Services

Consultation

At the inception of a project, Gallo Solutions will provide the client with an understanding of what potential permitting, compliance, operational, and time-frame requirements may need to be considered. As the project is refined, further consultation needs to take place to understand the political and/or social environment in the geographical region that the proposed project is planned. It is critical to engage all stakeholders and meet frequently with the regulating agency(s)  involved.

Air Permit Application

Gallo Solutions will work with the client to prepare the necessary air quality permit applications based on project type, size, and regulatory jurisdiction. We have extensive experience in North Dakota (including within the Fort Berthold Indian Reservation), Montana, and Wyoming.

• Minor Source
• Major Source (Title V)
• Post-construction Registration
• Tribal New Source Review

Regulatory Applicability

Determining what federal, tribal, state, and local regulations and requirements are  associated with the project is the most critical step that needs to take place. These regulations determine not only if the facility can be built, but also how it must operate once it is built. Ongoing emissions monitoring & testing, record-keeping, and reporting is determined through these regulations.

Emissions Inventories

Emissions must be estimated for each individual piece of equipment or process  that can emit air pollution. The regulated air pollutants are then analyzed against the different regulatory requirements to determine the types of emissions reductions, control devices, permitting programs, etc. Emissions are calculated utilizing equipment/process specific documentation, combined with emission factors, simulation software, analytical data, testing, etc.

Emissions Control Evaluations

When determining how to reduce emissions from a facility, the best available control technologies/strategies must be evaluated. Depending on the specific equipment or process, the technologies/strategies may be straightforward. However, there are many new emerging technologies that reduce emissions significantly greater than generally recognized technologies. Working with clients and regulating agencies to apply these technologies at the field level is critical to truly understand their real-world capabilities.

Methane Emissions Reduction Strategies

When companies are trying to determine how to reduce their carbon footprint, methane reduction is critical to achieving their internal goals and meeting regulatory standards. Methane is estimated to have approximately 25 times the atmospheric warming effect of CO2 during the next 100 years after being emitted. Furthermore, it is estimated to have 80 times the warming effect of CO2 during the first 20 years. Analyzing the gas/vapor streams and site-specific process equipment and operations is critical to determine the most cost effective approaches that will create the highest level of methane reductions.

Reporting

Emissions reporting may required to be submitted to the regulating agencies to  determine if each permitted facility is not emitting more than it is legally permitted. Reporting may also be used for purposes fees, geographical emissions modeling, understanding industry-wide emissions, ESG, etc. These reporting requirements include, but are not limited to:

• NSPS OOOOabc
• Mandatory Greenhouse (GHG) Reporting (Subpart W, etc.)
• ESG
• Annual Emissions Inventories (State specific)
• Title V Semi-annual
• Tier II (not air quality related)

Sample Collection & Analysis

Depending on the type of operations, sampling the process and emissions streams is critical in determining the facility's potential to emit. These samples also assist in determining  a proper control evaluation, as well as ongoing compliance. 

Leak Detection and Repair (LDAR) Inspections

Fugitive emissions leaks from process equipment in the O&G industry are one of the most significant sources of emissions, especially GHGs (methane).  There are local, state, tribal, and federal regulations requiring LDAR inspections and reporting. Furthermore, LDAR is a critical component in ESG within the O&G industry. There are many different methods of leak detection, such as AOV, Method 9, Method 21, Method 22, OGI FLIR Camera, etc. New leak detection methods that reduce, boots on the ground inspections, are currently being evaluated by regulating agencies, such as drones, planes, and satellites.

Stormwater Pollution Prevention Plan (SWPPP)

A detailed, well developed, and flexible SWPPP is required to maintain construction, industrial, and municipal properties in accordance with Section 402 of the Clean Water Act. Most states require a Construction General Permit, Notice of Intent (NOI) and Notice of Termination (NOT) when performing construction activities. The SWPPP includes, but is not limited to required state/federal forms, Best Management Practices (BMP) details, site maps, schematics, inspection requirements, etc. throughout all phases of construction activity including maintenance, modifications, and corrective action logs. Gallo Solutions is a certified Qualified Preparer of Stormawater Pollution Plans (QPSWPPP) and Qualified Compliance Inspector of Stormwater (QCIS).