Overview of Key Water Issues Affecting the Oil and Gas Industry - PowerPoint PPT Presentation

Loading...

PPT – Overview of Key Water Issues Affecting the Oil and Gas Industry PowerPoint presentation | free to download - id: 450c2a-ZGNlY



Loading


The Adobe Flash plugin is needed to view this content

Get the plugin now

View by Category
About This Presentation
Title:

Overview of Key Water Issues Affecting the Oil and Gas Industry

Description:

Overview of Key Water Issues Affecting the Oil and Gas Industry John Veil Argonne National Laboratory NPTO Seminar September 11, 2002 Three Hot Issues Phase II ... – PowerPoint PPT presentation

Number of Views:275
Avg rating:3.0/5.0
Slides: 37
Provided by: Veil8
Learn more at: http://www.netl.doe.gov
Category:

less

Write a Comment
User Comments (0)
Transcript and Presenter's Notes

Title: Overview of Key Water Issues Affecting the Oil and Gas Industry


1
Overview of Key Water Issues Affecting the Oil
and Gas Industry
  • John Veil
  • Argonne National Laboratory
  • NPTO Seminar
  • September 11, 2002

2
Three Hot Issues
  • Phase II Stormwater
  • SPCC
  • Section 316(b)

3
Stormwater Runoff - Background
  • Stormwater runoff must be covered under an NPDES
    permit (usually general permit)
  • Phase I runoff from industrial sites and from
    construction sites disturbing gt5 acres
  • Phase II - Runoff from construction sites
    disturbing from 1-5 acres
  • CWA exempts oil and gas exploration and
    production sites from stormwater permits
  • EPA interprets construction of lease roads, drill
    pads, and other disturbed areas to be outside of
    the scope of the exemption

4
Jurisdiction
  • EPA delegated NPDES authority to most states
  • States issue general permits
  • Where states do not take over program, EPA
    regions issue permits
  • Region 6 presents particular problem for industry
  • NM does not have primacy
  • OK and TX have primacy for all categories except
    for oil and gas
  • Region 6 writes oil and gas stormwater NPDES
    permits for these 3 heavy producing states

5
Region 6 Issued a Phase I Permit in July 1998
  • Permit technical requirements
  • must provide an ESA consultation
  • must provide information on whether the
    activities would affect any property on the
    National Register of Historical Places
  • where effects occur, must provide written
    agreement with State or Tribal Historic
    Preservation Officer
  • must conduct inspections at least every 14 days
    and within 24 hours of any rainfall gt 0.5

6
Phase I Permit Requirements (2)
  • must develop a stormwater pollution prevention
    plan (SWPPP)
  • describe BMPs (does not specify which BMPs must
    be used but must use one or more as necessary)
  • employ structural practices to divert flows,
    store flows, and/or control runoff
  • provide the timing and sequence of different BMPs
  • install and maintain any control measures in
    accordance with manufacturer's specifications
  • sediment traps and ponds must be cleaned out
    before accumulating more than 50 of their
    capacity

7
What Is the Concern?
  • EPA will issue first Phase II permit in Jan.
    2003 and begin implementation in March 2003
  • EPA has not discussed permit conditions, but will
    probably have some or all of the conditions in
    the Phase I permit
  • Suddenly, most new EP operations will need to
    get a Phase II permit before starting
  • The huge increase in number of permits, ESA
    certifications, and historic preservation reviews
    is likely to cause
  • delays in starting to drill (drill rig scheduling
    problems)
  • costs for additional studies and paperwork
  • Some wells wont get drilled

8
Next Steps
  • Participate in meetings, discussions, and
    conference calls
  • Comment on a related regulatory proposal
  • Effluent guidelines for construction industry
  • Review and comment on draft permit, when
    available
  • Work with EPA and OMB to make permit conditions
    more flexible and reasonable

9
SPCC Background
  • SPCC spill prevention, control, and
    countermeasure
  • Existing SPCC regulations have been in place
    since 1973
  • EPA has proposed a series of amendments over the
    ensuing years
  • These were captured in final regulations passed
    July 17, 2002
  • New rules are more comprehensive
  • Many provisions that previously were
    discretionary are now mandatory

10
Applicability
  • Expands coverage to include users of oil
  • Facility definition is broadened
  • Can include individual pieces of equipment
  • Threshold increased to 1,320 gals of oil in
    aboveground tanks
  • Exemptions
  • Completely buried tanks
  • Containers of 55 gals or less
  • Tanks used for wastewater treatment (does not
    include produced water treatment)

11
SPCC Plans
  • Must be certified by Professional
    Engineer
  • Must be reviewed following material change to
    facility or every 5 years
  • Plan must be kept on site if facility is manned
    gt4 hours/day
  • Revision required following
  • Single spill gt1,000 gals
  • Two spills each gt42 gals within 12 month period

12
Content of SPCC Plans
  • More requirements for drawings, emergency
    procedures, etc.
  • Option for plan to be written in non-standard
    format
  • Periodic integrity testing of tanks and leak
    testing of pipes and valves
  • Annual training for oil-handling employees

13
SPCC Plan Compliance Dates
  • Any facility in operation before August 17, 2002
    and having experienced a reportable release must
    prepare a plan in accordance with the new rule
    within six months and implement the plan within
    one year
  • A facility going into operation between August 16
    2002 and August 18, 2003 must implement the plan
    by August 18, 2003
  • Existing facilities required to have a current
    SPCC plan and that have not experienced a
    reportable release must revise the current plan
    within six months of the new five-year expiration
    period of the existing plan

14
Requirements for All Facilities Covered by Rule
  • Discharge control equipment (e.g., dikes, curbs,
    berms, sumps, weirs, etc.) is required for all
    equipment and facilities
  • Could include tank batteries, separators, pipes,
    flow lines, etc.
  • Any bulk storage containers virtually any tank or
    device used to store oil) must provide secondary
    containment
  • Containment must hold volume of largest container
    plus stormwater
  • Secondary containment can only be waived if
    technically impractical
  • High cost is not an excuse
  • Any field constructed aboveground tank undergoing
    repair must be tested before it is placed back
    into service

15
Other Requirements for Specific Facilities
  • New buried piping must have protective wrapping
    and coating
  • Drilling facilities must install blowout
    prevention before drilling below casing strings
    or during workovers
  • Additional inspections

16
Next Steps
  • The rule was only published last month so little
    has been done yet
  • This is a final rule so there is no opportunity
    to review and revisit it
  • Make sure all stakeholders are aware of new
    requirements

17
316(b) - Background
  • 316(b) of the CWA requires location, design,
    construction, and capacity of cooling water
    intakes to reflect best technology available to
    minimize adverse environmental impact
  • Primarily affects power plants and manufacturing
    facilities that use a lot of cooling water
  • Also affects refineries and offshore drilling
    operations
  • In mid-1990s, EPA was sued by environmental
    groups and agreed to develop new rules

18
EPAs Regulatory Schedule
Category Proposal Date Final Rule Date
Phase I - New facilities 8/10/00 - done 12/18/01- done
Phase II - Existing utility and non-utility power producers 4/9/02 - done 8/28/03
Phase III - Other existing facilities 6/15/03 12/15/04
19
Commonly Considered Impacts from Cooling Water
Intakes
  • Impingement
  • Organisms are trapped on intake
  • Entrainment
  • Organisms pass through intake

Note Some but not necessarily all impinged and
entrained organisms are killed.
20
Basic Principles of Phase I Proposal
  • Two-track process
  • Track I requires closed-cycle cooling for most
    facilities
  • Track II allows companies to demonstrate that
    other measures short of closed-cycle cooling are
    acceptable
  • EPA is currently being sued by both industry and
    environmental groups

21
Basic Principles of Phase II Proposal
  • Different sets of requirements for water bodies
    with different presumed sensitivity
  • Technology based standards for impingement
    mortality and/or entrainment
  • reductions compared to a baseline of
  • Shoreline intake
  • No fish protection technology
  • May use mitigation methods as part of reduction
    package
  • Several alternative ways of complying
  • Cost-to-cost variance
  • Cost-to-benefit variance
  • Install closed-cycle cooling

22
Overview of Phase II Requirements
  • All facilities must reduce impingement mortality
    by 80-95 and some must reduce entrainment by
    60-90
  • Requirements based on water body type

23
Mitigation
  • Operator must demonstrate that suite of
    mitigation measures will maintain fish and
    shellfish to a level comparable to that resulting
    from the use of CWIS technologies
  • Mitigation can be part of a compliance program or
    the entire program

24
What Are the Concerns?
  • What will the flow threshold be for Phase III?
  • 2 MGD was threshold for Phase I
  • How many offshore facilities will be included?
  • What types of controls may be placed on them?
  • Mobile offshore drilling facilities have
    different construction and design issues than
    fixed onshore facilities

25
Next Steps
  • Work with EPA and industry to accurately
    characterize offshore drilling facilities
  • Cooling water intake volume
  • Number of facilities
  • Opportunities for cost-effective retrofits
  • Review EPA work regarding refineries and offer
    comments as necessary

26
Other Water Regulatory Issues
  • Discharge Issues
  • Water quality standards
  • Total maximum daily loads (TMDLs)
  • Wetlands

27
Discharge Issues
  • NPDES permits required
  • Coal bed methane discharges

28
Water Quality Standards (WQS)
  • EPA continues to develop new water quality
    criteria for toxics, nutrients, microorganisms
  • http//www.epa.gov/ost/standards/wqcriteria.html
  • WQS used to set NPDES permit limits
  • Need to consider mixing zone policies
  • May result in very strict limits
  • May serve as CERCLA or RCRA clean up standards
  • If WQS are set very low, the cost of complying
    can be quite high

29
Total Maximum Daily Loads (TMDLs)
  • Maximum amount of a given pollutant that a water
    body can receive and still meet water quality
    standards
  • TMDLs are pollutant-specific
  • May need more than one TMDL for a given water
    body
  • Based on the capacity of the water body, not on
    the sources of the pollutant

30
Final TMDL Regulations
  • Adopted in 2000
  • Controversial EPA adopted this rule against the
    wishes of Congress
  • Includes point sources and nonpoint sources
  • Air deposition from utilities
  • Nitrogen deposition in Chesapeake Bay watershed
  • Mercury in Great Lakes
  • Strong potential for economic impact over 5-20
    year time frame

31
2000 Rule Whats in a TMDL?
  • Name of water body and pollutant
  • Water quality standard that must be met
  • Allowable pollutant load
  • Load reduction needed and sources of pollutant
  • Allocations for point and nonpoint sources
  • Implementation plan

32
2000 Rule Implementation Plan
  • List of actions needed to reduce pollutant
    loadings
  • Time line
  • Reasonable assurance that implementation will
    occur
  • Monitoring plan with milestones for measuring
    progress
  • Plans for revising TMDL if suitable progress is
    not made

33
Actual Example of TMDL for Mercury in the Middle
and Lower Savannah River
  • Acceptable instream mercury 2.8 ppt
  • Using average annual flow and loading, final TMDL
    is 32.8 kg/year (2/28/01)
  • Current loading is 58.8 kg/year
  • Needed reduction is 26 kg/year
  • Assumes that 99 of mercury comes from
    atmospheric sources
  • Load allocation (atmospheric sources) 0.99
    (32.8) 32.6 kg/year
  • Wasteload allocation (NPDES sources) 0.01
    (32.8) 0.3 kg/year

34
How Will Mercury TMDL Be Achieved?
  • Assumes that 44 reduction in atmospheric
    allocation will be met be 40-50 reduction in
    mercury deposition by 2010 (CAA MACT controls)
  • Assumes that NPDES permits will employ water
    quality based limits for mercury and some
    facilities will implement mercury minimization
    plans

35
Wetlands
  • Many regulatory initiatives on wetlands
  • Nationwide permits
  • Mitigation banking
  • Could affect ability to install, maintain, or
    repair pipelines or to drill wells in some areas
  • There have been and continue to be precedential
    court decisions
  • Need to follow developments to avoid costly or
    time-delaying rules

36
Conclusions
  • There are lots of water issues that affect the
    oil and gas industry
  • Some are developing and DOE can play a role in
    shaping their outcome
  • Others are finalized and DOE can help
    stakeholders implement the requirements
About PowerShow.com