EMISSIONS REGULATIONS AND REDUCTIONS TECHNOLOGY IN WESTERN CANADA S OIL & GAS SECTOR

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Laura L. Chunty, P.Eng. EMISSIONS REGULATIONS AND REDUCTIONS TECHNOLOGY IN WESTERN CANADA S OIL & GAS SECTOR 16/05/2017 2017 COPYRIGHT PROCESS ECOLOGY INC. /Process-Ecology @processecology 1

AIR EMISSIONS OIL AND GAS Process Ecology Introduction What Regulations are there? What is Canada doing about it? Air Quality Management System (AQMS) Global Committments Oil and Gas How Big Is the Problem and What can we do about it? 2

PROCESS ECOLOGY INC. CORE COMPETENCIES Founded 2003, Calgary, AB Engineering consulting, process simulation & optimization, software development, air emissions estimation and management Track record of advanced modelling, simulation and process design, combining and extending simulators and rigorous engineering calculations to handle complex scenarios 3

AIR EMISSIONS - DEFINITIONS Methane CH4 Greenhouse Gases CO2, N2O, HCs Risks to Human Health Short Lived Climate Pollutants: Black Carbon, Ozone, Particulate Matter and others Benzene 4

AIR EMISSIONS REGULATIONS BY TYPE Methane CH4 Alberta reduce 45% from 2012 by 2025 New facility standards Directive (mid 2018?) Measurement Monitoring and Reporting(MMR) (2018?) Leak Detection and Repair (LDAR) (2018?) already in US Voluntary Joint Initiative reduction and verification BC reduce 45% by 2025 Target fugitive and vented emissions legacy facilities Offset protocol/clean infrastructure royalty credits new facilities Mandatory LDAR & others post 2018 Supporting Efficient Engines, supplying clean LNG 5

AIR EMISSIONS REGULATIONS BY TYPE Methane Saskatchewan No specific provincial regulation Federal reduce 40-45% below 2012 by 2025 Regulation Timing adjusted (was 2020, now 2023) LDAR Compressors seals and rod packing vents Well Completions prohibit venting Process Venting limit totals, dehy capture requirements Pneumatics low or no emissions 6

AIR EMISSIONS REGULATIONS BY TYPE GHG Alberta SGRR: >50,000 tonnes/yr CO2e, must report SGER: >100,000 tonnes/yr CO2e: Reduce Emissions Intensity 20% per year by: Improving Operations Purchase Offsets - $30/tonne in 2017 Emission Performance Credits from Previous period Replaced by Carbon Competitiveness Regulation by 2018 Carbon Tax: $20/tonne CO2e in 2017; $30/tonne in 2018 Charged on fuel imported, sold, flared and vented in Alberta Natural Gas produced and consumed ON SITE - exempt 7

AIR EMISSIONS REGULATIONS BY TYPE GHG BC GHG Industrial Reporting and Control Act Climate Action Secretariat GHG Emission Reporting Regulation >10,000 tonnes/yr CO2e must report GHG Emission Control Regulation > 25,000 tonnes/yr CO2e must report and verify GHG Emission Penalties and Appeals Use Western Climate Initiative (WCI) rules to calculate Concept of Linear Facilities Carbon Tax Oil and Gas pay on all combustion of fuels 8

AIR EMISSIONS REGULATIONS BY TYPE GHG Saskatchewan No specific regulation Focus on Federal Carbon Capture and storage Decarbonizing Power System Greenhouse Gas Reporting Program (GHGRP) since 2004 >50,000 tonnes/yr CO2e must report may change to >10,000 tonnes/yr CO2e in 2018 or 2019 MANY more facilities will report Carbon Tax minimum $10/tonne CO2e, currently in negotiations with provinces. 9

AIR EMISSIONS REGULATIONS BY TYPE Other Air Emissions Federal NPRI (National Pollutant Release Inventory) Air, Water and Ground Full reporting only at > 20,000 man-hours/yr (Under Review) Smaller facility reporting: Part 4 and 5 only Particulate Matter SOx NOx VOCs CO NH3 Alberta/BC/Saskatchewan Benzene Reporting Type I Carcinogen From Dehydrators: Alberta Directive 39, BC Oil and Gas Operations Manual Appendix J; Saskatchewan Directive S-18 10

AIR EMISSIONS REGULATIONS BY TYPE Flaring and Venting (F&V) Source of GHG, Methane and Other Gases Alberta Directive 60 rules about F&V, especially conservation of solution gas Also reported in various ways through Petrinex according to rules in Directives 7, 17 and 76 BC Oil and Gas Commission (OGC) Flaring and Venting reduction guideline eliminate all routine flaring by 2016 (?) Saskatchewan Directives R01, S-10, PNG017 and S-20 11

AIR QUALITY MGMT SYSTEM (AQMS) AQMS Federal Initiative (Except Quebec) Canadian Council of Ministers of the Environment 2012 Comprehensive approach to reducing air pollution Canadian Ambient Air Quality Standards (CAAQS) Canadian Environmental Protection Act (1999) Newly reduced limits on PM2.5 and Ozone Human health impacts respiratory (Particulates and Smog) Aspirational Targets to Drive Improvements - Benzene Targets SO2 at ground level from flaring of acid gas 12

AIR QUALITY MGMT SYSTEM (AQMS) BLIERs Base Level Industrial Emission Requirements Major Industrial Emitters Ensure Good Base-Level Environmental Performance Minimum Performance Standards Oil and Gas must follow the MSAPR Multi-Sector Air Pollutant Regulations Limits on NOx from large combustion sources (Boilers, heaters, stationary engines Future limits on SO2, VOCs, NH3 and PM likely 13

AIR QUALITY MGMT SYSTEM (AQMS) Provincial and Regional Directives as indicated above Special Air quality management areas e.g. Peace River AER Directive 84 HC Emission Controls and Gas Conservation Peace River Area effective April 1, 2017 Provincial Guidelines: Alberta BC Substance Release and reporting Regulations under EPEA (Environmental Protection and Enhancement Act Alberta Ambient Air Quality Objectives (AAAQO) Oil and Gas Waste Regulation Air Quality Objectives (BC AQO): Saskatchewan PM10, PM2.5, Ozone, SO2, NO2, Formaldehyde, TSP (total Suspended particulate) Environmental Management and Protection Act and Regulations Focus on SO2, NO2, PM2.5, PM10, CO and VOCs 14

AIR EMISSIONS GLOBAL FACTORS AIR doesn't respect BORDERS Conference of the Parties - recently COP21 (Paris, 2015) and COP22 (Marrakech, 2016) Reduce HFCs Reduce Aviation Emissions Ratification of Paris agreement limiting global warming Carbon Tax Commitment United Nations Environment Programme: Canada a founder of CCAC Climate and Clean Air Coalition Focus on Short Lived Climate Pollutants (SLCPs): Black carbon, ozone, methane, HFCs Targeting Transportation, Electric generation, Oil & Gas Methane, HFCs, AQMS 15

AIR EMISSIONS GLOBAL FACTORS Global Methane Initiative (GMI) Voluntary, Canada co-chairs Oil and Gas Subcommittee Canada focusing on: Oil & Gas Landfills Agriculture Global alliance for Clean Cookstoves Global Gas Flaring Reduction Partnership (World Bank) (Alberta) Public/Private Research, Best practices, Regulatory work United Nations Economic Commission for Europe Best practices on reducing emissions Arctic Council 16

AIR EMISSIONS OIL AND GAS NUMBERS Federal Estimates 2015 (most Recent): 189 Mt CO2e - 26% of national emissions (NIR to UNFCCC) GHGRP reports only 81 Mt CO2e (only facilities that are large) Alberta: Methane: 31.4 Mt CO2e as Methane, 70% of provincial CH4 emissions REFERENCE: 722 Mt CO2e Canada s Total GHG Emissions in 2015 ~50,000 Mt CO2e Worldwide Total 17

AIR EMISSIONS OIL AND GAS NUMBERS Clearstone Report (2011 data) and Current Alberta Government: GHG Source % of Total Fuel Combustion 59.8% Fugitive Equipment Leaks 11.9% Reported Venting 10.4% Unreported Venting 9.2% Releases of Formation CO2 4.8% Flaring 3.9% Methane Source % of Total (Clearstone) Reported Venting 31.7% Unreported Venting 28.2% % of Total (AB Govt) 48% Fugitive Equipment Leaks 36.1% 46% Other (Flaring, Tanks, etc.) 4.1% 6% 18

AIR EMISSIONS OIL AND GAS NUMBERS New Data (2017): St. F.X BC Montney Shale 111,800 tonnes CH4 annually Environmental Defence / Greenpath Alberta Methane emissions from oil and gas could be 60% higher than originally thought (significantly more leaking equipment unreported venting) Purdue University refineries and Gas power plants methane leaks 2-120 times higher than EPA estimates Environmental Sci & Tech (2015) Natural Gas Processing and Gas Gathering Actual Methane emissions substantially higher than current EPA estimates Many others generally measurements are higher than estimates have been Baseline Hard to capture Factored estimates increasingly inaccurate Can t measure it all 100,000+ sources in Alberta alone NEED BETTER MODELS! 19

AIR EMISSIONS OIL AND GAS REDUCTIONS First Targets? Fugitives Venting Combustion Protocols Existing Pneumatics Solution Gas Conservation Upcoming LDAR (Leak Detection and Repair)? Best Practices CAPP Documents CSA Z620.1 API Compendium EPA s AP-42 20

AIR EMISSIONS REGULATIONS WHAT are the Regulations? It s convulted! WHAT are we DOING about it? Federal initiatives WHAT is our place in the Global Picture? World leader HOW Big is the Problem? Numbers vary, hard to estimate WHERE to reduce? Fugitives and Venting 21

THANK YOU QUESTIONS? CONTACT: Laura Chutny laura@processecology.com 403-478-4758 22