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Avoid Air-rors! Discuss the Air Regulations that Impact Oil and Gas Development
The document discusses air regulations affecting the oil and gas industry, specifically focusing on EPA's New Source Performance Standards (NSPS) subpart OOOO, which sets stringent requirements for emissions control and leak detection. It outlines the necessary compliance actions, including greenhouse gas inventory reporting, optical gas imaging, and the implications of other air regulations. Key updates include more stringent control requirements for storage tanks and various regulations impacting emissions reporting for oil and gas operations.
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Avoid Air-rors! Discuss the Air Regulations that Impact Oil and Gas Development
- 1. Avoid Air-rors! Discuss theAir Regulations that Impact Oil and Gas Development January 29, 2014 Jay Christopher Il Kim
- 2. Today’s Presenters Jay Christopher BusinessUnit Manager, Air & Process Services jchristopher@trihydro.com 303/815-9583 Il Kim Chemical Engineer, Air & Process Services ikim@trihydro.com 307/745-7474
- 3. Today’s Agenda NSPS SubpartOOOO (“Quad O”) Leak Detection and Repair Greenhouse Gas (GHG) Inventory/Reporting Optical Gas Imaging with Infrared Cameras
- 4. The more youexplain it, the more I don’t understand it. -Mark Twain
- 5. Today’s Agenda NSPS SubpartOOOO (“Quad O”) Leak Detection and Repair Greenhouse Gas (GHG) Inventory/Reporting Optical Gas Imaging with Infrared Cameras
- 6. EPA’s New SourcePerformance 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. What is CoveredUnder 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
- 9. Primary Impacts fromQuad 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)
- 10. 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
- 11. Other Air Regulations EPAPower Plant NSPS Rule Colorado’s proposed Regulation 7 California 2013 law to regulate CO2 EOR projects used for carbon sequestration
- 12. Air Permitting andCO2 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?
- 13. Major Source AirPermitting 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
- 14. Today’s Agenda NSPS SubpartOOOO (“Quad O”) Leak Detection and Repair Greenhouse Gas (GHG) Inventory/Reporting Optical Gas Imaging with Infrared Cameras
- 15. Leak Detection andRepair (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
- 16. LDAR and NSPSOOOO 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
- 17. LDAR and MACTHH 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
- 18. LDAR Implications One facilitycan have components subject to NSPS KKK, NSPS OOOO, and MACT HH Carefully evaluate facility changes
- 19. Today’s Agenda NSPS SubpartOOOO (“Quad O”) Leak Detection and Repair Greenhouse Gas (GHG) Inventory/Reporting Optical Gas Imaging with Infrared Cameras
- 20. GHG Emissions Reporting GreenhouseGas 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
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- 23. 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…”
- 24. Image: Bureau ofOcean Energy Management
- 25. Subpart W –Petroleum and Natural Gas Systems
- 26. Subpart W –GHGs to Report All industry segments under Subpart W will report the following GHGs CO2 CH4 N20 CO2, CH4, and N20 CO2e
- 27. Other Considerations forSubpart W Enhanced Oil Recovery Reporting under multiple subparts Reporting under Subpart W Calculations Changes to Subpart W Effective January 1, 2014 Global warming potentials
- 28. 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
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- 30. Monitoring and QA/QCRequirements Methods to conduct leak detection You must operate and calibrate all flow meters, composition analyzers and pressure gauges… Best available monitoring methods (BAMM)
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- 32. 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
- 33. 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
- 34. 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
- 35. 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
- 36. Subpart UU –Calculating CO2 Emissions You must calculate annual mass of CO2… Received by pipeline Received in containers
- 37. Today’s Agenda NSPS SubpartOOOO (“Quad O”) Leak Detection and Repair Greenhouse Gas (GHG) Inventory/Reporting Optical Gas Imaging with Infrared Cameras
- 38. FLIR GF 320Basics Theory Cooled, 320x240 Indium Antimonide Microcooler and Cold Filter Auto, Manual, and High Sensitivity Modes (HSM)
- 39. 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
- 40. Other Applications ofthe GF320 Highway Safety Raw Materials Monitoring Airport Security Medical Veterinary Building Inspection Electrical
- 41. Questions? If you askme 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
Editor's Notes
- #2 Good afternoon, and thank you for attending the first in what we hope will be a series of workshops jointly sponsored by the Enhanced Oil Recovery Institute and Trihydro Corporation. Today’s topic focuses on air quality regulations, a hot topic these days. Future workshops will focus on ---------------------------------------------First, some housekeeping. We are presenting both before an in-person audience at EORI’s beautiful facility on the University of Wyoming campus in Laramie, as well as before a remote audience via webinar. The webinar audience is muted, and you can submit questions online. We hope to respond to any questions at the break points between topics in our presentation today. Also, based on the registration information you provided, we will provide you with a PDF version of today’s presentation in the near future. There will be some video segments shown today, but unfortunately those files are too large to provide.
- #3 Our presenters today are Jay Christopher and Il Kim with Trihydro. Both Jay or Il will be available following the workshop for discussions with the local audience, and their contact information is provided if you would like to follow-up directly.
- #4 Thank you Amy. Thanks again for all of you joining us this afternoon. We have over 90 people signed up for the webinar this afternoon, and about 20 people in person here at the Encana auditorium at the Enhanced Oil Recovery Institute’s facility on the University of Wyoming campus in Laramie. We have a broad mix of attendees. Industry professionals, attorneys, regulators, fellow consultants, and students. The audience ranges from experts on some of the topics we will address to others that may not have much knowledge of these programs. We hope our presentation today will result in some takeaways that will help you in the future. Again, thank you all for your interest today. We are going to focus on four topics during today’s workshop. With the exception of some of the GHG reporting rules we will discuss later, most of these topics apply not only to the enhanced oil recovery sector, but also more broadly to the oil and gas sector as a whole. First, we will talk about NSPS Quad O, which applies to oil and gas operations from the wellhead forward. We will follow that with a high level discussion about recent regulatory issues affecting oil and gas leak detection and repair programs. Then Il Kim will discuss greenhouse gas inventory and reporting, and finally Il will close with a discussion about the use of infrared cameras to detect fugitive emission leaks.
- #5 Obviously Mark Twain was a man before his time. Isn’t it amazing that Mark Twain had some much insight into our regulatory world?
- #7 EPA’s New Source Performance Standard Subpart OOOO, often referred to as Quad O, was finalized in August 2012. As you will see, the rule actually affects many regulated pieces of equipment that were put in place on or after August 23, 2011. This is because the Clean Air Act as written by Congress includes language that specifies that the effect date of New Source Performance Standards will be the date that the rule was proposed.
- #8 Here is a graphic showing the portions of operations affected by Quad O. With respect to enhanced oil recovery, the impacts tend to be more on the production side, although as we will discuss shortly, gas plants are also affected. However, it is safe to say that Quad O affects a large swath of the upstream and midstream sectors of oil and gas operations.
- #9 This timeline shows some of the key dates in the Quad O rule. I want to highlight several for you. August 23, 2011 is the rule’s effective date … this means that affected facilities installed since August 2011 may be subject to requirements under Quad O. August 16, 2012 – this is the date that the Quad O rule was published in the Federal Register. It interesting that it took 4 months following the EPA Administrator's signature before the rule was published … much longer than normal. October 15, 2012 – the date when many of the key Quad O requirements went into effect. April 2014 - the compliance date for Group 1 storage tanks April 2015 – the compliance date for Group 2 storage tanks
- #10 I’ve tried to highlight the primary impacts from this rule. As you will note, it is a bit more focused on natural gas production.
- #11 In September 2013, EPA finalized the first of what may be several “reconsiderations” of the rule. Basically, a reconsideration is when the rule needs to be adjusted because the initial rule did not consider all issues at the right level of detail. In this instance, EPA changed the manner in which storage tanks are regulated, and generally requires controls on storage tanks that emit greater than 6 tons/year of volatile organic compounds that were installed during the timelines mentioned on the slide. EPA is currently working through an additional “reconsideration” that is expected to be published by the end of March this year. I am sure that some of you listening today are very involved in that reconsideration process.
- #12 I wanted to take a minute to talk about some other issues that will have some affect on our industry.First, the Power Plant NSPS rule, which specifically targets GHG emissions from coal-fired plants.Next, as many are aware, Colorado has proposed oil and gas air regulations that are intended to apply statewide, and include all hydrocarbons, as opposed to volatile organic compounds. What that principally means is that methane is proposed to be regulated under this regulation. Finally, last year California passed a bill that requires the air resources board to establish regulations for CO2 enhanced oil recovery projects.So the big question here, I think, is where will all of these lead?
- #15 Now let’s talk about leak detection and repair programs.
- #16 - Method 21 measures concentrations at the point of leakage in ppm. Interestingly, although most of the regulatory programs specifying Method 21 for measuring fugitive leaks are for VOCs, Method 21 often requires calibration with methane. The concentrations detected are not specific to a particular hydrocarbon, and often speciation data is used to adjust the results to the required measurements.- Il Kim will discuss optical gas imaging in more detail in his discussion shortly.
- #22 What is EPAs GHG MMR – The mandatory reporting rule is a rule that has been set in place by the US EPA. They have established reporting requirements of GHGs for owners and operator of certain facilities that directly emit GHGs.
- #23 What is EPAs GHG MMR – The mandatory reporting rule is a rule that has been set in place by the US EPA. They have established reporting requirements of GHGs for owners and operator of certain facilities that directly emit GHGs.
- #26 We are mostly concerned with Onshore Petroleum and natural gas production and onshore natural gas processingAffected Industry SegmentsOffshore petroleum and natural gas productionOnshore petroleum and natural gas productionOnshore natural gas processingOnshore natural gas transmission compressionUnderground natural gas storageLiquefied natural gas (LNG) storageLNG import and export equipmentNatural gas distribution
- #28 If you are an industry segment under Subpart W and you also perform EOR you must remember to calculate the emissions from injection of CO2. You must calculate EOR injection pump blowdown and the EOR hydrocarbon liquids dissolved CO2. More than likely you will then have to calculate GHG emissions under Subpart RR or Subpart UU for the remainder of the injection calculations.
- #29 The methods described in section 98.234(a) will also be implemented in Subpart RR – CO2 Geological Sequestration.
- #31 We will come back to monitoring and QaQc requirements. Subpart RR will refer back to this section. We are most concerned with OGI instrument requirements.
- #32 You don’t just have Monitoring and QAQC requirements but you also have reporting and record keeping requires. Some of these documents are considered “living documents” others are not.
- #33 If your facility injects any amount of CO2 for long-term containment in subsurface geologic formation you must report, There is no minimum threshold for reporting.
- #34 Monitoring the Equipment leaks and vented emissions are very interesting in the subpart.
- #35 Monitoring the Equipment leaks and vented emissions are very interesting in the subpart.
- #36 If your facility injects any amount of CO2 for long-term containment in subsurface geologic formation you must report.
- #37 The calculations for subpart UU are very simple. The we are all happy when the calculations are simpler than finding fluid momentum in a given volume.
- #39 Principal behind the camera – Detects the imbalance of emission and absorption of a chemical species. Each gas absorb and emit energy in the form of IR radiation (waves). The camera is calibrated to detect this energy within a certain wave band. Detector is made of a semi-conductor material Indium Antimonide (InSb), Reduces quantum noise in the detector. Detector visualizes gases in the 3.2 – 3.4 micrometer waveband. Cold filter – improve detectivity by eliminating background radiation in unwanted wavelength regions. Proprietary MWIR Cold FilterInternal cooling system – cools detector to near liquid Nitrogen Temperature (77K or -321F) using a stirling microcoolerModes of Use – High sensitivity mode, Auto, Manual. HSM – Image subtractions. Removes frames from video. This allows to any small movement to be noticed. Enhances the differences in the frames
- #40 Cost of methane from U.S. Energy Information Administration. Methane citygate price = $5.14 per thousand cubic feet