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Avoid Air-rors! Discuss the Air Regulations that Impact Oil and Gas Development

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Presentation about the air regulations affecting oil and gas development. Topics covered include NSPS OOOO, Leak Detection and Repair, Greenhouse Gas Inventory/Reporting, Optical Gas Imaging with Infrared Cameras

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Avoid Air-rors! Discuss the Air Regulations that Impact Oil and Gas Development

  1. 1. Avoid Air-rors! Discuss the Air Regulations that Impact Oil and Gas Development January 29, 2014 Jay Christopher Il Kim
  2. 2. Today’s Presenters Jay Christopher Business Unit Manager, Air & Process Services jchristopher@trihydro.com 303/815-9583 Il Kim Chemical Engineer, Air & Process Services ikim@trihydro.com 307/745-7474
  3. 3. Today’s Agenda     NSPS Subpart OOOO (“Quad O”) Leak Detection and Repair Greenhouse Gas (GHG) Inventory/Reporting Optical Gas Imaging with Infrared Cameras
  4. 4. The more you explain it, the more I don’t understand it. -Mark Twain
  5. 5. Today’s Agenda     NSPS Subpart OOOO (“Quad O”) Leak Detection and Repair Greenhouse Gas (GHG) Inventory/Reporting Optical Gas Imaging with Infrared Cameras
  6. 6. EPA’s New Source Performance Standards, Subpart OOOO (aka NSPS Quad O)      Applicable to Crude Oil and Natural Gas Production, Transmission and Distribution Final rule published August 16, 2012 Affects many activities after August 23, 2011 Targets VOC emissions, not methane Natural gas focused, but not exclusively
  7. 7. What is Covered Under NSPS OOOO? Well site • Completions • Storage Vessels • Pneumatics Gathering Booster Facilities • Storage Vessels • Pneumatics • Compressors Natural Gas Plants • Storage Vessels • Pneumatics • Compressors • LDAR • SO2 Natural Gas Transmission Compression • Storage Vessels Underground Natural Gas Storage • Storage Vessels To Distribution
  8. 8. Primary Impacts from Quad O  Natural Gas Production  Hydraulic Fracturing Green Completions Gas Plants (tighter LDAR requirements) Also, significant recordkeeping and reporting requirements.  Oil and/or Natural Gas    Compressors (centrifugal wet seal controls; reciprocating - rod packing replacement) Pneumatic controllers (zero bleed at gas plants, low bleed everywhere else) Storage vessels (controls if emit > 6 tons VOCs/year)
  9. 9. Quad O – Storage Tank Reconsideration  EPA finalized “reconsideration” of storage tank control requirements on September 23, 2013. Final rule is more stringent    EPA significantly underestimated the number of effected storage tanks Group 1 (between August 23, 2011 and April 12, 2013) – controls after April 15, 2015. Emissions evaluation by October 15, 2013. Group 2 (after April 12, 2013) – controls by April 15, 2014
  10. 10. Other Air Regulations    EPA Power Plant NSPS Rule Colorado’s proposed Regulation 7 California 2013 law to regulate CO2 EOR projects used for carbon sequestration
  11. 11. Air Permitting and CO2    CO2 is an “air pollutant” (U.S. Supreme Court; Massachusetts vs. EPA, 2007) EPA “Endangerment Finding” – 2009 Automobile tailpipe emission standards So how does this affect you?
  12. 12. Major Source Air Permitting  EPA’s “Tailoring Rule”    Major source permitting thresholds (100 tons/year of pollutants) would result in “absurd results” - EPA established a 25,000 tons/year threshold for CO2 Projects that are major for CO2 must consider Best Available Control Technology (BACT) CCS is not “mature” and most CO2 BACT to date has focused on energy efficiency
  13. 13. Today’s Agenda  NSPS Subpart OOOO (“Quad O”)  Leak Detection and Repair   Greenhouse Gas (GHG) Inventory/Reporting Optical Gas Imaging with Infrared Cameras
  14. 14. Leak Detection and Repair (LDAR)  What is LDAR?    A systematic evaluation of leaking components (valves, pumps, flanges, connectors, relief valves, etc.) for fugitive leakage of organic compounds to the atmosphere. EPA Method 21 – a formal method using calibrated instruments to measure fugitive leakage Optical gas imaging – uses a special infrared camera that can “see” fugitive emission leaks
  15. 15. LDAR and NSPS OOOO  Process Unit Definition    Need to accurately define process unit boundaries Be sure the Management of Change process captures LDAR-type changes NSPS OOOO triggers will be for affected process units, not the entire facility
  16. 16. LDAR and MACT HH    MACT HH applies to gas plants with glycol dehydrators (major sources or area sources) Major sources have > 1 ton/year benzene emissions, with LDAR streams > 10% volatile organic HAPs (VOHAP) 2012 MACT HH LDAR leak definition changed to 500 ppm valves/2,000 ppm pumps
  17. 17. LDAR Implications   One facility can have components subject to NSPS KKK, NSPS OOOO, and MACT HH Carefully evaluate facility changes
  18. 18. Today’s Agenda     NSPS Subpart OOOO (“Quad O”) Leak Detection and Repair Greenhouse Gas (GHG) Inventory/Reporting Optical Gas Imaging with Infrared Cameras
  19. 19. GHG Emissions Reporting  Greenhouse Gas Mandatory Reporting Rule (GHG MRR)      Subpart W for oil and gas sources Subpart RR for geologic sequestration Subpart UU for enhanced oil recovery Reporting due every March for prior calendar year Testing, source counting, data capture, emission factors
  20. 20. GHG MRR
  21. 21. GHG MRR
  22. 22. EPA’s GHG MMR - Who Must Report?  “…owners and operators of any facility that is located in the United States or under or attached to the Outer Continental Shelf…”
  23. 23. Image: Bureau of Ocean Energy Management
  24. 24. Subpart W – Petroleum and Natural Gas Systems
  25. 25. Subpart W – GHGs to Report  All industry segments under Subpart W will report the following GHGs     CO2 CH4 N20 CO2, CH4, and N20  CO2e
  26. 26. Other Considerations for Subpart W  Enhanced Oil Recovery     Reporting under multiple subparts Reporting under Subpart W Calculations Changes to Subpart W   Effective January 1, 2014 Global warming potentials
  27. 27. Subpart W – Field Data   40 CFR 98.233 (o) & (p) centrifugal compressor venting and reciprocating compressor venting 40 CFR 98.233 (q) Leak detection and leaker emission factors
  28. 28. Optical Gas Imaging
  29. 29. Monitoring and QA/QC Requirements    Methods to conduct leak detection You must operate and calibrate all flow meters, composition analyzers and pressure gauges… Best available monitoring methods (BAMM)
  30. 30. Document, Report, Keep Records, Repeat
  31. 31. Subpart RR – Geologic Sequestration of Carbon Dioxide  Source Category  The geologic sequestration of carbon dioxide (CO2) source category comprises any well or group of wells that inject CO2 stream for long-term containment in subsurface geologic formations
  32. 32. Subpart RR – Calculating CO2 Geologic Sequestration  You must calculate annual mass of CO2…      Received by pipeline and containers Injected and sequestered in subsurface geologic formations Produced from wells Emitted by surface leakage Equipment leaks and vented emissions
  33. 33. Subpart RR – Monitoring and QA/QC Requirements of Equipment Leaks  Monitoring of surface equipment between the flow meter and the wellhead   You can use any of the methods described in section 98.234 of Subpart W FLIR has been working to create a Gas Finder IR camera to detect CO2
  34. 34. Subpart UU – Injection of Carbon Dioxide   Injection of carbon dioxide (CO2) source category comprises any well or group of wells that inject CO2 stream into the subsurface Source category refers to those facilities that inject CO2 for the purpose of enhanced oil recovery by CO2 injection not CO2 storage
  35. 35. Subpart UU – Calculating CO2 Emissions  You must calculate annual mass of CO2…   Received by pipeline Received in containers
  36. 36. Today’s Agenda     NSPS Subpart OOOO (“Quad O”) Leak Detection and Repair Greenhouse Gas (GHG) Inventory/Reporting Optical Gas Imaging with Infrared Cameras
  37. 37. FLIR GF 320 Basics     Theory Cooled, 320x240 Indium Antimonide Microcooler and Cold Filter Auto, Manual, and High Sensitivity Modes (HSM)
  38. 38. Leaking Gas = $$$   A leak at 60 gph methane equates to about $134.00 per leak per year Average 100 leaks per facility and each leak is 10 times the rate of 60 gph the total money lost in gas is $133,567.00 per year
  39. 39. Other Applications of the GF320        Highway Safety Raw Materials Monitoring Airport Security Medical Veterinary Building Inspection Electrical
  40. 40. Questions? If you ask me anything I don’t know, I’m not going to answer. -Yogi Berra Jay Christopher Business Unit Manager, Air & Process Services jchristopher@trihydro.com 303/815-9583 Il Kim Chemical Engineer, Air & Process Services ikim@trihydro.com 307/745-7474

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