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Greenhouse Gas Reporting for E&P

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Presentation for Oklahoma Independent Producers Association, Unconventional Resources Symposium in Tulsa, Oklahoma on December 13, 2011.

Presentation for Oklahoma Independent Producers Association, Unconventional Resources Symposium in Tulsa, Oklahoma on December 13, 2011.

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  • Vented = intentional releases. Leaks by design (rod packing in reciprocating compressor) Other categories report combustion emissions under Subpart C.
  • Segments as defined in the rule. EOR is included in the gas production facilities. Offshore includes facilities in the US and on or under the Outer Continental Shelf, in the territorial seas. As an information gathering rule, it is not regulating emissions. Basin - Uses AAPG (Amer. Association of Petroleum Geologists) definition of basin. If multiple permits, combine them.
  • Basin level = under common ownership or control EOR is included in the gas production facilities. Offshore includes facilities in the US and on or under the Outer Continental Shelf, in the territorial seas. As an information gathering rule, it is not regulating emissions. Basin - Uses AAPG (Amer. Association of Petroleum Geologists) definition of basin. If multiple permits, combine them.
  • Well type is horizontal or vertical
  • Fractionate = NGLs into components (ethane and heavier) Throughput = annual average
  • Transcript

    • 1. December 13, 2011 Deanne D. Hughes, PE Principal GHG: What’s The Big Fuss?
    • 2. GHG Reporting for the Independent Producer
      • Overview/Recap
      • Oil and Gas Related GHG MRR Subparts
      • Subpart W (Petroleum and Natural Gas Systems)
      • Source Categories in Subpart W
      • BAMM Timeline Reminders
      • Questions and Discussion
    • 3. Mandatory Reporting Rule
      • Purpose – To create a nationally-comparable database for use by Congress, EPA, states and the public in designing GHG Policy
      • Proposal – April 10, 2009
      • Finalization – September 22, 2009
      • Effective Date – December 29, 2009
      • Data gathering began 1/1/2010, first report due 9/30/2011 for some categories
      • First reporting year for Onshore Petroleum and Natural Gas Production is 2011 with reports due September 2012.
    • 4. Mandatory Reporting Rule
      • Data gathering beginning January 2010, first reports due September 2011:
        • Subpart C (Stationary Combustion)
        • Subpart Y (Petroleum Refineries)
        • Subpart MM (Suppliers of Petroleum Products)
        • Subpart NN (Natural Gas and Natural Gas Liquids)
        • Subpart PP (Suppliers of Carbon Dioxide)
        • Data gathering beginning January 2011, first reports due September 2012:
        • Subpart W (Petroleum & Natural Gas Systems)
        • Subpart RR (Geologic Sequestration)
        • Subpart UU (Carbon Dioxide Injection)
    • 5. Subpart W – Petroleum & Natural Gas Systems
      • Includes Reporting of:
        • CO 2 , CH 4 released through venting and equipment leaks
        • CO 2 , CH 4 , N 2 O emissions due to flaring
        • CO 2 , CH 4 , N 2 O stationary combustion emissions for onshore production and LDCs
      • Threshold category
        • To determine applicability, all “threshold” categories are additive
    • 6. Subpart W – Segments
      • Includes the following industry segments:
        • Petroleum & natural gas production – offshore & onshore
        • Onshore natural gas processing plants
        • Onshore natural gas transmission compression
        • Underground natural gas storage
        • LNG storage
        • LNG import and export equipment
        • Natural gas distribution (LDCs)
    • 7. Subpart W – Onshore Production
      • Onshore production includes portable non-self propelled equipment, EOR operations using CO2 or natural gas
      • Facility definition is basin level
        • All equipment on well pad or associated with a well pad, under common ownership or control, including leased, rented or contracted activities by a production owner or operator located in a single hydrocarbon basin
        • Basin is American Association of Petroleum Geologist Provinces Code Map
      • Assets will be classified within each basin by sub-basins based on the type of hydrocarbon formation and county boundaries.
        • Oil, high permeability gas, shale gas, coal seam, or other tight reservoir rock.
    • 8. Subpart W – Onshore Production
      • Natural Gas pneumatic device venting
      • Natural Gas driven pneumatic pump venting
      • AGR vent stack
      • Dehy vent stack
      • Well venting for liquids unloading
      • Well completion/workover venting
      • Storage tanks
      • Well testing venting/flaring
      • Associated gas venting/flaring
      • Flares
      • Compressor venting
      • Equipment leaks
      • EOR dissolved CO2
      • EOR injection pump blowdowns
      • Combustion Emissions
    • 9. So What?
      • Significant data collection, assurance, and management issues.
        • Some of the activities for which reporting is required are grouped by “sub basin and well type combinations”
      • Devon provided very good summary at Fall Conference. Its GHG Applicability Tool suggests that reporting under Subpart W could be triggered with as few as 40-50 wells in a basin.
      • The EPA Applicability Tool significantly underestimates emissions from sources meaning that some operators may think his/her company is exempt from reporting when, in fact, the CO2e emissions exceed thresholds.
    • 10. Onshore Production – Devon Applicability Tool Details
      • Natural Gas pneumatic device venting
      • Natural Gas driven pneumatic pump venting
      • AGR vent stack
      • Dehy vent stack
      • Well venting for liquids unloading
      • Well completion/workover venting
      • Storage tanks
      • Well testing venting/flaring
      • Associated gas venting/flaring
      • Flares
      • Compressor venting
      • Equipment leaks
      • EOR dissolved CO2
      • EOR injection pump blowdowns
      • Combustion Emissions
    • 11. Subpart W – Natural Gas Processing
      • December 2, 2011 amendments to the rule revise the definition to include one or a combination of the following:
        • Separation of NGLs from produced natural gas
        • Separation of non methane gases from produced natural gas
        • Separation of NGLs into one or more component mixtures
      • Separation can be extraction of NGLs, S or CO2 removal, fractionation of NGLs, or capture of CO2
      • Applies only to plants with >25 MMscf annual average daily throughput .
      • Includes owned or operated residue compression
    • 12. How can I get all this done?
      • This grouping approach is not consistent with how most operators structure their business, their people, or their data.
      • Inventories of equipment are ever-changing in response to field and well needs.
      • Will take numerous trained people to collect the required data
      • It is a continuous process of determining rule applicability that essentially requires the same level of effort as reporting.
    • 13. What Do I Need to Do NOW?
      • Organize and Plan
        • What do you need? – Rule, Guidance, Internal and External Resources
        • What do you have? – Spreadsheets of information, purchase records, production records…
        • How are you going to manage the data? – software, database, spreadsheet….
        • Who is on the team and what is each person’s role?
        • How can I have more time?
    • 14. Apply for BAMM
      • For 2011, Best Available Monitoring Methods can be used to obtain the information to perform the calculations for reporting.
        • Automatic
      • Note – this is not an opportunity to calculate the GHG emissions any way you want --- you have to use the calculation methodology as described in the rule.
      • BAMM gives you the flexibility for how you determine the inputs to the equations.
    • 15. BAMM Process
      • If desired for 2012, need to apply on e-GGRT
      • Notice of Intent to apply for BAMM must be submitted by December 31, 2011.
      • The BAMM request is due by March 30, 2012.
      • BAMM is automatically approved through June 30, 2012 for facilities submitting NOI and BAMM Request.
      • EPA must approve facility to use BAMM past June 30, 2012.
    • 16. BAMM e-NOI
      • Identification of all facilities for which BAMM is needed.
      • What source categories apply to the facilities
      • Application comes from the Designated Representative.
    • 17. BAMM Extension Request
      • Detailed information on what source categories apply and the data required.
      • Explain each data parameter for which BAMM is requested and why.
        • “ Unusual or Unique Circumstances”
      • Timeline for complying with the reporting requirements.
      • This could be a very significant submittal – don’t wait to start it.
      • Anything NOT in the BAMM request? Begin collecting data in accordance with Subpart W on 1/1/12.
    • 18. Questions?
      • Deanne Hughes, PE
      • [email_address]
      • 918.895.9766 or 405.202.9605
      • Kristine Baranski, PE
      • [email_address]
      • 405.842.1066
      • www.CardinalEngineers.com
    • 19. Acknowledgements
      • EPA Greenhouse Gas Mandatory Reporting Rule - Darren Smith and Bill Bailey, Devon Energy, Presenters at Fall Conference, November 2011, Oklahoma City, OK.
      • http://www.oipa.com/custom/shownewsmulti.php?action=detail&id=334
      • Kristine Baranski, PE, Cardinal Engineering, Inc.
    • 20. Helpful Links
      • www.oipa.com –
        • Applicability Tool for portions of Onshore Production source category
        • Presentations made at Fall Conference and Air Emissions Workshop
        • Links to BAMM information
      • http://www.epa.gov/climatechange/emissions/ghgrulemaking.html - EPA website for GHG reporting rule.
    • 21. Questions?
      • Deanne Hughes, PE
      • [email_address]
      • 918.895.9766 or 405.202.9605
      • Kristine Baranski, PE
      • [email_address]
      • 405.842.1066
      • www.CardinalEngineers.com

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