EPA s Methane Agenda Will the Oil & Gas NSPS OOOOa Regulation Affect Other Sectors? Presented By: Jay Christopher Trihydro Corporation

Transcription

1 EPA s Methane Agenda Will the Oil & Gas NSPS OOOOa Presented By: Jay Christopher Trihydro Corporation

2 Why Should Other Sectors Care About Oil & Gas NSPS Requirements? Methane is not a big issue to us, isn t that what this rule is all about?

3 Why Should Other Sectors Care About Oil & Gas NSPS Requirements? Methane is not a big issue to us, isn t that what this rule is all about? Not exactly.

4 Why Should Other Sectors Care About Oil & Gas NSPS Requirements? EPA often uses precedent in many different ways. The rule has several issues that could become precedent setting for the other industry sectors. While we all have plenty to worry about (that is why we are here this week), we need to pay attention to these other issues.

5 Why Should Other Sectors Care About Oil & Gas NSPS Requirements? Topics where NSPS OOOOa may establish, directly or indirectly, some important precedents affecting other sectors: Leak detection and repair programs NSPS General Provisions, particularly around modification and affected facilities Methane Next Generation Compliance

6 NSPS OOOOa Background New Source Performance Standards (NSPS) Subpart OOOOa Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification, or Reconstruction Commenced After September 18, 2015 Proposed on September 18, 2015; final on June 3, 2016; effective date August 2, 2016 NSPS VVa level of control for VOC and methane for new, modified, and reconstructed equipment, except optical gas imaging is preferred method Expanded the NSPS OOOO source category (e.g. oil well completions, pneumatic pumps, and fugitive emission components at well sites and compressor stations) Incorporates Next Generation compliance tracking, verification, and electronic reporting requirements

7 Leak Detection and Repair (LDAR) Here s a new acronym for you BSER

8 Leak Detection and Repair (LDAR) Best System of Emissions Reduction Clean Air Act Section 111(a)(1) defines a standard of performance as (A) standard for emissions of air pollutants which reflects the degree of emission limitation achievable through the application of the best system of emission reduction which (taking into account the cost of achieving such reduction and any non-air quality health and environmental impact and energy requirement) the Administrator determines has been adequately demonstrated.

9 LDAR OOOOa BSER Determinations Source Fugitive emissions from well sites and compressor stations Equipment leaks at natural gas processing plants BSER Well Sites: Monitoring and repair based on semiannual monitoring using optical gas imaging (OGI) Compression Stations: Monitoring and repair based on quarterly monitoring using OGI Leak detection and repair at 40 CFR part 60, subpart VVa level of control Final Standards of Performance for GHGs and VOCs Monitoring and repair of fugitive emission components using OGI with Method 21 as an alternative at 500 ppm A monitoring plan must be developed and implemented and repair of the sources of fugitive emissions must be completed within 30 days of finding fugitive emissions Follow requirements at NSPS part 60, subpart VVa level of control as in the 2012 NSPS

10 What Should We Pay Attention to Regarding LDAR and BSER? As BSER, optical gas imaging (OGI) is not just favored over Method 21, OGI is now recognized as a demonstrated emission reduction technology. EPA abandoned skip period monitoring and specifies fixed monitoring frequencies (semiannual for well sites, quarterly for compressor stations), regardless of performance. EPA selected 500 ppm as the Method 21 leak rate if using Method 21 for initial or follow-up monitoring in lieu of OGI, based on the concept that a camera can sometimes see leaks under 10,000 ppm.

11 LDAR Emissions Monitoring Plans Frequency of monitoring. Methodology (OGI or Method 21). Instrumentation information (manufacturer and model number). Procedures and timeframes for identifying and repairing fugitive emissions components from which fugitive emissions are detected, including timeframes for fugitive emission components that are unsafe to repair. Procedures to verify component repairs. Records that will be maintained under the monitoring program. Site map A defined observation path that ensures fugitive emissions components are within sight of the path. The observation path must account for interferences. If using Method 21, a list of equipment to monitored and how components will be identified in the field (i.e., tagging, P&ID drawings, etc.). A written plan for all of the fugitive emission components designated as difficult-to-monitor. A written plan for fugitive emission components designated as unsafe-tomonitor.

12 LDAR Emissions Monitoring Plans (there s more!) If using OGI: Verification that OGI equipment meets specification in the regulation. Ability to image the gases in the spectral range for the compound of highest concentration. Capable of imaging a 50% methane/50% propane gas with a 10,000 ppm concentration at a flow rate of 60 grams/hour from a ¼-inch diameter orifice. Initial and daily camera verification checks. Procedure to determine the operator s maximum viewing distance from equipment and ensure that this distance is maintained. Procedure to determine maximum wind speed during which monitoring can be performed to ensure monitoring occurs only at wind speeds below this threshold (EPA does not specify this wind speed). Procedure to ensure an adequate thermal background is present. Procedure to deal with adverse monitoring conditions. Procedure to deal with adverse interferences (e.g., steam). Training and experience needed to perform surveys. Procedures for calibration and maintenance.

13 LDAR OGI Recordkeeping Date of the survey Beginning and end time of the survey Name of operator(s) performing survey Training and experience of the operator Monitoring instrument used Ambient temperature Sky conditions Maximum wind speed Any deviations from the monitoring plan or a statement that there were no deviations from the monitoring plan

14 Other LDAR Topics Delay of Repair DOR until next scheduled shutdown or two years maximum Repairs required if there is an unscheduled or emergency shutdown Repair Timeframe 30 days to complete repair, additional 30 days to remonitor Repair Verification If using OGI, then no visible emissions; if Method 21, then < 500 ppm Soap bubble test specifically recognized to verify repair

15 General Provisions Modification Explicit definitions for some scenarios (addition of a new compressor or increase in horsepower at a compressor station; drilling a new well at an existing well site; and more. The trigger does not specifically require an emissions increase. If accomplished without capital expenditure, then not a modification, but: EPA changed the General Provisions calculation to determine capital expenditure very conservatively. Asset guideline repair allowance ( B value) set at 4.5 Base year in calculation fixed at 2011

16 Affected Facility In OOOOa, EPA is pushing to smaller affected facilities. In OOOOa, affected facilities are each individual: Centrifugal compressor Reciprocating compressor Continuous bleed natural gasdriven pneumatic controller not located at a natural gas processing plant with a natural gas bleed rate greater than six standard cubic feet per hour Continuous bleed natural gasdriven pneumatic controller at a natural gas processing plant Storage vessel with the potential to emit six tons per year or more of VOC (and storage vessels are viewed as once in/always in) Natural gas-driven pneumatic diaphragm pump at a natural gas processing plant Natural gas-driven pneumatic diaphragm pump in operation 90 days or more located at a well site

17 Methane Methane is part of NSPS OOOOa, but does not change implementation of LDAR that much. Equipment has to be in VOC service, and then methane is included. Residue (or dry) gas by itself is not directly controlled. Another instance where a greenhouse gas (methane) is a regulated pollutant under the Clean Air Act.

18 Next Generation Compliance Thus EPA s Next Generation Compliance and rule effectiveness strategies, in and of themselves, impose no requirements or obligations on the regulated community. The strategies establish no regulatory terms for any sector or facility nor create rights or responsibilities in any party. Rather, the strategies describe general compliance assurance and regulatory design principles, approaches, and tools that EPA may consider in conducting rulemaking, permitting, and compliance assurance, and enforcement activities [EPA Subpart OOOOa preamble language, 81 FR 35884, June 4, 2016].

19 Next Gen (type) Requirements in OOOOa Establishes OGI as a BSER (seems precedent setting). Alarms on bypass lines that could route a regulated stream away from a control device, alarmed to the nearest field office location. Performance testing of control devices by either the operator or the manufacturer (flares or combustors commonly used at oil and gas production facilities). Performance test reports submitted via EPA s Electronic Reporting Tool, CEDRI (similar to Refinery Sector Rule.

20 Next Gen (type) in OOOOa (con t) Closed vent system designs (for venting storage vessels to a control device) must be certified by a qualified professional engineer (PE). Pneumatic pump emissions at an oil and gas site must be routed to an existing control device or back to the process. If infeasible, there are significant documentation requirements, including certification of technical infeasibility by a qualified PE. Documentation that oil and gas well completion operations were properly controlled with appropriate control devices (reduced emission completion, or REC) by including digital pictures with geolocations in the annual report (this is an alternative to more conventional reporting).

21 Next Gen That Did Not Make the Final Cut 3rd-party verification of the adequacy of closed vent system design (instead of relying on PE certification). Electronic submittal of LDAR (OGI or Method 21) semiannual reports. Once the Electronic Reporting and Recordkeeping proposed rule (March 20, 2015) goes final, this reporting requirement will happen. Require leak detection and repair programs to undergo regular third-party audits, and that the facilities had to certify that the auditors were both competent and independent.

22 Presenter Jay Christopher Senior Scientist Specialist

23 Questions? WHAT WHY WHERE WHEN WHO HOW