High Efficiency Program

This page provides information on how to apply for acceptance into the Department’s High Efficiency Program for air pollution control devices.

Questions about the Department’s High Efficiency Program may be addressed to Russell Martin at 701-328-4639 or RSMartin@nd.gov.

Concept

The goal of the High Efficiency Program is to reduce fugitive emissions, increase control efficiency, and improve North Dakota’s air quality. The High Efficiency Program is an optional flare/combustor approval program within the Division of Air Quality. The program requires collaboration between control device manufacturers, industry leaders, facility operators, and the Department.

The High Efficiency Program takes a top-down approach to addressing emissions from oil and gas facilities through the following steps:

Flare and combustor manufacturers who want to certify their products within the High Efficiency Program must first perform rigorous testing, which is reviewed independently by the Department.
Companies operating oil and gas facilities work with the Department to negotiate an agreement to ensure that both the approved control devices and the companies enact updated standard operating procedures that reduce emissions through enhanced inspections monitoring, maintenance, and air pollution control equipment.
The Department monitors all aspects of the program to ensure that emissions are being maintained within the standards of the High Efficiency Program.

The Department must approve the use of flares or combustors within the High Efficiency Program BEFORE any alternative emission factors can be used .

THE HIGH EFFICIENCY PROGRAM DOES NOT ALLOW RETROACTIVE AUTHORIZATIONS.

Information for Manufacturers

Manufacturers of flares and/or combustors that want to have their products certified under the High Efficiency Program must first contact the Division of Air Quality.

Approval requires:

A rigorous emissions testing and verification process to validate the proposed DRE and/or proposed alternative emission factor.
A system of operating parameters to ensure efficiency is achieved in the field.
A set of maintenance/troubleshooting requirements to reliably maintain the control device to the necessary performance.

Emissions testing of combustors must be performed using Environmental Protection Agency (EPA) approved reference methods and shall be conducted in a manner which documents that the combustors can operate under the range of conditions expected while achieving greater than the proposed DRE and/or alternative emission factor(s).

A variety of flare testing procedures are accepted by the Department for “candlestick” flares. The Department should be contacted for more information regarding the development of a test protocol for these flares.

Test data and protocols submitted to the Department will be reviewed internally before approval to test is granted within the High Efficiency Program.

Information for Oil and Gas Companies

Oil and gas production (upstream) and transmission (midstream) companies can apply for entry into the High Efficiency Program.

The High Efficiency Program requires companies to submit an application at the company-level, which requires a one-time fee of $325 for each application (one application is required for the use of approved flares with a separate application required for the use of approved combustors). Two separate applications must be submitted if a company wishes to apply for the use of flares and combustors. Applications and payment must be submitted online within your company’s “general file” site through CERIS-ND:

Go to Apps, Requests and Reports
Under the Applications, Service Requests & Permit Change Forms header, select Start New Form
Select All Other Forms
The form is titled Air High Efficiency Program Application
Select Begin Submission

The application must address these topics, at a minimum:

Steps your company takes to tie in to/expand the natural gas infrastructure in areas that have available capacity.
Steps your company takes to reduce flaring when capacity is not available.
Your company’s use of quality assurance and quality control (QA/QC) to improve operations, including the utilization of a competent person with training (e.g. OGI and/or LDAR training).
Consideration of reviewing the sizing of collection and processing equipment.
Consideration of improved thief hatches.
Consideration of dump valve enhancements.
Consideration of pressure monitoring.
Consideration of community monitoring for nearby communities.
Consideration of gas capture equipment.
Consideration of acoustic sensors on piping and tanks.
Monitoring and recordkeeping of high efficiency operations.
Identification of locations with MRUs, including the installation date and production from the unit(s) (if applicable).
At least one item/action your company will commit to implementing to reduce fugitive emissions for approval into the High Efficiency Program.

If a company is approved to enter the High Efficiency Program, an approval letter will be issued by the Department. This approval must be included in all future submissions of registrations or permit applications for facilities at which the High Efficiency Program will be utilized. Registrations may not be revised or submitted using any alternative DRE or emission factor until an approval letter has been issued by the Department. The effective date of the approval is the issuance date on the approval letter. The approval may not be utilized retroactively.

Following company approval into the High Efficiency Program:

Oil and gas production (upstream) companies who wish to have oil and gas production sites included in the High Efficiency Program must submit revised oil and gas production site registrations for each previously active site to be included in the High Efficiency Program. New sites may also be registered in the High Efficiency Program. All new and revised registrations must include the Department’s approval letter with the registration.
Oil and gas transmission (midstream) companies shall notify the Department’s compliance manager for all previously active facilities that the company intends to operate within the High Efficiency Program. New constructions must include the Department’s approval letter in the permit to construct application.

Individual facilities under the High Efficiency Program will be given an approval to use an alternative DRE, CO emission factor, and/or NOx emission factor other than the EPA’s accepted AP-42 value for approved flares and/or combustors.

More information is included in the Department Memorandums below.

The Department must approve the use of flares or combustors within the High Efficiency Program BEFORE any alternative emission factors can be used .

THE HIGH EFFICIENCY PROGRAM DOES NOT ALLOW RETROACTIVE AUTHORIZATIONS.

Currently Approved Flares and Combustors

The following flares and combustors have been approved for use in the Department’s High Efficiency Program:

Manufacturer	Approved Models	% DRE Approved	CO EF Approved	NO_x EF Approved
Steffes LLC	SHP-6	99.0%	0.015 lb/MMBtu	N/A
Steffes LLC	SHC-6	99.0%	0.015 lb/MMBtu	N/A
Steffes LLC	SVG-3B4	99.0%	0.030 lb/MMBtu	N/A
American Welltest Incinerators (AWI)	100	99.5%	0.015 lb/MMBtu	0.30 lb/MMBtu
Questor	Q5000	99.5%	0.015 lb/MMBtu	0.30 lb/MMBtu
Zeeco	MJ-3	99.0%	0.10 lb/MMBtu	N/A
Zeeco	MJAG-3	99.0%	0.25 lb/MMBtu	N/A

Any flare or combustor manufacturing company that wishes for their product to be certified within the High Efficiency Program must first contact the Department.

Additional requirements of the High Efficiency Program are detailed in the Department Memorandums Below. Any company using the High Efficiency Program must follow the requirements detailed in the Department Memorandums.

NONCOMPLIANCE WITH THESE REQUIREMENTS MAY RESULT IN REMOVAL OR SUSPENSION FROM THE HIGH EFFICIENCY PROGRAM AND/OR ENFORCEMENT ACTION.