From the pages of
Sublette Examiner
Volume 8, Number 3 - April 10, 2008
brought to you online by Pinedale Online

DEQ Inspects Industry Equipment For Air-Quality Issues

by Tiffany Turner

The process oil and gas industry companies use to ensure proper operating protocols for Sublette County’s air quality is becoming increasingly important.

Companies usually have their own employees to ensure proper protocol is followed, which greatly reduces immediate risks for area employees and ensures machinery is operating properly.

For larger issues involving the natural habitat and environment, the Bureau of Land Management (BLM), Wyoming Department of Environmental Quality (DEQ) and the U.S. Fish and Wildlife Service (FWS)have the task of ensuring operator practices remain within legal limits–and if they are not ,fines are instated when needed.

“We issue Notices of Violation (NOV) when we inspect facilities and find what in our judgment constitutes a noncompliance condition that justifies a formal enforcement action,” said Dave Finley, Air Quality Division (AQD) administrator of the DEQ. “Not all noncompliance conditions we find result in a formal enforcement action; under the Wyoming Environmental Quality Act we are authorized to resolve violations through a process of ‘conference and conciliation’ without taking formal enforcement actions. Many of the conditions of noncompliance we encounter during inspections are resolved by conference and conciliation, often during the inspection.”

According to Finley, NOVs requiring enforcement then enter a settlement phase in which the DEQ works with the violator to reach an agreement.

“While we are empowered under the Wyoming Environmental Quality Act to enter into settlement agreements with companies to resolve violations, we do not have the power to unilaterally impose penalties on violators (except in the case of surface coal mine violations),” Finley said. “If we are unable to reach agreement on settlement terms that are acceptable to (DEQ ), and believe that a penalty is warranted for a particular violation, we must ask a state court to impose a penalty.”

“For NOVs that have not yet been settled with a company, we do not disclose information about settlement discussions until they have been finalized,” Finley said. “(The) Air Quality Division (AQD) enforcement actions are listed on the DEQ website, but the listings cover all notices that have been issued statewide.

NOVs given by the DEQ over the past year are available on its Web site with information on the violation and current status of the settlement. The website address is:

Jonah-Anticline NOVs

The Jonah Field has a full-time AQD inspector, Jennifer Frazier, who ensures all operations are running properly. “You will note that there are more notices for EnCana operations than for others,” Finley said. “The primary reason for this is that AQD’s inspection activities have been concentrated in the Jonah Filed where EnCana is the main operator. AQD’s inspection presence in Jonah has been made possible as a result of funding provided by Jonah operators which created the Jonah Infill Office (JIO); AQD is represented in that office by Jennifer Frazier.”

A total of 20 NOVs have been issued to Jonah/Pinedale Anticline (JPDA) operators.

“The status of all of these NOVs is that we are in settlement discussions with Shell, Ultra and EnCana and have entered into a settlement agreement with Devon,” Finley said. “You’ll observe that these notices were generally issued early in 2007.

“AQD’s increased presence in the Jonah field really began about that time. Prior to the creation of the JIO, DEQ’s AQD had conducted limited inspections of the thousands of oil and gas production facilities throughout the state. This is because our inspection resources have been historically concentrated on major sources, where an individual air emission source can emit several thousand tons per year of a single pollutant – while a natural gas well typically emits less than 100 tons/year uncontrolled, and less than 10 tons/year controlled.”

Noncompliance process

When the JIO came into existence in early 2007, one of the first steps taken by the DEQ was to require all production operators in the JPDA to conduct engineering assessments of “the design, operation and maintenance of they air pollution control systems to identify if there were systematic problems with those systems,” Finley said.

“Following the identification of the causes of noncompliance at each company’s operations,AQD required each company to upgrade each production site in the Jonah and Pinedale to make the changes that were identified in the company’s engineering evaluations as causing or contributing to any noncompliance,” he added.

According to Finley, these changes included “hiring additional personnel where in attention to routine maintenance was identified as the root cause, replacing piping to reduce backpressure and eliminate low points which led to freezing and pipe blockage, replacing combustors with newer design units that are more reliable, changing safety relief valves so they do not vent vapors to the atmosphere under normal operating condition and installing additional monitors to allow more effective operational oversight of air pollution control systems.”

Finley said most of required upgrades were finished in the summer and fall of 2007 except for EnCana’s. EnCana, Finley said, is roughly halfway through their required upgrades because their upgrades require wholesale replacement of combustors. EnCana is expected to finish the upgrades this August.

Continued inspections

“We are continuing to inspect production operations in the Jonah Field, and are evaluating upgraded air pollution control systems to ensure they are operating in compliance with our air permitting requirements,” Finley said. “When we find noncompliant systems, we will take appropriate enforcement action.”

According to Finley, in September 2007 the AQD instituted new conditions that required each new application for oil and gas production permit to contain written certification that all required equipment was installed and verified for effective operation. The AQD also instated a regulation requiring operators to periodically inspect each of their sites and correct any problems.

“Although the (AQD) has not had the resources in the past (and we still don’t, except for the Jonah Field) to focus inspection and compliance activities on oil and gas production sites, I have directed our Lander district field office to schedule routine inspections of these sited in the Pinedale Anticline, LaBarge, Riley Ridge and other southwest Wyoming fields,” he said.

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