avoid air-rors! discuss the air regulations that impact oil and gas development
DESCRIPTION
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 CamerasTRANSCRIPT
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 [email protected]/815-9583
Il KimChemical Engineer, Air & Process [email protected]/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)
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 [email protected]/815-9583
Il KimChemical Engineer, Air & Process [email protected]/745-7474