avoid air-rors! discuss the air regulations that impact oil and gas development

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

January 29, 2014Jay Christopher

Il Kim

Today’s PresentersJay Christopher Business Unit Manager, Air & Process Servicesjchristopher@trihydro.com303/815-9583

Il KimChemical Engineer, Air & Process Servicesikim@trihydro.com307/745-7474

Today’s Agenda

NSPS Subpart OOOO (“Quad O”) Leak Detection and Repair Greenhouse Gas (GHG) Inventory/Reporting Optical Gas Imaging with Infrared Cameras

The more you explain it, the more I don’t understand it.

-Mark Twain

NSPS Subpart OOOO (“Quad O”) Leak Detection and Repair Greenhouse Gas (GHG) Inventory/Reporting Optical Gas Imaging with Infrared Cameras

Today’s Agenda

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

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

What is Covered Under NSPS OOOO?

Primary Impacts from Quad O Natural Gas Production

Hydraulic Fracturing - Green Completions

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)

Also, significant recordkeeping and reporting requirements.

Gas Plants (tighter LDAR requirements)

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

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

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?

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

NSPS Subpart OOOO (“Quad O”) Leak Detection and Repair Greenhouse Gas (GHG) Inventory/Reporting Optical Gas Imaging with Infrared Cameras

Today’s Agenda

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

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

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

LDAR Implications

One facility can have components subject to NSPS KKK, NSPS OOOO, and MACT HH

Carefully evaluate facility changes

NSPS Subpart OOOO (“Quad O”) Leak Detection and Repair Greenhouse Gas (GHG) Inventory/Reporting Optical Gas Imaging with Infrared Cameras

Today’s Agenda

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

GHG MRR

GHG MRR

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…”

Image: Bureau of Ocean Energy Management

Subpart W – Petroleum and Natural Gas Systems

Subpart W – GHGs to Report

All industry segments under Subpart W will report the following GHGs CO2

CH4

N20 CO2, CH4, and N20 CO2e

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

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

Optical Gas Imaging

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)

Document, Report, Keep Records, Repeat

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

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

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

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

Subpart UU – Calculating CO2 Emissions

You must calculate annual mass of CO2… Received by pipeline Received in containers

NSPS Subpart OOOO (“Quad O”) Leak Detection and Repair Greenhouse Gas (GHG) Inventory/Reporting Optical Gas Imaging with Infrared

Cameras

Today’s Agenda

FLIR GF 320 Basics Theory Cooled, 320x240 Indium

Antimonide Microcooler and Cold Filter Auto, Manual, and High

Sensitivity Modes (HSM)

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

Other Applications of the GF320

Highway Safety Raw Materials Monitoring Airport Security Medical Veterinary Building Inspection Electrical

If you ask me anything I don’t know, I’m not going to answer.

-Yogi Berra

Questions?

Jay Christopher Business Unit Manager, Air & Process Servicesjchristopher@trihydro.com303/815-9583

Il KimChemical Engineer, Air & Process Servicesikim@trihydro.com307/745-7474