ESE was engaged by a major Exploration and Production (E&P) company to evaluate their production operations in the Arkoma Business unit for: Greenhouse Gas (GHG) compliance reporting in accordance with 40 CFR Part 98 Subpart W, Spill Prevention Control and Countermeasure Plan (SPCC), and to determine the appropriate level of air quality permitting necessary to comply with the federal and state requirement.
ESE’s objective was to prepare permit applications, permit-exempt packages etc. for submission to the agency, evaluate GHG emissions, review of equipment and appurtenances at each facility (including compressor engines), and prepare SPCC plans in accordance with the requirements set forth in the 40 CFR 112.
Scope of Work
- ESE performed applicability screening in regards to the NSPS/NESHAP/MSS/MACT/BACT standards and reviewed all operational data in regards to the process flow, equipment, liquid/gas material constituency and throughputs for preparing permit-exempt and air quality permit application packages.
- ESE conducted GHG applicability screening by compiling equipment inventory data, processes and appurtenances to calculate GHG emissions and submit the report to the EPA using e-GGRT. GHG guidance document and monitoring plan were created to assist the company with data collection, emission calculations and reporting and record keeping purposes.
- For SPCC preparation purposes, ESE visited each facility located in Arkoma Basin, examined all relevant and applicable facility oil storage, handling, transfer and loading/unloading process, as well as conducted interviews with designated facility personnel. ESE communicated the containment deficiencies to the company personnel, recommended corrective actions and prepared the final SPCC plan to be maintained and implemented at each site.
- ESE prepared and submitted emission inventory reports to the ODEQ for the facilities permitted under Title V, Minor Source Air Permits and Permit By Rule.
Key Benefits to Client
- Permitting, inspection and record keeping program ensured compliance with the applicable state and federal permits, rules and regulations.
- Voluntary disclosures/self-reporting of noncompliance to avoid any administrative or civil penalty.