BLM Venting/Flaring Rule Emergencies (t Emergencies (tem emporar porary, infreq , infrequent, una ent, unavoidable) oidable) • 24 hours per incident (unless extended by BLM), and no more than three emergencies per 30 day period • Exceptions (i.e., not an emergency) • More than 3 failures of the same equipment in a 365-day period • Failure from improperly sized, installed, or maintained equipment • Failure to limit production when rate exceeds capacity of equipment, pipeline, gas plant • Scheduled maintenance • Operator negligence Oil and Gas Air Regulations Air Quality Regulation Review
Source Determination (Aggregation) • Final rule June 3, 2016 (https://www.regulations.gov/contentStreamer?documentId= EPA-HQ-OAR-2013-0685- 0226&disposition=attachment&contentType=pdf) • Specific to the oil and gas sector, not other industries • What does “adjacent” mean • Very important for project permitting • Prevention of Significant Deterioration (PSD) • Non-attainment New Source Review (NNSR) • Title V operating permits Oil and Gas Air Regulations Air Quality Regulation Review
Aggregation – Historic Approach • Three-part test • Same industrial grouping (standard industrial code (SIC)) • Located on contiguous or adjacent properties • Under common control of single owner • EPA added additional considerations • Operational dependence • Functional interrelatedness Oil and Gas Air Regulations Air Quality Regulation Review
Aggregation – Summit Petroleum • Summit Petroleum Corporation – Michigan • EPA determined that oil/gas sweetening plant and ~ 100 Summit oil/gas wells were a single major source under the Title V operating permit program • The Summit wells were all within 8 miles of the plant, and EPA determined these were “adjacent” • Summit appealed to 6th Circuit Court of Appeals in 2012; EPA decision overturned (using “interrelatedness” in determining adjacency was unreasonable) • EPA issued guidance to follow the 6th Circuit ruling only in states subject to the 6th Circuit, and to continue to use functional interdependency elsewhere Oil and Gas Air Regulations Air Quality Regulation Review
Source Determination/Aggregation • Adjacent – equipment and activities in the oil & gas sector under common control are considered part of the same source if: • They are located on the same site or on sites that share equipment AND • They are located within ¼-mile of each other Oil and Gas Air Regulations Air Quality Regulation Review
• Source Determination/Aggregation
Other Important Programs (Federal/State) • Federal • New Source Review permitting • Ozone non-attainment areas • Texas - Permit-by-rule • Colorado - Regulation No. 7 • Wyoming – Presumptive BACT • North Dakota - Flare minimization • Pennsylvania – Pending changes to GP5 (midstream) and GP5A (upstream and remote pigging) Oil and Gas Air Regulations Air Quality Regulation Review
GHG MRR Subpart W Petroleum & Natural Gas Systems • Regulation has different requirements for each the 10 industry segments • Offshore natural gas and natural gas production • Onshore natural gas and natural gas production • Onshore natural gas processing • Onshore natural gas transmission compression • Underground natural gas storage Oil and Gas Air Regulations Air Quality Regulation Review
GHG MRR Subpart W • Liquefied NGL storage • LNG import export equipment • Natural gas distribution • Onshore petr Onshore petroleum and oleum and natural gas gatheri natural gas gathering and g and boostin boosting* • Onshore natural gas Onshore natural gas transmission pipeline* transmission pipeline* * Added for the 2016 Reporting year (reported by March of 2017) Oil and Gas Air Regulations Air Quality Regulation Review
GHG MRR Subpart W • Generally, deminimis level of 25,000 metric tons per facility • Each segment has its own definition of facility • Can be based on basin, physical facility or even aggregated for entire United States (pipelines) • Basins can cover part of more than one state • No county is split between two basins • Requires annual GHG emission inventories Oil and Gas Air Regulations Air Quality Regulation Review
GHG MRR Subpart W • All segments except the Production and Gathering and Boosting segments report combustion emissions following Subpart C • Production and Gathering/Boosting follow Subpart W • Report emissions from all combustion sources above the deminimis (5 mmBTU/hr for external combustion 130 hp for internal) • Includes sources on site temporarily, even if not owned or operated by reporting company (drilling, completions, workovers, maintenance) • Doesn’t include engines that power a drive shaft (not traditional definition of mobile) Oil and Gas Air Regulations Air Quality Regulation Review
GHG MRR Subpart W Added to the Production segment for 2016 • Gas venting during completions/workovers, with fracing for oil wells • Reporting well ID numbers (so calculation inputs can be confirmed) Gathering and Boosting • Reporting requirements very similar to production requirements • Covers almost all equipment not currently reported under another industry segment • Emissions aggregated by basin Oil and Gas Air Regulations Air Quality Regulation Review
GHG MRR Subpart W • Transmission Pipelines • Emissions nationally aggregated • Only includes emissions from blowdown vent stacks Oil and Gas Air Regulations Air Quality Regulation Review
Presenter Ja Jay C y Christ ristopher opher Senior Air Specialist jchristopher@trihydro.com Oil and Gas Air Regulations Air Quality Regulation Review
Questions? WHA WHAT WHY WHY WHERE WHERE WHEN WHEN WHO WHO HO HOW
Other Important Programs (Federal/State) • A PBR can be requested if PTEs are: • < 250 tpy of CO or NOx • < 25 tpy of VOC, SO2, or H2S • < 15 tpy PM10 and < 10 tpy PM2.5 and • < 25 tpy of any other contaminant, except • CO2, H2O, N2, CH4, C2H6, H or O2 • Can’t meet PBR qualifications? Try for a standard permit. • Can’t qualify for a standard permit? NSR permit is required Oil and Gas Air Regulations Air Quality Regulation Review
Texas PBR, Continued Common PBRs for the oil and gas industry (Chapter 106, Subchapter O): • 106.351 – Saltwater Disposal • 106.352 – Oil & Gas Handling and Production Facilities • 106.353 – Temporary Oil & Gas Facilities • 106.473 – Organic Liquid Loading and Unloading • 106.492 – Flares • 106.512 – Stationary Engines & Turbines Oil and Gas Air Regulations Air Quality Regulation Review
Colorado Regulation No. 7 Colorado Air Quality Control Commission adopted revisions on February 23, 2014 that apply to all oil and gas exploration and production operations, well production facilities, natural gas compressor stations, and natural gas processing plants Affected equipment includes: • Combustors • Open-ended lines/valves • Compressors • Storage tanks • Glycol dehydrators • LDAR • Pneumatic controllers Oil and Gas Air Regulations Air Quality Regulation Review
Wyoming Requirements • Wyoming requires Best Available Control Technology on all emission sources in the state, even if they were imported from another state • Requires permits for oil and gas well production sites • No deminimis levels for permitting or BACT • Oil and Gas Guidance has presumptive BACT requirements for oil and gas production facilities based on location within the state • Pump jack engine guidance for small pump jack engines Oil and Gas Air Regulations Air Quality Regulation Review
Wyoming Requirements • Current emission limits for natural gas-fired engines can be as low as 0.5 g/hp-hr for NOx and CO, 0.07 for formaldehyde • Engines must be permitted before being placed on site • Engine testing requirements exceed the NSPS and NESHAP requirements • Have been including annual OGI inspections of well sites on more recent permits • Requiring annual emission inventories of the Powder River Basin facilities (attainment area), including minor sources Oil and Gas Air Regulations Air Quality Regulation Review
North Dakota Requirements • Registration program instead of permits • Published emission factors, so no tank modeling required • Requires oil and water tank vapors to be captured and reduced by at least 98% • North Dakota Industrial Commission requiring a reduction in associated gas flaring • Initial goals - capture 85% by January 1, 2016 and 90% by October 1, 2020 • Delays in the these dates are under review Oil and Gas Air Regulations Air Quality Regulation Review
EPA’s Proposed Tribal Lands General Permit • Green completions • Meet NSPS OOOO and OOOOa • Meet engine NSPS and NESHAP requirements • Meet NSPS for sulfur dioxide • Less cumbersome than most state requirements Oil and Gas Air Regulations Air Quality Regulation Review
Oil and Oil and Gas Essentials Gas Essentials LD LDAR R AR Regulations gulations Presented by: Calvin Niss
Overview • Controlling fugitive • BLM – waste prevention emission leaks rule • Leak sources in the oil • Fugitive emission plans and gas industry • Two-part test for LDAR • NSPS vs NESHAP modification • LDAR regulations for the • Capital expenditure oil and gas industry • LDAR pitfalls Oil and Gas Air Regulations Equipment – Specific Requirements
Reduction of Leaking Equipment – Control of Leaks Leak Detection and Repair (LDAR) is the control of fugitive emission leaks from process equipment through: • Equipment standards • Work practice standards • Equipment monitoring • Repair of leaking equipment • Applies to equipment containing VOCs or HAPs, and for the oil and gas sector methane (CH 4 ) is a pollutant Oil and Gas Air Regulations Equipment – Specific Requirements
http://www3.epa.gov/airquality/oilandgas/basic.html EPA’s View of the Oil & Gas Industry
EPA’s View of the Oil and Gas Industry • Oil and natural gas systems encompasses wells, gas gathering and production facilities, storage, and transmission and distribution pipelines. • Pr Production oduction – includes drilling and well completions of oil and gas wells, gathering lines and booster stations • Gas Plant Pr Gas Plant Processing ocessing – focuses on stripping out impurities and other hydrocarbons and fluids to produce pipeline grade natural gas that meets specific tariffs (pipeline quality natural gas is 95 – 98 percent methane) • Transmission & ansmission & St Storage orage – includes transmission compressor stations, transmission pipelines and underground storage • Distribution Distribution – delivery and distribution of natural gas from the major pipelines to end users (e.g., residential, commercial, and industrial) Oil and Gas Air Regulations Equipment – Specific Requirements
NSPS vs. NESHAP • New Source Performance Standards (NSPS) • Criteria pollutants (primarily volatile organic compounds (VOCs) • New, modified, or reconstructed sources • Controls consider economic viability • National Emission Standards for Hazardous Air Pollutants (NESHAP) • Maximum Achievable Control Technology (MACT) • Hazardous Air Pollutants (HAPs) • All sources, existing and new, at major or area sources of HAPs Oil and Gas Air Regulations Equipment – Specific Requirements
NSPS Triggers • Triggered based on having the equipment in the source category that defines the NSPS subpart. The NSPS subpart does not become applicable until one of the three criteria are met. 1. Constructed new after the applicability date (proposed rule date) 2. Modification after the applicability date in the regulation 3. Reconstruction after the applicability date in the regulation • Subpart KKK – January 21, 1984 to August 23, 2011 • Subpart OOOO – August 24, 2011 to September 18, 2015 • Subpart OOOOa – September 19, 2015 to present Oil and Gas Air Regulations Equipment – Specific Requirements
NESHAP / MACT Triggers • MACT regulations apply to Major Source Categories • Applicability for a MACT standard for LDAR is based on the percent of defined organic hazardous air pollutants (HAPs) that are present in each piece of regulated equipment • MACT regulations become effective on the date that they are published or triggered by a change • The NSPS criteria of new, modified or reconstruction does not apply to a MACT regulation • MACT regulations have exemptions Oil and Gas Air Regulations Equipment – Specific Requirements
Fugitive Emission Regulations that Apply to the Oil and Gas Sector • NSPS KKK NSPS KKK – references NSPS VV • NSPS OOOO NSPS OOOO – references NSPS VVa • NSPS OOOOa NSPS OOOOa –September 18, 2015 newly constructed, modified, or reconstructed facilities • BLM W BLM Wast ste Pre e Prevention R ention Rule le – requires first inspection by 1/17/18 for existing facilities and within 60-days of beginning production after 1/17/18 • BLM delayed rule 1/2019 • US District Court California – Reinstated the rule 2/2018 • NSPS LL NSPS LL – specific to SO 2 • Part 63 Subpa 63 Subpart HH t HH – oil and natural gas production facilities • Part 63 Subp 63 Subpart HHH t HHH – natural gas transmission and storage facilities Oil and Gas Air Regulations Equipment – Specific Requirements
NSPS KKK Applicability • Subpart KKK – Standards of performance for equipment leaks of VOC from onshore natural gas processing plants that commenced construction, reconstruction, or modification after January 20, 1984 and or before August 23, 2011. • Equipment subject to the standard includes equipment in wet gas service or VOC service with a VOC content greater than 10 percent by weight. • Compressor station, dehydration unit, sweetening unit, underground storage tank, field gas gathering system is covered by this subpart if located at an onshore natural gas processing plant. • Each piece of equipment is presumed to be in VOC service or in wet gas service unless an owner or operator demonstrates that the piece of equipment is not in VOC or wet gas service. • Joule – Thompson (JT) skids are defined as natural gas processing plants – subject to NSPS KKK. Oil and Gas Air Regulations Equipment – Specific Requirements
NSPS KKK Exemptions • Pressure relief devices in gas/vapor service may be monitored quarterly and within 5 days after each pressure release to detect leaks provided these PRVs are not at an unmanned gas plant. Option of VV – 500 ppm within 5 days 1. Option of KKK – Monitor quarterly and 5 days at 10,000 ppm 2. • Sampling connection systems are exempt per 60.482 – 5 • Pumps in light liquid service, valves in gas/vapor and light liquid service, and pressure relief devices in gas/vapor service that are located at a nonfractionating plant that does not have the design capacity to process 10 MM scf/day (283,200 scm/day) or more of field gas are exempt from the routine monitoring requirements of 60.482-2(a)(1) and 60.482-7(a), and 60.6333(b)(1). • Reciprocating compressors in wet gas service are exempt from compressor control requirements of 60.482-3. Oil and Gas Air Regulations Equipment – Specific Requirements
NSPS OOOO Applicability • NSPS OOOO – Standards for equipment leaks of VOC from onshore natural gas processing plants that commenced construction, reconstruction or modification after August 23, 2011. • Lower leak definitions – 500 ppm valves, 2,000 ppm pumps. • NSPS OOOO – Specific work practice for both centrifugal and reciprocating compressors. • NDE requirements for compressors routed to CVS w/in 180 days • Emissions from rod packing vents are not subject to LDAR monitoring. Oil and Gas Air Regulations Equipment – Specific Requirements
NSPS OOOO Exemptions • NSPS OOOO – references VVa • Indefinite stay of NSPS equipment leaks of VOC from SOCMI and petroleum refineries 1. Clarification of the definition of process unit in subparts VV, VVa, GGG, and GGGa 2. Assigning of shared storage tanks to specific process units 3. Connector monitoring requirements in subpart VVa 4. The definition of capital expenditure in subpart VVa • Trihydro regulatory opinion – the stay is only applicable to GGGa facilities (i.e., petroleum refineries) • NSPS OOOO – requires annual connector monitoring • NSPS OOOO – response to comments – JT skids are not gas processing plants (ADI in flash drive) Oil and Gas Air Regulations Equipment – Specific Requirements
OOOOa Rule – Big Fugitive Picture • LDAR required for well sites and compressor stations – now includes methane • Initial monitoring survey for affected facilities was 6/3/2017 • Changes to the definition of “new” and “modified” and clarifications of the capital expenditure calculation • BSER – Best System of Emission Reduction – Optical Gas Imaging (OGI) • Site specific monitoring plans must be developed and implemented • Next Generation compliance, verification, and electronic reporting requirements Oil and Gas Air Regulations Equipment – Specific Requirements
OOOOa Rule – Big Fugitive Picture Continued • Modification • Well Sites – Addition of a new well or fracturing or refracturing of an existing well • Compressors – Addition of a new compressor, or when a physical change is made to an existing compressor that creates greater horsepower • Initial survey within 60 days of startup or modification • Gas Plants – No changes – VVa program Oil and Gas Air Regulations Equipment – Specific Requirements
Key Fugitive Aspects – NSPS OOOOa • Fixed monitoring schedule (e.g., compressor stations – quarterly and well sites semi-annually). • Semiannual inspections must be conducted at least 4 months apart and quarterly inspections at least 60 days apart. • Monitoring using M21 – repair threshold 500 ppm. • 30-days for repairs of fugitive emission sources. • 30-days for resurvey. • Delay of repair – Final rule removes the requirement for completion of delayed repairs during unscheduled or emergency vent blowdowns. DOR components are required to be repaired during compressor station shutdown, well shutdown after a planned wait, or within two years. • M21 – Soap solution is allowed for repair verification under certain conditions (e.g., no moving parts or no surface temperature above the boiling point or below the freezing point of the soap solution). Oil and Gas Air Regulations Equipment – Specific Requirements
NSPS OOOOa – Changes in Final Rule • Low production well sites are not exempt. • Fugitive emission component definition was changed to exclude equipment types, such as uncontrolled storage vessels and vented emissions. • Timing of initial monitoring – 60 days from startup of production. • Owner/Operators must retain a record of each OGI monitoring survey. The photographed or video must either include the latitude and longitude of the collection of sources imbedded within the photograph or video, or consist of an image of the survey being performed with a separate GPS device with the same picture or video. • Owner/Operators can either hang a leak tag on the leaking component or take a digital photograph, provided the photo is taken with an OGI instrument and includes latitude and longitude. Oil and Gas Air Regulations Equipment – Specific Requirements
NSPS OOOOa – Well Sites • Collection of fugitive emission components at a well site – oil well, gas well, or injection well and it’s associated well pad. • Includes all ancillary equipment – valves, connectors, pressure relief devices, open-ended lines, flanges, convers, and closed vent systems. • Exemptions – devices that vent as part of normal operations, such as natural gas-driven pneumatic controllers and pumps. • Well sites that only contain one or more wellheads are not affected facilities and are not subject to the fugitive emissions requirements. • Emissions originating from other than the vent, such as the thief hatch on a controlled storage vessel, would be considered fugitive emissions. Oil and Gas Air Regulations Equipment – Specific Requirements
NSPS OOOOa – Compressor Stations • Compressor station definition – includes natural gas transmission, storage, gathering, and booster stations. Combination of one or more compressors located at a well site or natural gas processing plant is not a compressor station. • Collection of fugitive components – includes valves, connectors, pressure relief devices, open-ended lines, flanges, covers, and closed-vent systems. • Affected facility – compressor station if an additional compressor is added or if it is a replacement of greater horsepower. • BSER – OGI survey. • Follow-up monitoring – OGI or M21. • M21 – Repair confirmation leak rate is 500 ppm. Oil and Gas Air Regulations Equipment – Specific Requirements
NSPS OOOOa – Natural Gas Processing Plants • LDAR program based on NSPS VVa • Leak definitions – 500 ppm valves, 2,000 ppm pumps and annual connectors at 10,000 ppm • Repair schedules – 5/15 day and delay of repair Oil and Gas Air Regulations Equipment – Specific Requirements
NSPS OOOOa – Fugitive Emissions Monitoring Plans • Frequency for conducting surveys • Technique for determining fugitive emissions (e.g., M21 or OGI) • Manufacturer and model number of fugitive emissions detection equipment • Procedures and timeframes for identifying and repairing fugitive emissions component • Procedures and timeframes for verifying fugitive emission component repairs • Records that will be kept and the length of time records will be kept Oil and Gas Air Regulations Equipment – Specific Requirements
NSPS OOOOa – Monitoring Plan Requirements • Site map • Defined observation path that ensures fugitive emission components are within instrument sight • If a facility is using M21, the plan must include a list of fugitive emission components to be monitored and method for determining location of components • The plan must include all components designated as difficult-to-monitor or unsafe-to-monitor Oil and Gas Air Regulations Equipment – Specific Requirements
NSPS OOOOa – Monitoring Plan Requirements / OGI • OGI equipment must be capable of imaging gases in the spectral range for the compound of highest concentration • OGI equipment must be capable of imaging a gas that is half methane, half propane at a concentration of 10,000 ppm at a flow rate 60g/hr • Procedure for daily instrument verification • Procedure for determining operator’s maximum viewing distance • Procedure for determining maximum viewing distance Oil and Gas Air Regulations Equipment – Specific Requirements
NSPS OOOOa – Monitoring Plan Requirements / OGI • Procedure for conducting surveys • How the operator will ensure adequate thermal background • How the operator will deal with adverse weather, such as wind • How the operator will deal with interference (e.g., steam) • Training and experience needed prior to perform surveys • Procedures for instrument calibration and maintenance Oil and Gas Air Regulations Equipment – Specific Requirements
NSPS OOOOa – Clarifications • Owners / operators shall demonstrate compliance within 180 days of initial pr process unit ocess unit startup. Applies to new, modified and reconstructed sources. • Defines annual connector monitoring for process units subject to NSPS OOOO • Capital expenditure calculation – was not revised in NSPS OOOO and reverts to NSPS KKK, which references VV • B value in the formula – based on IRS annual asset guideline repair allowance for exploration and production including natural gas plant processing, specified as 4.5 Oil and Gas Air Regulations Equipment – Specific Requirements
MACT HH – National Emission Standards for Hazardous Air Pollutants From Oil and Natural Gas Production Facilities • Applicable to MACT major and area sources • Major sources – affected equipment includes glycol dehydration units, storage vessels and loading facilities • Area sources – Triethylene Glycol (TEG) dehydration unit • VHAP is defined as a piece of equipment that contains or contacts a fluid (e.g., liquid or gas) with a VHAP concentration > 10 percent by weight Oil and Gas Air Regulations Equipment – Specific Requirements
MACT HH – National Emission Standards for Hazardous Air Pollutants From Oil and Natural Gas Production Facilities • Equipment leak standards – only applies to equipment in VHAP service at natural gas processing facilities • HH – Amended in August 2012 - lower leak definition for valves at 500 ppm, pumps 10,000 ppm, and no connector monitoring • Exemption – if the piece of equipment is not in VHAP service > 300 hours per year Oil and Gas Air Regulations Equipment – Specific Requirements
MACT HHH – National Emission Standards for Hazardous Air Pollutants From Oil and Natural Gas Production Facilities • Applies to owners and operators of natural gas transmission and storage facilities that transport or store natural gas (i.e., downstream of natural gas plants) • Applicable to MACT major transmission facilities • For Subpart HHH – affected equipment is each glycol unit • NDE initial monitoring M21 of CVS – annual visual thereafter Oil and Gas Air Regulations Equipment – Specific Requirements
BLM Flaring Rule – LDAR Applicability • Applicable – Existing well sites and all associated equipment used to produce, process, compress, treat, store or measure natural gas (e.g., oil, and gas wells) allocated to a Federal or Indian lease. • The rule also applies to equipment associated with produced water. • First Inspection – January 17, 2018 for sites that have begun production prior to January 17, 2018. • Within 60 days of beginning production for sites that begin production after January 17, 2018. • Within 60 days of the date where a site that was out of service brought back into service and re-pressurized. Oil and Gas Air Regulations Equipment – Specific Requirements
BLM Flaring Rule – LDAR Exemptions • A site that contains a wellhead or wellheads and no other equipment • A well or well equipment that has been depressurized • A component that is deemed “inaccessible” Oil and Gas Air Regulations Equipment – Specific Requirements
BLM Flaring Rule – LDAR Inspection Requirements • Existing well sites – semi-annually must be conducted at least 4 months apart • Existing compressor stations – quarterly, must be conducted at least 60 days apart • New, modified, or reconstructed – well sites and compressor stations will be required to comply with NSPS OOOOa • Leak rates – NSPS OOOOa • Approved instruments and methods – NSPS OOOOa • Repairing leaks – NSPS OOOOa • Reporting – annual report due to BLM by March 31, each calendar year Oil and Gas Air Regulations Equipment – Specific Requirements
Reconstruction • Determine if the “process unit” has been reconstructed – NSPS Subpart A, 60.15 • Process unit reconstructed for LDAR if you replace components (individual LDAR equipment) of an existing facility to the extent that: • The fixed capital cost of the new components exceeds 50 percent of the fixed capital cost that would be required to construct a comparable new “affected facility” (e.g., process unit and a compressor) Oil and Gas Air Regulations Equipment – Specific Requirements
Modification Modification means any physical change in, or change in the method of operation of, an existing facility, which: • Increases the amount of any pollutant (to which a standard applies) emitted into the atmosphere by that facility, or • Results in the emission of any pollutant (to which a standard applies) into the atmosphere not previously emitted Oil and Gas Air Regulations Equipment – Specific Requirements
Two Part Test for LDAR Modification Was there a net increase in VOC emissions? 1. Calculate your emission change. There is no deminimus increase defined, so any increase meets the first part of the test. Example: adding one valve without removing a valve in the same service within the process unit would constitute an increase in emissions. If there is an emissions increase proceed to step 2. 2. Calculate if you have a “capital expenditure” 3. Addition or replacement of equipment (defined in 60.591) for the purpose of process improvement which is accomplished without a capital expenditure shall not by itself be considered a modification Oil and Gas Air Regulations Equipment – Specific Requirements
Capital Expenditure NSPS VV section 60.481 explains how to calculate whether or not a facility has had a capital expenditure • A facility is defined in the NSPS subparts as the group of equipment in a process unit. Only the cost of LDAR-associated equipment, including pumps, valves, connectors, flanges, etc., are considered in the calculation. The cost of heaters, piping, vessels, heat exchanger and other process equipment in a process unit is not part of the facility for determining if there has been a modification for LDAR. • Compressors are also not used in the modification calculation (see 60.591) • A separate calculation must be made for each affected facility Oil and Gas Air Regulations Equipment – Specific Requirements
Capital Expenditure Calculation Capital expenditure defined. In addition to the definition in 40 CFR 60.2, an expenditure for a physical or operational change to an existing facility that: 1. P = Allowable amount of replacement cost that the project must be less than for the project to not be considered a modification 2. B = Annual asset guideline repair allowance 3. R = Facility replacement cost (only LDAR related equipment/components) 4. A = Adjusted annual asset guideline repair allowance percentage (AAGRP) 5. X = 1982 minus year of construction of the “existing facility” 6. P = R x A 7. A = Y x (B/100) 8. Y = 1-0.575 log x Oil and Gas Air Regulations Equipment – Specific Requirements
Modification – Scenario • A natural gas processing facility was constructed in 2009. The plant underwent a modification with the addition of new valves, pumps and connectors in the inlet processing unit. The contract with the engineering firm was executed on September 1, 2011. The original authorization for expenditure (AFE) for the entire project was $110,000,000 and the cost of the LDAR related equipment totaled $5,000,000. The additional pumps and valves for the modification totaled $100,000. • Discussion - Is the $100,000 project expense considered a capital expenditure? Did the facility trip a new LDAR regulation? Oil and Gas Air Regulations Equipment – Specific Requirements
Answer • YOC = 2009 The $100,000 project expense is not considered a “capital • Change 2006 to 2011 expenditure” for modification (since that is the NSPS because the project expense OOOO applicability date) has to be greater than the • Change B to 4.5 for oil and replacement cost for the capital expenditure to be considered a natural gas sector modification. • X = 2011 – 2009 = 2 • Y = 1.0 – (0.575 * log (2)) = 0.83 Because the facility modification • A = 0.83 * (4.5/100) = 0.04 was done after August 23, 2011, • P = $5,000,000 * 0.04 = 200,000 the NSPS OOOO date of 2011 • P = Replacement Cost is $200,000 was used in the calculation. • Project expense = $100,000 Oil and Gas Air Regulations Equipment – Specific Requirements
Applicability to More Than One NSPS / MACT Regulation • What do you do when you are subject to more than one NSPS or MACT regulation? • A facility is still subject to each regulation that is applicable • Look for overlap provisions in each of the regulations. They will tell what part of each regulation is applicable Oil and Gas Air Regulations Equipment – Specific Requirements
Common LDAR Pitfalls – Applicability, Inventory, and Tagging • Not completing the calculation of capital expenditure for modification under NSPS KKK, OOOO and OOOOa • Modification of a process unit can only occur if there is an increase in emissions combined with a capital expenditure • Missing the initial monitoring event of 30 days for new equipment in existing process units • Missing equipment (e.g., storage tanks, glycol dehydrators) in VHAP service that are greater than 10 percent VHAPs and subject to MACT HH • Incorrectly identifying a “process unit” in a natural gas processing facility Oil and Gas Air Regulations Equipment – Specific Requirements
Common LDAR Pitfalls – Applicability, Inventory and Tagging • Overlooking contiguous and adjacent facilities that potentially could be subject to LDAR monitoring and reporting • Failure to monitor all components associated with a wet gas compressor (integral to the compressor) at a natural gas processing facility • Failure to monitor all components in a process unit for two successive months after tripping into a new regulation (e.g., KKK, OOOO, OOOOa) • Incomplete or outdated weekly pump visual list including documentation and recordkeeping • The final repair follow-up reading does not count as the first of two successive monthly readings after successful repair Oil and Gas Air Regulations Equipment – Specific Requirements
LDAR Pitfalls – Method 21 Monitoring • Collecting monitoring reading in less time than it takes to physically move between two points in the facility • Using an instrument which cannot detect the hydrocarbon in the equipment or detect within the 10 X response factor range allowed by M21 • Failure to monitor all potential leak interfaces or monitoring too quickly • Failure to monitor per M21 requirements – soap solution can be used for follow-up monitoring • Failure to monitor new valves for two successive months prior to placing the valve on a quarterly schedule • Changing a sub grouping of a valve within the monitoring schedule per NSPS rules that monitoring is completed with the month period • Failure to monitor connectors within 12 months Oil and Gas Air Regulations Equipment – Specific Requirements
LDAR Pitfalls – Repairs • Missing repair time frames (first attempt and final repair) • Missing instrument and operator identification, repair methods, or repair attempt date information in leak log • Facility maintenance personnel missing final repair date • Failure to monitor valves placed on delay-of-repair on a routine schedule that are • Failure to track and record all repair attempts, including AVO’s Oil and Gas Air Regulations Equipment – Specific Requirements
Presenter Calvi Calvin Ni Niss ss Senior Vice President cniss@trihydro.com Oil and Gas Air Regulations Equipment – Specific Requirements
Questions? WHA WHAT WHY WHY WHERE WHERE WHEN WHEN WHO WHO HO HOW
Oil and Gas Air R Oil and Gas Air Regulations gulations Eq Equipment – uipment – Specif pecific R c Requirements irements Presented by: Jay Christopher
Overview We will summarize the air regulatory requirements in terms of regulated equipment/operations, including: • Gas venting with workovers and completions with hydraulic fracturing • Production • Storage Vessels • Pneumatics • Compressors • Glycol Dehydrators • Flares Oil and Gas Air Regulations Equipment – Specific Requirements
Oil & Gas Operations – Gas Well Modifications • Fracturing/re-fracturing an existing natural gas well = NSPS modification • Gas wells that are re-fractured and use RECs plus completion combustion controls are not considered modifications • But these wells must meet all notification, recordkeeping, and reporting requirements • Ultimately, not much difference, but better to avoid an NSPS trigger • Significant recordkeeping/reporting requirements • Geotagged photo of green completion operations, responsible official self-certification, and many, many more Oil and Gas Air Regulations Equipment – Specific Requirements
Production Operations – Reduced Emissions Completion “Well completion following fracturing or refracturing where gas flowback that is otherwise vented is captured, cleaned, and routed to the flow line or collection system, re-injected into the well or another well, used as an on-site fuel source, or used for other useful purpose that a purchased fuel or raw material would serve, with no direct release to the atmosphere.” Oil and Gas Air Regulations Equipment – Specific Requirements
Production Operations – Reduced Emissions Completion • NSPS OOOO is the primary rule • State regulations important too • Controls • Flares, seals, piping • Quad O – “once in always in” • If you fall to 4 tpy you can move flares but still have requirements Oil and Gas Air Regulations Equipment – Specific Requirements
Storage Vessels • 6 tons per year actual emission limit per tank for Quad O • Leak detection requirements for Quad Oa • Calculations challenges for tank emissions – look at the Noble Energy and Slawson Consent Decrees • Challenge of keeping the system leak tight and getting the vapors to controls while not over pressurizing the tanks • Pressure relief valves or thief hatches frequent venting is a serious problem, easily seen by IR camera Oil and Gas Air Regulations Equipment – Specific Requirements
Storage Vessels - Applicability • Applies to each new, modified, or reconstructed storage vessel in oil or natural gas production operations, natural gas processing, or natural gas transmission/storage facilities • Storage vessel on mobile equipment (e.g., frac tanks) that is intended to be located at a site for at least 180 days is an affected storage vessel (OOOOa adds requirement to demonstrate less than 180 days onsite) • Excludes surge control vessels, knockout vessels, and pressure vessels designed to operate without emissions to atmosphere • Adding a new source (well) to a tank battery is a modification Oil and Gas Air Regulations Equipment – Specific Requirements
Storage Vessels - Limits • Enforceable controls to stay under 6 tpy (can be permit, permit by rule, and other “legally and practically enforceable” requirement) • If VOC emissions >6 tons/year, reduce emissions by 95%. Controls may be fixed roof with control device or floating roof (meets NSPS Kb). Oil and Gas Air Regulations Equipment – Specific Requirements
Storage Vessels - Applicability • State programs may require additional plans and requirements • States are aggressively and actively establishing new requirements, particularly around storage vessel vapor controls • Most states specify controls for existing storage vessels that have emissions greater than 6 tons per year VOCs • Different calculation methods and their limitations • Simulations only as good as analytical results • E&P Tanks, older program based on traditional wells (heavier) • HYSYS and ProMax, expensive process design software packages Oil and Gas Air Regulations Equipment – Specific Requirements
Pneumatic Equipment Natural gas-driven pneumatic equipment has become a significant regulatory focus. Oil and Gas Air Regulations Equipment – Specific Requirements
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