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
Choosing the Right CBSE School A Comprehensive Guide for Parents
Avoid Air-rors! Discuss the Air Regulations that Impact Oil and Gas Development
1. Avoid Air-rors!
Discuss the Air Regulations that Impact
Oil and Gas Development
January 29, 2014
Jay Christopher
Il Kim
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. Today’s Agenda
NSPS Subpart OOOO (“Quad O”)
Leak Detection and Repair
Greenhouse Gas (GHG) Inventory/Reporting
Optical Gas Imaging with Infrared Cameras
4. The more you explain it, the more I
don’t understand it.
-Mark Twain
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. 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. 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.
9. 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)
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
EPA Power Plant NSPS Rule
Colorado’s proposed Regulation 7
California 2013 law to regulate CO2 EOR
projects used for carbon sequestration
12. 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?
13. 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
14. Today’s Agenda
NSPS Subpart OOOO (“Quad O”)
Leak Detection and Repair
Greenhouse Gas (GHG) Inventory/Reporting
Optical Gas Imaging with Infrared Cameras
15. 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
16. 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
17. 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
19. Today’s Agenda
NSPS Subpart OOOO (“Quad O”)
Leak Detection and Repair
Greenhouse Gas (GHG) Inventory/Reporting
Optical Gas Imaging with Infrared Cameras
20. 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
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…”
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 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
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
30. 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)
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 Subpart OOOO (“Quad O”)
Leak Detection and Repair
Greenhouse Gas (GHG) Inventory/Reporting
Optical Gas Imaging with Infrared
Cameras
38. FLIR GF 320 Basics
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 of the GF320
Highway Safety
Raw Materials Monitoring
Airport Security
Medical
Veterinary
Building Inspection
Electrical
41. 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
Editor's Notes
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.
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.
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.
Obviously Mark Twain was a man before his time. Isn’t it amazing that Mark Twain had some much insight into our regulatory world?
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.
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.
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
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.
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.
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?
Now let’s talk about leak detection and repair programs.
- 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.
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.
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.
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
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.
The methods described in section 98.234(a) will also be implemented in Subpart RR – CO2 Geological Sequestration.
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.
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.
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.
Monitoring the Equipment leaks and vented emissions are very interesting in the subpart.
Monitoring the Equipment leaks and vented emissions are very interesting in the subpart.
If your facility injects any amount of CO2 for long-term containment in subsurface geologic formation you must report.
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.
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
Cost of methane from U.S. Energy Information Administration. Methane citygate price = $5.14 per thousand cubic feet