De-mystifying GHG Monitoring and Reporting - Achieve Benefits from Compliance

Transcription

1 De-mystifying GHG Monitoring and Reporting - Achieve Benefits from Compliance Patrick Truesdale Senior Consultant Emerson Process Management Standards Certification Education & Training Publishing Conferences & Exhibits

2 Presenter Patrick Truesdale is a Senior Consultant with Emerson Process Management's Industry Solutions Group. Has 40 years of experience in applying Information, Automation, and Control Technologies across different industry segments. Patrick holds a BS EE from North Carolina State University at Raleigh. He is a Registered Professional Engineer; a Senior Member of ISA. 2

3 Presentation Objectives Background and challenges Highlights of Greenhouse Gas Mandatory Reporting Rule (GHG MRR) Overview of Subpart A: General Provisions Overview of Subpart C: Stationary Combustion Units Several Industry specific requirements Green facilities of the future? Automation impact Energy and carbon management impact Wrap-up

4 Global Warming: Fact or Fiction? 1. Greenhouse gas/effect dates to Fourier (1824) 2. CO2 is not a pollutant but a plant food; halting all combustion will not measurably affect atmospheric CO Are cows the cause of warming? Methane/yr for each cow is equivalent to ca. 2,300 kg CO2/yr agriculture is responsible for 18% of the total release of greenhouse gases worldwide.. 2 ) 4. A $1 gasoline price increase would reduce obesity and save 16,000 lives and $17 billion/year 3 Interesting debate points BUT reality is: Energy efficiency projects are TRIPLE WINNERS!!! 1. Reduce Costs, 2. Improve Safety, and 3. Aid Regulatory Compliance reduce emissions 1. Pierre R. Latour PhD. PE 3 rd Industry Forum, Hydrocarbon Processing, Houston, Dec. 3, Published on Time for change ( 3. Charles Courtemanche, Washington University, St. Louis, Sept. 10, 2007

5 Emissions Defined What s Important? Combustion Process Fugitive

6 GHG Regulatory Activity Past, Present, and Future Endangerment Finding Proposal 4/2009 GHG Inventory 1 Proposed 4/2009 GHG NSR Permit Proposal 10/2009 GHG Inventory 1 Final 10/2009 GHG Inventory 1 Effective 1/2010 GHG Inventory 2 Proposed 3/2010 GHG Inventory 2 Final 2Q/2009 GHG Inventory 2 Effective 1/ CAFÉ/Tailpipe Rule Proposed 9/2009 CAFÉ/Tailpipe Rule Final 2Q/2009 CAFÉ/Tailpipe Rule Effective 2012????? Cap and Trade Other RFS-2 Proposed 5/2009 Endangerment Finding Final 12/2009 RFS-2 Final 4Q/2009 RFS-2 Effective 1/2010 GHG Permitting (PSD and NSPS) 1/2/2011

7 What are GHG s? How quantified? Reporting only mandatory: Kyoto six: CO 2, CH 4, N 2 O, HFCs, PFCs,SF 6,, Other fluorinated gases: NF 3, HFEs Convert to CO 2 e using GHG i x GWP i i=1,n GWP=Global Warming Potentials GWP=Global Warming Potentials CO 2 = 1 CH 4 = 21 N 2 O = 310 HFC23 = 11,700 PFC14 = 6,500 SF6 = 23,900 No Limit Controls (Yet)

8 Is your facility on the list? exceeds the 25,000 mt/yr threshold? Oil and Gas Stationary Combustion Landfills 2551 NG and NGL Suppliers 1502 Electricity Generation 1108 Pulp and Paper 425 Petroleum Product Suppliers 315 Industrial GHG Suppliers Petroleum Refineries Iron and Steel Cement Production 107 Others Nitric Acid Glass Injection and GS of CO2 Petrochemical Lime Silicon Carbide HCFC 22/HFC 23 Adipic Acid Soda Ash Zinc Titanium Dioxide Ferroalloy Lead CO2 Suppliers Aluminum Phosphoric Acid Ammonia Hydrogen

9 How are facilities affected? All-in Source Categories Limited Applicability Source Categories Supplier Source Categories No CO2eThreshold CO2eThreshold = 25,000 mt CO2eThreshold = 25,000 mt (D) Electricity Generation (1,108) (E) Adipic Acid Production (F) Aluminum Production (G) Ammonia Manufacturing (23) (H) Cement Production (107) (O) HCFC-22 Production and HFC-23 Destruction (S) Lime Manufacturing (89) (V) Nitric Acid Production (45) (HH) MSW Landfills (2,551) (X) Petrochemical Production (80) (Y) Petroleum Refineries (150) (Z) Phosphoric Acid Production (BB) Silicon Carbide Production (CC) Soda Ash Production ( EE) Titanium Dioxide Production (K) Ferroalloy Production (N) Glass Production (55) (P) Hydrogen Production (41) (Q) Iron and Steel Production (121) (R) Lead Production (U) Use of Carbonates (W) Oil and Gas Facilities (3,087) (AA) P&P Manufacturing (425) Misc 1 (GG) Zinc Production Stationary Combustion Source Categories CO2eThreshold = 25,000 mt (C) Stationary Fuel Combustion (3,000) (LL) Suppliers of Coal-based Liquid Fuels (MM) Suppliers of Petroleum Products (315) (NN) Suppliers of Natural Gas and Natural Gas Liquids (1,502) (OO) Suppliers of Industrial Greenhouse Gases (167) (PP) Suppliers of Carbon Dioxide (13) (RR) CO2 Injection and Geologic Sequestration (80) In effect 1 January Food, ethanol production, manure manufacturing

10 What about SubPart JJ: Manure Management? NOTE: EPA will not be implementing subpart JJ of Part 98 using funds provided in its FY2010 appropriations or Continuing Appropriations Act, 2011 (Public Law ), due to a Congressional restriction prohibiting the expenditure of funds for this purpose.

11 Who must report? START Facility has category in Table 1 1? yes Report GHGs from all source categories covered by rule. no Facility has category in Table 1 2? yes CO 2 e from Table 1 2 sources, stationary combustion, carbonate use 25,000 mt? yes Report GHGs from all source categories covered by rule. no no Is facility-wide max. rated heat input for stationary combustion < 30 mmbtu/hr? no Is stationary combustion CO 2 e 25,000 mt? yes yes No reporting needed Report GHGs per instructions for stationary source combustion Notes: 1. Reference EPA document No.430-F R reference 40 CFR 98, subpart A 1 September CO 2 emissions from combustion of biogenic fuels is not counted towards the CO 2 e threshold. no No reporting needed

12 How much is 25,000 CO2e mt/yr? (Annual Equivalents) 459,000 mscf Nat Gas 1 combusted 61,500 mscf vented (methane 2 value) = $245,000 3 Natural Gas Boiler, furnace or heater (NG): 30MM Btu/hr 2,500,000 gal road diesel combusted 2,850,000 gal motor gasoline combusted 10,680 mt industrial grade coal combusted 85,580,000 kwh standard grid electricity 74,750,000 regular automobile miles 111,150,000 motorcycle miles (>500cc gasoline) 8,930,000 hamburgers (single patty + bun) 4 Waste gas Note: 1. Pipeline grade gas, 99% combusted 2. Global warming of methane = Methane valued at $4 per mcf 4. Excludes all transport plus other manufacturing of condiments, paper, etc.

13 Subpart A: General Provisions 1. Monitoring Plan Requirements 2. Meter Calibrations 3. Recordkeeping Requirements 4. Certification Requirements

14 Subpart A: Meter Calibrations What is required. Calibration procedures: Approved test method given in rule, or Manufacturer s recommended procedure, or Industry standards specified in rule Calibration Frequency: Initial Start (unless shutdown is required or within acceptable frequency since last calibration) Subsequent calibrations: Annually, Manufacturer s recommended practice, or Industry standard Accuracy within 5% Billing meters exempted from QA requirements

15 Subpart A: Recordkeeping What is required. 1. List of all units/operations for which GHG emissions are calculated 2. Data used for calculations by fuel or material type Facility operating or process data used Actual GHG emissions calculations and methods Analytical results for HHV, CC, fuel or feedstock parameters 3. Annual GHG report 4. Missing data computations 5. Written GHG Monitoring Plan Retain for 3 years

16 Subpart C: Stationary Fuel Combustion Broad definition: devices that combust solid, liquid, or gaseous fuel to either: Produce electricity, steam, heat, or other useful energy Reduce the volume of combustible matter Note 1: does not include portable equipment, emergency equipment, flares (unless covered in other subparts), and hazardous waste combustion (unless co-fire listed fuel) Note 2: if unit <250MMBtu/hr, only have to report if fuel is listed in Table C-1 What is covered: CO 2, CH 4, N 2 O from each fuel combustion unit Report separately for each fuel Aggregation of combustion sources using common fuel is allowed, but units over 250 MMBtu/hr must be broken out separately

17 Subpart C: Stationary Fuel Combustion Calculation Methods Device Type For Fuel Types Measure Parameters Use Default Factors Tier 1 250mmBTU/hr Biogenic fuels All in Table C-1 except MSW generate steam Annual Fuel Use Default EF Default HHV Tier 2 250mmBTU/hr NG/Distillate Oil bio/fossil fuels All MSW Annual Fuel Use HHV Steam Generation Default EF Tier 3 250mmBTU/hr No NG/Distillate Oil Any fuels 10% Refinery fuel gas 1 Solid/liquid Gas Annual Fuel Use Carbon Content Annual Fuel Use Carbon Content Molecular Weight -- Tier 4 CEMS Other conditions All CO2 -- Note: 1. Conflict between Preamble, Subpart C, and Subpart Y (Petroleum Refineries); Tier 1 & 2 not allowed for Refineries.

18 Subpart Y: Petroleum Refinery Emission Sources Refinery Sources CO2 CH4 N2O Stationary combustion C C C Flares Y Y Y Catalytic cracking Y Y Y Traditional fluid coking Y Y Y Fluid coking with flexicoking design C/Y C/Y C/Y Delayed coking Y Catalytic reforming Y Y Y Onsite and offsite sulfur recover y Y Coke calcining Y Y Y Asphalt blowing Y Y Equipment leaks Y Storage tanks Y Other process vents Y Y Y Uncontrolled blowdown systems Y Loading operations Y Hydrogen plants (nonmerchant) P P C = 40 CFR part 98, subpart C (General Stationary Combustion Sources). P = 40 CFR part 98, subpart P (Hydrogen Production). Y = 40 CFR part 98, subpart Y (Petroleum Refineries). = Reporting from this process is not required.

19 Subpart W: Oil and Gas Facilities Started 1 January 2011 Broad definition 8 segments: 1. Onshore petroleum and natural gas production 2. Offshore petroleum and natural gas production 3. Onshore natural gas processing plants 4. Onshore natural gas transmission compression 5. Underground natural gas storage 6. Liquefied natural gas storage 7. Liquefied natural gas import and export equipment 8. Natural gas distribution What is covered: CO 2, CH 4, N 2 O Direct and Upstream Emissions Process Combustion Fugitive

20 Subpart W: Oil and Gas Facilities Sources for all Segments Natural gas pneumatic high bleed device venting Natural gas pneumatic low bleed device venting Natural gas driven pneumatic pump venting Well venting for liquids unloading Gas well venting during conventional well completions Gas well venting during unconventional well completions Gas well venting during conventional well workovers Gas well venting during unconventional well workovers Gathering pipeline fugitives Onshore production and processing storage tanks Transmission storage tanks Reciprocating compressor rod packing venting Well testing venting and flaring Associated gas venting and flaring Coal bed methane produced water emissions Enhanced Oil Recovery injection pump blowdown Produced water dissolved CO2 Acid Hydrocarbon liquids dissolved CO2 Centrifugal compressor wet seal degassing venting Gas removal vent stack Dehydrator vent stacks Other fugitive emissions Blowdown vent stacks shutdown & start-up bypass Flare stacks Above ground meter regulators and gate station fugitives Below ground meter regulators and vault fugitives Pipeline main fugitives Service line fugitives

21 Benefits from GHG Compliance 1. Enhance loss control (business process and procedures) Follow well-established measurement standards and fiscal controls Custody, Sarbanes Oxley, (Weight & Measure), etc Customs and Excise (Foreign Trade Zone), Alcohol Tax (ethanol), etc Mass and energy balances Establish and monitoring KPI s 2. Enhance key equipment performance Control loops Measurement systems Identify and repair leaks 3. Improve energy efficiency/emission recovery Furnaces/Heaters Distillation Columns Vapor Recovery/Waste Treatment

22 Creating Value while reducing GHG Emissions Mass Balance Accuracy Loss Category Measured % 1 Reality % 1. Custody transfer (receipt, shipments) 2. Flare, evaporation, spills/leaks, FCC coke make calculation, carbon dioxide, other 0.5 to to Fuel/H2 internal production and consumption (understated or overstated) not real oil loss but affects overall balances! 1.1 to Total 2.0 to Note: 1. Mass Basis converted from volume data ,000 BPD; 5.8MM BTU/Bbl; $7 MMBTU; Tier 1 Calc; No CO2 trading credits

23 Creating Value while reducing GHG Emissions Combustion (Process Heater) Damper Actuator HIC 353D PIC 359D PIC 357D Feed TI 066 FIC H306 FIC 102 Draft Pressure PI FIC 103 TI 072 TI 073 TI 071 AIC CO Analyzer 354D Product AIC 356DO2 Analyzer TIC TI 362D 067 TI Tube 069 Temperature TI 069 TI 043 FIC 104 TI TI TIC 361 Key Operating Objectives Constant outlet temp Min excess air Maintain within constraints PIC 360B PIC 360A FIC 361 BTU AI 360 Fuel Item CO2e (MT/yr) Natural Gas Flow (scf/hr) Natural Gas Flow (Mscf/yr) Before Energy Savings 44, , ,121 After Energy Savings 44, , ,949 Delta ,171 Savings $ 893 $ 6,809 $ 57,198

24 Creating Value while reducing GHG Emissions Combustion (Boiler) Figure 4 Desired O 2 Setpoint vs. Steam Load, f 3 (x), for Boiler 3 Burning Gas % Excess O Original Setpoint New Setpoint Actual Data f 3 (x) for Boiler 3 for Gas Full Scale Desired O2 Setpoint 250 X Old Y New Y Steam Steam Original New KPPH % Steam Setpoint Setpoint % Steam Flow 125,000 lb/ hr 400 psig steam; 1% Fuel Savings; $140,000 per year ($7/ MMBTU)

25 Creating Value while reducing GHG Emissions Process Energy Consumers Over 40,000 distillation/fractionation columns in the US alone Consume 40% - 60% of the total energy used in refining and chemical industry Consume 19% of the total energy used in manufacturing industry in the US Consume 6% of total US energy usage Note: In addition to energy benefits secondary benefits are achievable from better control of qualities. Reference: Distillation Column Modeling Tools Office of Industrial Technology: Energy Efficiency and Renewable Energy; US Department of Energy Washington, DC

26 Case Study Gulf Coast Chemical Plant Complicated OH condenser system Internal Reflux From F690 From F605 T C TI Lt Ends This flow sets the material balance (D/F) At constant OH rate, this temp sets the energy balance (R/F). Ultra-high purity product specifications requires tight quality controls Over 40,000 distillation and fractionation columns in the US alone Multiple large, 200+ tray columns with extremely long time constants Large energy consumer Different feedstock suppliers with different qualities unloaded from railcars Bottoms to D103/104

27 Case Study Distillation Column Example Controller ON Isoprene loss in Overhead Overhead Rate Results Reduced average isoprene loss by 22% Reduced steam usage 7% Improved capability to handle disturbances: feed quality, and meet tight specifications Total benefit: > $700K/year

28 Oil and Gas Systems Separator Skid Cryogenic Dehydrators Compressor Skid

29 Creating Value while reducing GHG Emissions Industry Opportunity CH4 Emissions by Sector in Oil & Gas Industry CY2003 (Bcf) 68 Assume CH4 = $6/mmbtu 10% recovered in Production Sector Benefit = $91,000, Production Sector Processing Sector Transmission Sector Refrigeration Compressor Distribution Sector Vapor Recovery CH4 Emissions by Category in Production Sector CY2003 (Bcf) Pneumatic Devices Other Sources 61 Well Venting & Flaring Dehydrators & Pumps Gas Engine Exhaust Meters & Pipeline Leaks Storage Tank Venting 1.

30 Creating Value while reducing GHG Emissions Recovering CH4 Action Avg. CH4 Savings/device 1 MSCF/yr $/yr 1. Replace high-bleed devices 2 Controllers (liquid and pressure) 315 2,200 Positioners and transducers Retrofit bleed reduction kits 315 2,200 Most high-bleed controllers 3. Maintenance to reduce losses Repair/retune Reduce supply pressures Note: CFR 98 Subpart W (Oil and Gas Systems) implementation deferred until final review/comments. 2. John Mangan, Process Control goes Green, Valve Magazine, Winter EPA Natural Gas STAR Program

31 The Future Why is accuracy important? $100 $90 $80 $70 $60 $50 $40 $30 $20 $10 $0 Small Facility (25,000 tpy) Large Facility (1,000,000 tpy) Projected cost of carbon allowances (in 2005 constant dollars) Source: EPA preliminary analysis of Waxman-Markey $1,250,000 Value at Risk $50,000,000 Value at Risk

32 Facilities of the future? Facilities need equipment and service solutions now: not to just comply BUT to achieve benefits while complying Energy efficiency will justify projects that will lead to compliance Best Available Control Technology (BACT) emerging Measurements, energy efficiency, low bleed instruments, instrument air, vapor recovery units, low bleed compressor packing, etc. Operating, maintenance, and fiscal control practices and procedures evolving: Gas capture - blow-downs/start-up events, vent capture, etc. More attention to uptime and reliability Meter verification and calibration Verifiable and auditable trading values?

33 Closing Thoughts And Prediction Does History Repeat Itself? In 1970, the EPA and Clean Air Act started the Train. The Train refueled in In 1997, the Kyoto Protocol joined this Train. In 2010, the USA started boarding with GHG MRR. Will it be with planning and economics in mind? i.e. The Pacesetter Or, will it be with uncertainty, inaction, and wait-and-see? i.e. The Laggard or Lead-Follower

34 Thank You Questions?