Air Quality and Greenhouse Gas Issues Upstream and Mid-stream O&G Sectors Information Collection Request

Transcription

1 Air Quality and Greenhouse Gas Issues Upstream and Mid-stream O&G Sectors Information Collection Request November 10, 2016 The world s leading sustainability consultancy

2 Agenda ICR Framework Preparing for ICR Part 1 execution plan Part 2 execution plan Q&A Session 2

3 ICR Framework Denise Grubert 3

4 EPA s Stated Goals of the ICR What does EPA want? Methane emissions information From ALL oil and gas industry existing sources (to some extent) About technologies available to reduce the methane emissions Costs to apply control technologies Why? Base to write new regulations on existing sources (ESPS) and the next generation of NSPS OOOO The ICR process is not optional under Section 114 of the CAA 4

5 How is the ICR Organized? Part 1 and Part 2 requests will occur at the same time Part 1: For All Upstream In! No exemptions Onshore Oil & Natural Gas Production Gathering Booster Stations & gathering Pipelines Onshore Natural Gas Processing Part 2: Sample Facilities for all Sectors Onshore Natural Gas Transmission Compression Underground NG Storage & LNG Storage & Import/Export City Gate In! Underground NG Storage & LNG Storage & Import/Export 5 Onshore Oil & Natural Gas Production Gathering Booster Stations & Gathering Pipelines Onshore Natural Gas Processing Onshore Natural Gas Transmission Compression City Gate

6 How is the ICR Organized? Part 1 and Part 2 requests will occur at the same time Part 1: For All Upstream In! No exemptions Onshore Oil & Natural Gas Production Gathering Booster Stations & gathering Pipelines Onshore Natural Gas Processing Onshore Natural Gas Transmission Compression Underground NG Storage & LNG Storage & Import/Export City Gate Part 1 will be distributed to every onshore production operator in US All wells (actively producing and temporarily shut-in) and associated major equipment by well site All associated central production facilities (as defined in the ICR) EPA using Part 1 as census data - to extrapolate data from Part 2 to entire well population 60 day response time 6

7 Part 1 for Upstream Production Operators Applicability: All known onshore production operators All production well sites and associated central production surface sites operated, including those that receive a Part 2 request What type of information is being requested? Wells at well surface sites (as defined in the ICR) Major equipment Linkage to central production sites (as defined in the ICR) Basin and County Location of each Surface Site Identification of NSPS OOOOa LDAR applicability Lat/Longs of well sites 7

8 How is the ICR Organized? Part 1 and Part 2 requests will occur at the same time Part 2 will be distributed to a sample of facilities across different industry sectors Random sample by industry sector; well sites by GOR and production (stripper and non-stripper wells) EPA using Part 2 data to develop model plants to support existing source rulemaking 180 day response time Part 2: Randomly Selected for all Sectors In! Underground NG Storage & LNG Storage & Import/Export 8 Onshore Oil & Natural Gas Production Gathering Booster Stations Onshore Natural Gas Processing Onshore Natural Gas Transmission Compression City Gate

9 Part 2 for Upstream and Midstream Operators Applicability: Select upstream and midstream facilities What type of information is being requested? Inventory Event-Based Measurements /Testing Cost Data Well Sites Tanks/Separators Pneumatics Blowdowns Flash Liberation Testing Control Costs AGRU Dehys Operation and Maintenance Costs Equipment and Component Counts Compressors Liquids Unloading Direct Measurements (if available) Leak Survey Costs Control Devices 9

10 Who will receive Part 2 ICR? EPA will send Part 2 ICR to a selection of facilities based on the following sampling approach EPA's Estimated Count of Facilities Target Number Requests to be Sent Percentage of Population Sampled, % Industry Sector Subtotal for Onshore petroleum and natural gas production facility 698,717 2, % Onshore petroleum and natural gas gathering and boosting facility 5,000 N/A 10% Onshore natural gas processing plant (or facility) % Onshore natural gas transmission compressor station 1, % Natural gas transmission pipeline facility % Underground natural gas storage facility % Liquefied natural gas (LNG) storage facility % LNG import and export facility % TOTALS 707,336 4,505 1% Onshore Production EPA will select US Well IDs based on GOR for Part 2. Gathering and Boosting Operators must identify 10% of gathering and boosting compressor station facilities and gathering and boosting pipeline facilities (new definition) using a separate Excel workbook Gathering and Boosting Tool 10

11 Details to pay attention to Definitions are specific to the ICR and do not align with other EPA programs Gathering and booting was split into two separate categories: compressor stations and gathering pipelines Delineation between facility boundaries in part 1 and Part2 (central production versus gathering and boosting) EPA added gathering lines into the definition of well surface site when connecting to central production Part 1 can be submitted electronically or by hard copy Part 2 reported in e-ggrt with fixed structure Consider submitting extension requests upon receipt Data is in multiple systems of record dealing with various stakeholders and data managers within your organization Do not have to report any data parameter already reported under subpart W 11

12 Timeline and Resource Hurdles EPA finalized deadlines for the ICR: Part 1: 60 days from receipt Part 2: 180 days from receipt 12 Q1 Reporting Periods Resource Constraints

13 Preparing for ICR Kevin Madry 13

14 Understanding of Challenges Inconsistent Data Sources Time Crunch Certification 14

15 ERM s Data Management Solution CBI Decisions Data Sources Collect Core Data Operator Production Site Facility Well Tank Compressor Counts Calcs Filters Export to Workbooks 15

16 ERM s Data Management Solution 16

17 ERM s Data Management Solution 17

18 ERM s Data Management Solution 18

19 Summary/Benefits Added Value Organized normalized data collection Logical counts, calculations More rigorous QA/QC Documented process/details Increased efficiency through multiple data paths/automated export Future Data Reuse Facility-level regulatory cost assessments Compliance planning and tracking Compilation for other regulations 19

20 Part 1 Execution Plan Lisa Campbell 20

21 Part 1 Execution - Example Schedule ICR Letters Received Part 1 Deadline Thanksgiving Holidays Activity Nov 14 Nov 21 Nov 28 Dec 5 Dec 12 Dec 19 Dec 26 Jan 2 Jan 9 Jan 16 Compliance Plan Data Systems Mapping / Gaps Well to Facility Mapping Well to Central Production Mapping Field Data Collection Data Aggregation QA/QC Reporting GHG Reporting 21 Applies to all companies with active production wells

22 Suggested Program Management Approach Now! Develop a Compliance Plan Who will be involved roles/responsibilities? What data is needed? Where is data located (systems of record)? How will data get collected/aggregated/reviewed/reported? When schedule to meet 30 day timeframe? Organize the Team Leveraging company and 3 rd party resources IT, EHS, operations/engineering, management Data Systems Mapping Systems of Record where data elements reside 22

23 Part 1 Well Mapping Well and equipment mapping exercise: Associating wells and equipment with Well Surface Sites (WSS) Identifying plugged & abandoned wells at production well sites Associating Central Production Surface Sites (CPSS) with wells/wss Do you need boots on the ground to fill data gaps? Prod Well Prod Well P&A Well WSS CPSS 23 WSS and CPSS definitions are NOT aligned with Subpart W

24 Key considerations for Part 1 60 days, including holidays!!!!!! Time lost getting to appropriate contact? Data housed in multiple systems of records Data on Plugged & Abandoned wells at production well sites Delineating between Gathering & Boosting and Central Production Surface Sites 24

25 Part 2 Execution Plan Andy Woerner 25

26 Part 2 for Upstream and Midstream Operators Inventory Event-Based Measurements/ Testing Cost Data Well Sites Tanks/Separators Pneumatics Blowdowns Flash Liberation Testing Control Costs AGRU Dehys Operation and Maintenance Costs Equipment and Component Counts Compressors Control Devices Liquids Unloading Samples Leak Survey Costs 26

27 Example Schedule Part 2 Pilot Location All Locations Activity Nov Dec Jan Feb Mar April May June Compliance Plan Project KO Training Field Data Collection Sampling / Testing > 10 bbl/day Non Field Data Collection Data Management, QA/QC Sign off & Reporting 27 GHG Reporting

28 Suggested Program Management Approach Provide Confidence to Your Management Ability to complete in tight timeframe Level of QA/QC Now! Well-Coordinated Approach Leveraging company and 3 rd party resources Develop a Compliance Plan / Road Map Clear understanding of required data Clarity on roles and responsibilities (SWIM lanes) Establish lines of communication 28

29 Suggested Program Management Approach Now - December Kick-off Meeting(s) Key stakeholders within various business segments, facilities Confirm level of resource availability / commitment Training for Field Data Collection Scope, Templates equipment / component counts Recommend pilot / dry run(s) Field Sampling Efforts Ensure Lab(s) lined up early Seek to complete any sampling as early as possible Data Management Reach Agreement on Preferred Approach Database vs. Spreadsheets 29

30 Suggested Program Management Approach December - April Field and Non-field Data Collection / Generation Component Counts, Separator Sampling Cost Information Types of compressor seals, Verifying types of pneumatics Emission test data, blowdowns, liquids unloading Generation of Emission Estimates January to May QA/QC Start as early as possible, likely breaking up by data type Regular dialogue / engagement of agreed stakeholders Status Tracking Regular (Weekly / Bi-weekly) status update calls Progress Tracker List of Open Issues Then celebrate or at least sleep! 30

31 Part 2 Road Map Pneumatics Example Inventory Well Sites Tanks/Separators Pneumatics AGRU Dehys Equipment and Component Counts Compressors Confirm Presence of Air vs. NG Pneumatics All Air All done For NG Pneumatics - Leverage Existing Data Sources Asset Inventory Tools (Maximo, etc.) Emission Inventories P&IDs (not expected to be adequate) Leverage Facility Staff to Flush Out Inventories 3 rd Party staff visits to facilities to complete inventories Leverage Regional Resources Potential combined visits with other activities? Categorize Controller Types Control Devices 31

32 The Road Ahead Develop / Finalize Compliance Plan Right-size plan - burden & available resources Evaluate Overall Data Management Approach Stay Active in the Trades Data will still be collected and eventually used 32

33 Q&A Session 33

34 Contact Information Today s Speakers: Denise Grubert Raleigh, NC denise.grubert@erm.com Kevin Madry Denver, CO kevin.madry@erm.com Lisa Campbell Raleigh, NC lisa.campbell@erm.com Andy Woerner Philadelphia, PA andrew.woerner@erm.com 34