Agenda
• NSPS OOOO Refresher – Affected Facilities
• Storage Vessels
• Oklahoma Permit By Rules (PBR)
• Questions
NYSE: DVN www.devonenergy.com page 3
What is NSPS OOOO?
• NSPS – New Source Performance Standard
• Applies to sources constructed after a certain date – 8/23/2011
• Technology over time – Cheaper – Increased availability
NYSE: DVN www.devonenergy.com page 4
NSPS OOOO
• Hydraulically Fractured Natural Gas Wells – Minimize emissions
• Reciprocating Compressors – Change rod packing
• Centrifugal Compressors – Control of wet seal emissions
• Pneumatic Controllers – No continuous high bleed
The heavy hitters…
NYSE: DVN www.devonenergy.com page 5
NSPS OOOO
• Affected Facility
“has the potential for VOC emissions equal to or greater than 6 tpy” Group 1: 8/23/11 - 4/15/13 Group 2: 4/15/13 – Forever
*Note: Determination for G1 tanks must be made by 10/15/13
• Compliance
“Reduce VOC emissions by 95.0 percent”
Group 1: 4/15/15 Group 2: 4/15/14
Storage Vessels - What Everyone Knows
NYSE: DVN www.devonenergy.com page 7
NSPS OOOO
• Cover inspections – monthly audio, visual and olfactory inspection
• Control piping inspection – monthly audio, visual and olfactory inspection
• Flare/combustor inspection – Confirm pilot is lit – 15 minute smoke observation – Audio, visual and olfactory inspection – Check air vent for obstruction – Check for liquid reaching the combustor
Storage Vessels – The Fine Print Monthly Inspection Requirements
NYSE: DVN www.devonenergy.com page 8
NSPS OOOO
• Tank ID with lat/long location
• Determination of VOC rate
• Deviations
• Combustor manufacturer tests
• Unsafe to inspect or difficult to inspect maintenance plans
• For mobile tanks, records or dates onsite
• Closed vent system and cover inspections
• Control bypass inspections
• Records of inspections, corrective actions taken, manufacturers operating instructions, procedures and maintenance schedules
• Records of smoke reading – Company, location, company rep, process unit, start time, observation period, accumulated
emissions time, end time
Storage Vessels – The Fine Print Recordkeeping & Reporting Requirements
NYSE: DVN www.devonenergy.com page 9
EHS Engineering Guidance
• Avoid becoming subject to the fine print! – Process changes – Reduce production – Permit out – Etc.
• Run • Run • Run
NYSE: DVN www.devonenergy.com page 10
Permit By Rule
• Developed in response to NSPS OOOO
• ≤40 tpy VOC PTE
• ≤10 tpy single HAP PTE
• ≤25 tpy combination HAP PTE
• New & Existing Facilities
…Nothing special
NYSE: DVN www.devonenergy.com page 11
Permit By Rule
• ODEQ Form 100-223 • Page 2 • Second Section
But Wait!
NYSE: DVN www.devonenergy.com page 12
Permit By Rule
• Emissions are less than 6 tpy
• “Compliance” with NSPS OOOO … without being subject to the fine print!
What Does “Enforceability” Mean?
NYSE: DVN www.devonenergy.com page 13
Permit By Rule
• Everyone gets what they want – EPA gets “compliance”
– Oklahoma gets to support local business
– Industry continues to operate
– Emissions are lowered
NYSE: DVN www.devonenergy.com page 14
Summary
• NSPS OOOO Refresher – Multiple affected sources – Storage vessels may be heaviest hitter
• Storage Vessels – Groups 1 & 2 – Avoid becoming subject to the rule!
• Oklahoma PBR – 40 tpy limit – Enforceability
NYSE: DVN www.devonenergy.com page 16