Federal GHG Reporting Rule

Transcription

1 innovative environmental solutions, inc. INGAA Foundation 2010 Spring Meeting Federal GHG Reporting Rule EPA Re-Proposal of Subpart W: Petroleum and Natural Gas Systems San Antonio, TX April 9, 2010

2 Topics Requirements for Transmission and Storage: EPA Reporting Rule and Subpart W Background Natural Gas Industry Sectors Covered Applicability Sources for Transmission and Storage Methods and Monitoring Reporting Schedule

3 EPA GHG Reporting Rule Background In FY2008 Appropriations Bill, Congress provided funding for EPA to require mandatory reporting of GHG emissions above appropriate thresholds in all sectors of the economy of the United States. April 2009 Proposed Rule included natural gas systems in 40 CFR, Part 98» Combustion emissions (Subpart C)» General provisions (Subpart A)» Natural gas systems fugitive and vented (Subpart W)» Applicability threshold of 25,000 metric tons CO 2 equivalent» EPA received extensive comments on Subpart W October 2009 Final Reporting Rule excluded Subpart W» 2010 combustion emissions reporting required by 3/31/2011

4 Subpart W: 2009 Primary Comments Rule uses emission factors or readily available information for most industries» Measurement burden results in inequity for natural gas sector EPA descriptions of measurement procedures are informal and do not reference standard protocols» Standard, refereed methods are not available» Description of procedures are ambiguous in many cases» Undefined methods will cause implementation uncertainty Uncertainty in determining whether facility >25,000 tonnes» Measurement may be needed to confirm exempt status» Exemption based on estimate with safety margin should be defined If measurement is required, it should focus on components more likely to leak; use statistical sampling to reduce monitoring frequency at any single facility

5 Subpart W Re-Proposal EPA signature version of Subpart W released on 3/23/10 and appeared in FR on 4/12/10» 60 day comment period ending 6/11/10 EPA added two new sectors to cover well to burner tip» Offshore petroleum/natural gas production Onshore petroleum and natural gas production (new)» Onshore natural gas processing» Natural gas transmission compressor stations» Underground natural gas storage» LNG storage» LNG import/export facilities Natural gas distribution (new) EPA also proposed Subpart RR for CO 2 injection and geological sequestration (e.g., enhanced oil & gas recovery)

6 Subpart W Re-Proposal Today s focus is Transmission and Storage, but Facility definitions for production and distribution are broad-based and not consistent with other air rules: Onshore petroleum and natural gas production facility means all petroleum or natural gas equipment associated with all petroleum or natural gas production wells under common ownership or common control by an onshore petroleum and natural gas production owner or operator located in a single hydrocarbon basin as defined by the American Association of Petroleum Geologists which is assigned a three digit Geologic Province Code. Where an operating entity holds more than one permit in a basin, then all onshore petroleum and natural gas production equipment relating to all permits in their name in the basin is one onshore petroleum and natural gas production facility. Natural gas distribution facility means the distribution pipelines, metering stations, and regulating stations that are operated by a Local Distribution Company (LDC) that is regulated as a separate operating company by a public utility commission or that are operated as an independent municipallyowned distribution system.

7 Subpart W: Applicability Applies to all sectors of natural gas industry Facility subject if actual emissions >25,000 tonnes CO 2 e» For 2010, only Combustion emissions are reported for T&S ~5000 hp of recip engines running 24/7 exceeds 25k tonnes» Once Subpart W applies, include combustion, vented, and fugitive emissions in this applicability determination Fugitive and vented emissions can comprise over 50% of total emissions at some facilities» Uncertainty in fugitive emissions (and vents associated with compressor rod packing, etc.), so emission estimate to determine facility exemption is not straightforward» INGAA 2009 comments requested simplified exemption criteria with safety margin to facilitate determination for smaller facilities; Comment not addressed in 2010 proposal

8 Subpart W Emission Sources to Report Gas transmission compressor station sources to report include: (1) Reciprocating compressor rod packing venting (2) Centrifugal compressor wet seal degassing venting (3) Transmission storage tanks (4) Blowdown vent stacks (5) Natural gas pneumatic high bleed device venting (6) Natural gas pneumatic low bleed device venting (7) Fugitive emissions from connectors, block valves, control valves, compressor blowdown valves, pressure relief valves, orifice meters, other meters, regulators, and open ended lines Note: For comparison, onshore production facilities require reporting for 21 source types

9 Subpart W Emission Sources to Report Natural gas storage facility sources to report include five of seven source types for compressor stations: (1) Reciprocating compressor rod packing venting (2) Centrifugal compressor wet seal degassing venting (3) Natural gas pneumatic high bleed device venting (4) Natural gas pneumatic low bleed device venting (5) Fugitive emissions from connectors, block valves, control valves, compressor blowdown valves, pressure relief valves, orifice meters, other meters, regulators, and open ended lines LNG storage facilities include (1), (2) from above and:» fugitive emissions from valves, pump seals, connectors vapor recovery compressors, and other fugitive sources

10 Subpart W Emission Estimation Methods Transmission Sources Estimation Methods from Rule Preamble Emission Source Monitoring Method Emission Quantification Method Natural Gas Pneumatic Bleed Devices (High or Continuous) Natural Gas Pneumatic Bleed Devices (Low) Blowdown Vent Stacks Condensate Tanks (Transmission) Centrifugal Compressor Wet Seal Oil Degassing Vent Large Reciprocating Compressor Rod Packing Vents Large Compressor Blowdown Valve Leak Large Compressor Blowdown Vent (Unit Isolation Valve Leak) Fugitive Sources Engineering Estimation Component Count Engineering Estimation Direct Measurement (flow measurement) Direct Measurement (flow measurement) Direct Measurement (flow measurement) Leak Detection with optical gas imaging instrument Leak Detection with optical gas imaging instrument Leak Detection with optical gas imaging instrument Manufacturer device model bleed rate x operating hours (for each device) Population emission factor x component count Equipment specific emission factor (based on volume, T, P) x number of events Flow metered emission factor x operating hours (if vent losses detected) Flow metered equipment specific emission factor x operating hours Flow metered equipment specific emission factor x operating hrs (by operating mode) Flow metered equipment specific emission factor x operating hours Flow metered equipment specific emission factor x stand-by depressurized hours Leaker emission factors x operating hours (count is for leaking components detected )

11 Subpart W: Measurement and Monitoring Methods Vent flow measurement required for vent lines tied to recip rod packing or centrifugal compressor wet seals» Measure via permanent meter or once/year measurement» Recip rod packing vents must be measured in three separate modes Operating Standby and pressurized Not operating and de-pressurized» Emissions updated annually based on metered rate and hours of operation (by mode for recip compressors) Fugitive leaks are estimated based on Emission Factors from Canadian study and require leak survey and count of leaking component by type» Leak rate measurement is not required

12 Subpart W Leak Monitoring Emission factors provided for nine component types:» Connectors» Block valves» Control valves» Compressor blowdown valves» Pressure relief valves» Orifice meters» Other meters» Regulators» Open ended lines Facility screening with Optical Imaging Instrument is required using an Alternative Work Practice developed for refineries from 40 CFR, Part 60» i.e., screen with infrared camera to identify & count leaks

13 Subpart W Leak Monitoring Optical Imaging is required» Other methods are available and used for leak screening (e.g., acoustical instruments, OVA, soap bubbles) but EPA mandates Optical Imaging Instrument» Camera cost ~$100k (equipment cost only)» Camera can be overly sensitive but also has limitations related to background, ambient temperature, moisture» Expertise for screening and component count is limited» Emission factors and calculation basis will be reviewed to understand whether (and to what degree) this approach improves uncertainty relative to lower cost options Other emission factors (e.g., GRI study per INGAA Guidelines, ongoing EPA sponsored study with UTx) are not allowed

14 Subpart W Reporting Annual Report due by March 31 of the following year» Report emissions of CO 2, CH 4 and CO 2 e Emissions must be reported for each sector and source type with emissions aggregated by source type in most cases» e.g., aggregate rod packing vent emissions from all recip compressors» Activity data must also be reported» Throughput for compressors (by type) must be reported Facility minimum, maximum and average throughput must be reported Fugitive survey records (e.g., IR camera video) must be retained

15 Subpart W Schedule Federal Register publication is imminent 60 days from publication to submit comments INGAA comment coordination and development has been initiated Basis for EPA decisions will be reviewed» Meeting(s) with EPA are planned» When available, docket material will be reviewed» Basis for limitations and exclusions adopted by EPA will be reviewed Final Rule anticipated in late summer or early fall Significant industry-wide burden is imposed with aggressive implementation schedule required to meet March 2012 reporting deadline