INTRODUCTION TO THE OIL AND GAS INDUSTRY Chapter 1 1 WHAT IS NATURAL GAS??? 2 2 1 - Intro to Oil and Gas 1-1 What Isn’t Natural Gas? This Photo by Unknown Author is licensed under CC BY-SA This Photo by Unknown Author is licensed under CC BY-SA This Photo by Unknown Author is licensed under CC BY-SA 3 3 Natural Gas • Colorless, shapeless, and odorless mixture of hydrocarbon gases • Highly combustible • When burned, it gives off a high amount of energy • Cleaner than many other fossil fuels • Emits lower levels of potentially harmful biproducts into the air This Photo by Unknown Author is licensed under CC BY • Abundant in the United States 4 4 1 - Intro to Oil and Gas 1-2 What is that smell? The smell we associate with natural gas is actually an odorant called mercaptan! Natural gas is odorless! 5 5 Components of Natural Gas • What is a hydrocarbon? Methane CH4 • An organic compound consisting Ethane C2H6 entirely of hydrogen and carbon Propane C3H8 • Natural gas consists primarily Butane C4H10 Carbon Dioxide CO2 0 – 10 % Oxygen O2 0 – 0.2% Nitrogen N2 0 – 5% Hydrogen Sulfide H2S 0 – 5% Rare gases Ar, He, Ne, Xe trace of methane (CH4) • Composition variable, but makeup generally similar based on location of origination (i.e., northeast U.S. vs. southern U.S.) 70 – 90% 0 – 20% 6 6 1 - Intro to Oil and Gas 1-3 “Dry” Natural Gas • “Dry” natural gas is at least 85% methane, but often more • Dry natural gas can be transported via pipelines across the country for home heating and electric generation • AKA “pipeline quality natural gas” or “consumer-grade natural gas” • Dry natural gas can also be used at natural gas extraction and transportation sites • Used to power vehicles, drilling rigs, and other operations • Reduces the need for using other fuels like gasoline and diesel 7 7 “Wet” Natural Gas • “Wet” natural gas contains higher percentages of compounds like ethane and butane • These natural gas liquids (NGLs) can be separated from the methane and sold as individual compounds • Ethane is widely used in petrochemical plants and to also manufacture consumer goods (like plastics) • Butane can be blended into gasoline to fuel vehicles • Propane is used for home heating and cooking • The propane and other lighter compounds found in the liquid natural gasses (LNGs) may be marketed as liquefied petroleum gas (LPG), and heavier hydrocarbons may be made into gasoline 8 8 1 - Intro to Oil and Gas 1-4 9 9 What is crude oil and what are petroleum products? • Crude Oil: a naturally occurring liquid beneath the Earth’s surface • Petroleum covers both naturally occurring unprocessed crude oil and petroleum products made up of refined crude oil • Commonly refined into various fuels, or petroleum products This Photo by Unknown Author is licensed under CC BY-SA 10 10 1 - Intro to Oil and Gas 1-5 Products Made from Crude Oil • Once crude oil is removed from the ground, it is sent to a refinery where the oil is distilled to create petroleum products • Most refineries focus on producing transportation fuels • From a 42-gallon barrel of crude oil, refineries produce approximately 19 gallons on motor gasoline, 11 gallons of distillate fuel, and 4 gallons of jet fuel 11 11 Composition of Crude Oil Paraffins • Crude oil is primarily hydrocarbons • Commonly alkanes (paraffins), cycloalkanes (naphthenes), aromatic hydrocarbons, or more complicated chemicals like asphaltenes • The more hydrocarbons are in the oil, the lighter the oil is Hydrocarbons CH4, C2H6, C3H8, etc. Naphthenes C3H6 Aromatics 50 – 98% C6H6 Asphaltenes - Sulfur - - 0 – 10% Nitrogen - - 0 – 1% Oxygen - - 0 – 5% 12 12 1 - Intro to Oil and Gas 1-6 Oil Wells vs. Gas Wells • Oil wells are predominantly crude oil, with some natural gas dissolved in it • Associated gas: gas produced as a byproduct of the production of crude oil • Gas wells are predominantly natural gas • Natural Gas Condensate: a mixture of light liquid hydrocarbons, similar to a very light crude oil • Condensate is typically separated out of stream at the point of production when the temperature and pressure of the gas is dropped to atmospheric conditions https://certmapper.cr.usgs.gov/data/apps/noga-drupal/ 13 13 14 Source: https://www.eia.gov/state/maps.php 14 1 - Intro to Oil and Gas 1-7 How are oil and natural gas measured? • Typically measured in terms of volume • Standard Cubic Feet (scf) for natural gas (at 60°F and 1 atm) • Barrels or Gallons for oil wells • Also measured by potential energy output • British thermal units (Btu) • Therms = 100,000 Btu = 97 scf • Barrels of oil equivalent (BOE) = A unit of energy equal to 5.8-million British thermal units (5.8 MMBtu) based on the approximate energy released be burning one barrel of crude oil. 1 BOE = 5,650 scf natural gas 15 15 U.S. Oil and Gas Production • U.S. Energy Information Administration (EIA) publishes monthly energy reviews which include production, consumption, and trade for petroleum, natural gas, coal, electricity, nuclear energy, renewable energy, and international petroleum 16 16 1 - Intro to Oil and Gas 1-8 How did oil and natural gas form? • The remains of plants, animals, and microorganisms that lived millions of years ago • Formed when organic matter is compressed under the earth as high pressures for long periods of time • “Thermogenic methane” • Higher the temperature, more natural gas 17 Source: https://www.eia.gov/energyexplained/index.php?page=natural_gas_home 17 How else can you create methane? • Natural gas can also be created: • Through the breakdown of organic matter by microorganisms • Ex., Landfill Gas • As hydrogen-rich gases and carbon molecules rise from deep under Earth’s surface • Combines with minerals underground to create elements and compounds found in the atmosphere • Forms methane deposits as they move toward the surface of the earth This Photo by Unknown Author is licensed under CC BY-NC-ND 18 18 1 - Intro to Oil and Gas 1-9 Oil and Natural Gas Deposits • After oil and natural gas forms, it rises towards the surface through rock pore spaces because of its low density • Most of the oil and natural gas deposits occur where gas migrated into a highly porous and permeable rock underneath an impervious cap rock layer, thus becoming trapped before it could reach the surface and escape into the atmosphere • Reservoir: location where large volumes of oil and/or natural gas are trapped in the subsurface of the earth. 19 19 Conventional vs. Unconventional Wells • Two categories of petroleum and natural gas deposits: conventional and unconventional • Conventional natural gas deposits are commonly found in association with oil reservoirs, with the gas either mixed with the oil or buoyantly floating on top • Unconventional deposits include sources like shale gas, tight gas sandstone, and coalbed methane Source: https://www.eia.gov/energyexplained/index.php?page=natural_gas_home 20 20 1 - Intro to Oil and Gas 1-10 Where is the gas and oil located? 21 21 Marcellus Shale Formation • One of the largest shale formations in the United States • Underlies parts of New York, Pennsylvania, Ohio, West Virginia, and small portions of Maryland and Virginia • Contains about 84 trillion cubic feet of natural gas (according to USGS) 22 22 1 - Intro to Oil and Gas 1-11 https://www.youtube.com/watch?v=hnzOEWVAVlk 23 23 Where Our Oil Comes From • The United States is one of the largest crude oil producers • Five states accounted for 68% of total U.S. crude oil production in 2018: • Texas—40.5% • North Dakota—11.5% • New Mexico—6.3% • Oklahoma—5.0% • Alaska—4.5% • In 2018, nearly 16% of U.S. crude oil produced from offshore wells in the federally administered waters of the Gulf of Mexico 24 24 1 - Intro to Oil and Gas 1-12 Where Our Natural Gas Comes From • The United States now produces nearly all of the natural gas that it uses • Five states accounted for 65% of total U.S. dry natural gas production in 2017: • Texas—23% • Pennsylvania—20% • Oklahoma—8% • Louisiana—8% • Ohio—6% • 4% of U.S. dry natural gas was produced offshore in the Federal Gulf of Mexico in 2017 25 25 Natural Gas Imports and Exports • Most U.S. natural gas imports are from Canada (~97%) • Natural gas imports have been declining since 2007 • Natural gas exports are increasing • In 2018, the United States exported natural gas to 33 countries 26 26 1 - Intro to Oil and Gas 1-13 Petroleum Imports and Exports • Most of U.S. petroleum imports are from Canada (~43%) • In 2018, net imports of petroleum averaged 2.3 MMb/d, the equivalent to 11% of total U.S. petroleum consumption • The lowest percentage since 1957 • In 2018, total U.S. petroleum exports averaged about 7.6 MMb/d, including about 2.0 MMb/d of crude oil or about 26% of total petroleum exports 27 27 International Oil and Gas Production 28 28 1 - Intro to Oil and Gas 1-14 How much oil and gas is left? • Oil and natural gas are non- renewable resources • It is difficult to determine how much oil and natural gas is left in the ground to be extracted • Estimates are becoming more reliable with updated technologies • There is a vast amount of oil and natural gas estimated to still be in the ground 29 29 Proved Reserves • Proved reserves: volumes of hydrocarbon resources that analyses of geological and engineering data demonstrate to be recoverable under existing economic and operating conditions • U.S. proved reserves of oil and natural gas increased nearly every year since 2000 • Undiscovered technically recoverable resources are reserves that are expected to exist, but have not been proven 30 30 1 - Intro to Oil and Gas 1-15 Proved Reserves Trends 31 31 Where are the proved reserves located? 32 32 1 - Intro to Oil and Gas 1-16 U.S. Geological Basins • Map of geological basins, or “provinces,” in the United States was created by the American Association of Petroleum Geologists (AAPG) in 1968 (updated in 1991). • Adopted by the U.S. Geological Survey (USGS), and used in most federal programs 33 33 AAPG U.S. GEOLOGICAL BASINS MAP 34 34 1 - Intro to Oil and Gas 1-17 World Crude Oil and Natural Gas Reserves 35 35 Natural Gas Consumption in the U.S. • In 2018, the U.S. consumed ~30 Tcf of natural gas (approx. 31% of total energy consumption) • Natural gas use by U.S. consuming sectors by amount and share of total U.S. natural gas consumption in 2018: • Electric power—10.63 Tcf—35% • Industrial—10.04 Tcf—34% • Residential—4.97 Tcf—17% • Commercial—3.48 Tcf—12% • Transportation—0.84 Tcf—3% 36 36 1 - Intro to Oil and Gas 1-18 Uses of Natural Gas by Sector • Electric power sector – generate electricity • Industrial sector – • fuel for process heating • in combined heat and power systems • as a raw material (feedstock) to produce chemicals, fertilizer, and hydrogen • Residential sector • heat buildings and water • cook • dry clothes 37 37 Uses of Natural Gas by Sector • Commercial sector – • heat buildings and water • operate refrigeration and cooling equipment • cook, dry clothes, and provide outdoor lighting • Transportation sector uses natural gas as a fuel to operate compressors that move natural gas through pipelines and as a vehicle fuel in the form of compressed natural gas and liquefied natural gas 38 38 1 - Intro to Oil and Gas 1-19 Petroleum Consumption in the U.S. • In 2017, U.S. petroleum consumption averaged about 19.96 million barrels per day (b/d), which included about 1 million b/d of biofuels • Petroleum use by U.S. consuming sectors by amount and share of total U.S. natural gas consumption in 2017: • Transportation – 14.02 MMb/d – 71% • Industrial – 4.76 MMb/d – 24% • Residential – 0.52 MMb/d – 3% • Commercial – 0.47 MMb/d – 2% • Electric power – 0.10 MMb/d – 1% 39 39 What are the petroleum products people consume most? • Gasoline is most consumed petroleum product in U.S. (about 47% of total U.S. petroleum consumption in 2017) • Distillate fuel oil (includes diesel fuel and heating oil) is second most-consumed petroleum product in U.S. (about 20% of the total U.S. petroleum consumption in 2017) 40 40 1 - Intro to Oil and Gas 1-20 Where Petroleum and Natural Gas is Used • The five largest natural gas consuming states in 2017 were: • Texas—14.3% • California—7.8% • Louisiana—5.9% • Florida—5.1% • Pennsylvania—4.7% This Photo by Unknown Author is licensed under CC BY-NC-ND • The five largest gasoline consuming states in 2017 were: • Texas—11% • California—11% • Florida—5% • New York—4% • Georgia—4% 41 41 NATURAL GAS – FROM WELLHEAD TO BURNER TIP 42 42 1 - Intro to Oil and Gas 1-21 Generally… • Exploration and Production: Taking raw natural gas and crude oil from underground formations. • Gathering and Processing: Once natural gas is extracted from the earth, some processing happens at the wellhead, but complete processing happens at a plant. Natural gas is transported to the processing plants through a gathering system, which is a network of small-diameter, low-pressure pipelines. Almost all raw natural gas must be processed in some way to meet quality standards and regulations. In addition, natural gas is processed to separate the heavier hydrocarbon liquids from the gas, which are valuable by-products of gas processing (NGLs). • Transmission and Storage: Delivery of natural gas from the wellhead and processing plant to city gate stations or industrial end users. Transmission occurs through a vast network of high-pressure pipelines. Natural gas storage falls within this sector. Natural gas is typically stored in depleted underground reservoirs, aquifers, and salt caverns. • Distribution: Delivery of natural gas from the major pipelines to the end users (e.g., residential, commercial and industrial). 43 43 Oil and Gas Industry - An Overview 44 Source: https://www.epa.gov/natural-gas-star-program/overview-oil-and-natural-gas-industry 44 1 - Intro to Oil and Gas 1-22 Upstream vs. Midstream vs. Downstream • Upstream: Exploration and Production • Midstream: Gathering and Boosting, Processing • Downstream: Transmission and Storage*, Distribution *Transmission and Storage is can be considered part of Midstream 45 45 U.S. Natural Gas Pipeline Network, 2009 Interstate natural gas pipelines operate and transport natural gas across state borders. Intrastate natural gas pipelines operate and transport natural gas within a state border. 46 46 1 - Intro to Oil and Gas 1-23 Regulation of the Oil and Gas Industry • Only pipelines and local distribution companies (LDCs) are directly regulated with respect to the services they provide • The Federal Energy Regulatory Commission (FERC) has jurisdiction over the regulation of interstate pipelines and is concerned with overseeing the implementation and operation of the natural gas transportation infrastructure • Local distribution companies are regulated by state utility commissions • Natural gas producers and marketers are not directly regulated • Production and marketing companies must still operate within the confines of the law, but the prices they charge are a function of competitive markets 47 47 QUESTIONS? 48 48 1 - Intro to Oil and Gas 1-24 INTRODUCTION TO OIL AND GAS AIR EMISSIONS Chapter 2 1 1970 Clean Air Act (CAA) • National Ambient Air Quality Standards (NAAQS) for criteria pollutants (i.e., SO2, NOX, PM, ozone, CO, and lead) • State Implementation Plans (SIP) • New Source Performance Standards (NSPS) • National Emission Standards for Hazardous Air Pollutants (NESHAP) 2 2 2 – CAA, Combustion, Eq Lks 2-1 1977 CAA amendments • Expanded NSPS program • Prevention of significant deterioration (PSD) • New source review (NSR) • Nonattainment provisions applicable to areas not meeting the NAAQS • Required EPA to review the air quality criteria and NAAQS every 5 years • Recent review led to: • New NAAQS for PM fine • 35 micrograms per cubic meter (μg/m3) 24-hour average • 15 μg/m3 annual average • Revised NAAQS for ozone = 0.075 parts per million (ppm) 8-hour average • Revised NAAQS for lead = 0.15 μg/m3 3 3 1990 CAA amendments • Title I: Strengthened NAAQS and NSPS program • Title II: Mobile Sources and Clean Fuels • Title III: Air Toxics (Hazardous Air Pollutants) • Title IV: Acid Deposition Control • Title V: Operating Permits • Title VI: Stratospheric Ozone Protection 4 4 2 – CAA, Combustion, Eq Lks 2-2 Standard Size and Type of Unit, Process, or Facility Applicability Criteria Pollutants Regulated NSPS – New Source Performance Standards (40 CFR Part 60) Standards generally focus on emission units or processes that are called “affected” facilities. The affected facility may be at a major or minor source. NSPS standards apply to the “affected facility.” Standards generally regulate criteria pollutants. Some standards may regulate noncriteria pollutants (e.g., H2S, CH4) Pre-1990 NESHAP – National Emission Standards for Hazardous Air Pollutants (40 CFR Part 61) Standards focus on sources that emit certain levels of specific hazardous air pollutants. Standards could apply to either area or major sources. Applies to both new and Focus on specific HAPs (premodified sources. Upon 1990s) list identified in §61.01. modification, an existing source shall become a new source for each HAP for which the rate of emissions increases. Post-1990 NESHAP a.k.a. MACT standards (40 CFR Part 63) Standards generally focus on emission units/processes that are called “affected facilities.” Most standards affect major HAP sources; several standards established for area sources. Applies to existing, new, and reconstructed major HAP “affected sources” as defined in §63.2. Each standard defines affected source as it relates to specific standard. Focus on specific HAPs (post1990) list identified in §112(b). List includes pre-1990 NESHAPs. 5 5 Major Federal Regs for Oil and Gas 1. 40 CFR Part 60, Subpart JJJJ – Standards of Performance for Stationary Spark Ignition Internal Combustion Engines • Establishes emission standards and compliance requirements for the control of emissions from stationary spark ignition internal combustion engines that commenced construction, modification or reconstruction after June 12, 2006, where the SI-RICE are manufactured on or after specified manufacture trigger dates 2. 40 CFR Part 60, Subpart KKKK – Standards of Performance for Stationary Combustion Turbines • Establishes emission standards and compliance schedules for the control of emissions from stationary combustion turbines with a heat input at peak load equal to or greater than 10 million British thermal units per hour (MMBtu/h) that commenced construction, modification or reconstruction after February 18, 2005 6 6 2 – CAA, Combustion, Eq Lks 2-3 Major Federal Regs for Oil and Gas 3. 40 CFR Part 60, Subpart OOOO – Standards of Performance for Crude Oil and Natural Gas Production, Transmission, and Distribution for which Construction, Modification, or Reconstruction Commenced after August 23, 2011, and on or before September 18, 2015 • Establishes emission standards and compliance schedules for the control of VOC and SO2 emissions from affected facilities 4. 40 CFR Part 60, Subpart OOOOa – Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification, or Reconstruction Commenced After September 18, 2015 • Establishes emission standards and compliance schedules for the control of the pollutant GHGs • The GHG standard in this subpart is in the form of a limitation on emissions of methane • This subpart also establishes emission standards and compliance schedules for the control of VOC and SO2 emissions. 7 7 Major Federal Regs for Oil and Gas 5. 40 CFR Part 63, Subpart HH – National Emission Standards for Hazardous Air Pollutants from Oil and Natural Gas Production Facilities • Applies to the owners and operators of affected units located at natural gas production facilities that are major or area sources of HAPs and that process, upgrade, or store natural gas prior to the point of custody transfer, or that process, upgrade, or store natural gas prior to the point at which natural gas enters the natural gas transmission and storage source category or is delivered to a final end user, and that are major sources of hazardous air pollutants (HAP) emissions 6. 40 CFR Part 63, Subpart HHH – National Emission Standards for Hazardous Air Pollutants From Natural Gas Transmission and Storage Facilities • Applies to owners and operators of natural gas transmission and storage facilities that transport or store natural gas prior to entering the pipeline to a local distribution company or to a final end user (if there is no local distribution company), and that are major sources of hazardous air pollutants (HAP) emissions 8 8 2 – CAA, Combustion, Eq Lks 2-4 Major Federal Regs for Oil and Gas 7. 40 CFR Part 63, Subpart ZZZZ – National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines (RICE) • Establishes national emission limitations and operating limitations for HAPs emitted from stationary RICE • Applies to owners or operators of new and reconstructed stationary RICE of any horsepower rating which are located at a major or area source of HAP emissions 8. 40 CFR Part 63, Subpart YYYY – National Emission Standards for Hazardous Air Pollutants for Stationary Combustion Turbines • Establishes national emission limitations and operating limitations HAP emissions from stationary combustion turbines located at major sources of HAP emissions 9 9 Oil and Gas Pollutants of Concern 1. Oxides of Nitrogen (NOx): • A byproduct of the combustion of fuel and air • The heat of combustion causes the molecular nitrogen (N2) in the combustion air to disassociate and oxidize, forming NO and NO2 2. Carbon Monoxide (CO): • Results from the incomplete combustion of carbon • Formed when insufficient oxygen or poor mixing interferes with the combustion reaction to produce CO2 10 10 2 – CAA, Combustion, Eq Lks 2-5 Oil and Gas Pollutants of Concern 3. Volatile Organic Compounds (VOC): • Any compound of carbon, excluding carbon monoxide (CO), carbon dioxide (CO2), carbonic acid, metallic carbides or carbonates, and ammonium carbonate, which participates in atmospheric photochemical reactions • VOCs may be defined as non-methane non-ethane hydrocarbons (NMNEHC) 4. Hazardous Air Pollutants (HAP): • Air pollutants known to cause cancer or to have other serious health impacts • Released through combustion, fugitive emissions, venting, and the processing of natural gas • HAPs of primary concern are n-hexane; benzene, toluene, ethylbenzene, xylenes (collectively known as BTEX); and formaldehyde • Also known as “air toxics” 11 11 Oil and Gas Pollutants of Concern 5. Oxides of Sulfur (SOx or SO2): • Produced as the byproduct of combustion of a fuel that contains sulfur 6. Particulate Matter (PM): • Classifications of particulate matter based on size (i.e., PM10 and PM2.5) and state (i.e., filterable and condensable) • Primary particles – PM emitted directly from a source, such as construction sites, unpaved roads, or combustion • Secondary particles – PM formed in complicated reactions in the atmosphere from SO2 and NOx 12 12 2 – CAA, Combustion, Eq Lks 2-6 Oil and Gas Pollutants of Concern 7. Carbon Dioxide (CO2): • Sometimes present in natural gas in significant quantities • A primary byproduct of combustion • CO2 is a greenhouse gas (GHG) 8. Methane (CH4): • The primary component of natural gas • Represents a major portion of the emissions from oil and gas sites • Methane is also a GHG and a precursor to ground level ozone 13 13 Types of Emissions PROCESS COMBUSTION FUGITIVES 14 14 2 – CAA, Combustion, Eq Lks 2-7 STATIONARY COMBUSTION SOURCES 15 15 Stationary Combustion at Oil and Gas Sites • Primary fuels used are natural gas, diesel, gasoline, and propane • Natural gas – fuel-specific information based on measurements are preferred over default values • Diesel, gasoline, and propane – fuel-specific information may be available from fuel suppliers or from MSDS for purchased fuel • The main pollutants emitted from the exhaust of combustion devices are NOX, CO, VOC, formaldehyde (HAP), SOX, PM, and GHGs, depending on the composition of the fuel used 16 16 2 – CAA, Combustion, Eq Lks 2-8 Combustion Emission Sources • Boilers/steam generators • Glycol dehydrator reboilers • Heater treaters • Generators • Fire pump • Compressor drivers (SI RICE, turbines) • Well drilling drivers (SI RICE) • Control Devices: Flares, Incinerators/Combustors 17 17 Combustion Emissions Estimation Approaches 1. AP-42 Emission Factors Sources: AP 42, Fifth Edition, Volume I, Chapter 1: External Combustion Sources; AP-42 Fifth Edition, Volume I, Chapter 3: Stationary Internal Combustion Sources https://www.epa.gov/air-emissions-factors-and-quantification/ap-42compilation-air-emissions-factors Calculation: Emissions [lb/yr] = EF [lb/MMscf] x Fuel Consumption [MMscf/hr] x Op Hours [hr/yr] or Emissions [lb/yr] = EF [lb/mmbtu] x Heat Input Capacity [mmbtu/hr] x Op Hours [hr/yr] 18 18 2 – CAA, Combustion, Eq Lks 2-9 19 19 Combustion Emissions Estimation Approaches 2. Manufacturer Documentation Source: Manufacturer-provided emissions data sheet Calculation: Emissions [lb/hr] = EF [g/KW-hr] x Engine Power [KW] x Op Hours [hr/yr] x 0.0022 [g/lb] Example: 20 20 2 – CAA, Combustion, Eq Lks 2-10 Combustion Emissions Estimation Approaches Part 98 Subpart C Emission Factors for GHG Emissions Source: EPA’s Greenhouse Gas Reporting Program – Part 98, Subpart C, Tiers 1 – 3 methodologies (98.33) Calculation: Tier 1: 3. Tier 2: Tier 3: 21 21 Control Technologies For Combustion Sources • Control technologies vary by sources, but may include: • Process controls (ex., fuel switching, fuel denitrification, coal cleaning, etc.) • Combustion controls (ex., low NOx burners, water/stream injection, flue gas recirculation, etc.) • Post-process controls (ex. Selective catalytic reduction (SCR), Selective noncatalytic reduction (SNCR), Nonselective catalytic reduction (NSCR), Catalytic oxidizers 22 22 2 – CAA, Combustion, Eq Lks 2-11 Pollution Control Efficiency • Control efficiency is a measure of emission reductions achieved by a control technology, whether it is a pollution prevention measure or an add on control device • Control efficiencies are typically specified by the manufacturer of the control technology and vary by pollutant • Example – for a combustion device with a Selective Catalytic Reduction (SCR), NOx emissions may be reduced by 95% • Calculated uncontrolled NOx emissions should then be reduced by 95% 23 23 Actual Combustion Emissions • Actual emissions calculated using actual fuel use and/or actual operating hours • If the emission factor is in units of pounds per quantity of fuel (gallons or cubic feet): Actual emissions (tpy) = Emission Factor (lb/unit) x Actual Annual Fuel Use (unit) x ([100 - Control Efficiency]/100) • If the emission factor is in units of pounds per hp-hr power output or pounds per MMBtu heat input: Actual Emissions (tpy) = Emission Rate [lb/hr] x Actual Operating Hours [hr] x 0.005 [ton/lb] x ((100 – Control Efficiency)/100) 24 24 2 – CAA, Combustion, Eq Lks 2-12 EQUIPMENT LEAKS 25 25 Equipment Leaks • Equipment leaks are typically low-level, unintentional losses of process gas from the sealed surfaces of process equipment • Leak emissions are primarily CH4 and VOCs • Typical leaking components: • Valves • Flanges and other connectors • Pump Seals • Compressor Seals • Pressure Relief Valves • Open-ended lines • Sampling Connections 26 26 2 – CAA, Combustion, Eq Lks 2-13 This Photo by Unknown Author is licensed under CC BY This Photo by Unknown Author is licensed under CC BY-SA This Photo by Unknown Author is licensed under CC BY-SA This Photo by Unknown Author is licensed under CC BY-SA 27 27 Why do leaks happen? • Leaks occur due to: • Changes in pressure, temperature This Photo by Unknown Author is licensed under CC BY-SA and mechanical stresses on equipment • Loose connections • Wear on seals and gaskets during normal operation of equipment • Weather conditions • Equipment that is not operating correctly, such as storage vessel thief hatches that are left open or separator dump valves that are stuck open 28 28 2 – CAA, Combustion, Eq Lks 2-14 Control Techniques for Equipment Leaks: LDAR Programs • A Leak Detection and Repair (LDAR) program is a facility’s system of procedures to minimize fugitive VOC, HAP, and GHG emissions from leaking components • A portable detection device is used to identify leaking equipment above a specified threshold (e.g., 10,000 ppmv) and these leaks are then repaired • Most LDAR requirements include: • Approved methods for detecting natural gas leaks • Definition of a leak • Equipment and components required to be monitored • Monitoring frequency (e.g., monthly, quarterly, semiannually, annually) • Leak repair requirements • Recordkeeping and reporting 29 29 LDAR Using EPA Method 21 • When performing Method 21 source screening, the portable analyzer probe opening is placed at the leak to obtain a "screening" value • The screening value is the concentration level of leaking natural gas • Example instrument detector types for meeting EPA Method 21 criteria include flame ionization detectors (FID) and photo ionization detectors (PID) This Photo by Unknown Author is licensed under CC BY-SA 30 30 2 – CAA, Combustion, Eq Lks 2-15 LDAR Using Optical Gas Imaging • An optical gas imaging (OGI) camera can be considered a highly specialized version of an infrared or thermal imaging camera • OGI cameras are used to visualize leaks This Photo by Unknown Author is licensed under CC BY-SA 31 31 https://www.youtube.com/watch?v=N5hA_x3BHuw 32 32 2 – CAA, Combustion, Eq Lks 2-16 https://www.youtube.com/watch?v=N5hA_x3BHuw 33 33 Audio/Visual/Olfactory (AVO) Inspections • Combines three inspection methods: • Audio (to hear leaking gas) • Visual (to see visible ruptures in equipment) • Olfactory (to smell odor added to methane for safety) This Photo by Unknown Author is licensed under CC BY-NC 34 34 2 – CAA, Combustion, Eq Lks 2-17 What defines a leak in a LDAR inspection? • Leaks are defined in each regulation, and may differ between regulations • Typical leak definitions: • Using an OGI Camera: any visible emission detected by an OGI camera calibrated according to 40 CFR 60.18 and a detection sensitivity level of 60 g/h • Using Method 21: a concentration greater than or equal to the applicable regulatory leak definition, calibrated as methane, detected by an instrument that meets the requirements of 40 CFR Part 60, Appendix A-7, Method 21 • Using AVO: any positive indication, whether audible, visual, or odorous, determined during an AVO inspection 35 35 Repairing the Leak • If a leak is detected, the owner/operator typically must tag the leak location and repair the leak • For example, NSPS OOOOa requires that the owner or operator make a first attempt of repair within 30 days of the detection of the leak and the leak be repaired no later than 60 days after the leak is detected • A leak is typically considered repaired if one of the following can be demonstrated: • No detectable emissions consistent with 40 CFR Part 60, Appendix A-7, Method 21 Section 8.3.2 • A concentration of less than 500 ppm calibrated as methane is detected when the gas leak detector probe inlet is placed at the surface of the component • No visible leak image when using an OGI camera calibrated in accordance with 40 CFR §60.18 with a detection sensitivity of 60 g/h • No bubbling at leak interface using a soap solution bubble test specified in Section 8.3.3 of 40 CFR Part 60, Appendix A-7, Method 21 36 36 2 – CAA, Combustion, Eq Lks 2-18 LDAR Frequency • Monitoring frequency varies depending on the regulatory programs. This can include: • Weekly audio, visual, olfactory (AVO) methods • Quarterly, semiannual or annual monitoring using Method 21 or OGI camera • Operators may reduce monitoring frequency if the leak rates are less than a set percentage of the total number of components; this can vary from 2% to 5% of the total • For most programs, if the monitored leak percentage is below the set percentage for a certain amount of time, the operator can skip a monitoring period 37 37 LDAR Recordkeeping and Reporting • Monitoring records must be kept on location or other approved location and available for inspection by the regulatory agency • Typical recordkeeping includes all monitoring records such as: • Monitoring dates • Monitoring equipment used • Calibration records • Listing of components monitored • Number of leaks detected • Date(s) of successful repair of the leak(s) • Deviations from the monitoring plan 38 38 2 – CAA, Combustion, Eq Lks 2-19 Federal Regulations with LDAR Requirements • Examples of regulations and programs that require, may require or encourage the use of LDAR for O&G facilities include: • 40 CFR 60 Subpart OOOO – tank hatches and closed vent system for storage tank emission controls • 40 CFR 60 Subpart OOOOa • 40 CFR 98 Subpart W – Mandatory Greenhouse Gas (GHG) Reporting rule • 40 CFR 60 Subpart KKK 39 39 Equipment Leak Estimation Approaches • Two general approaches: population emission factors and leaker emission factors 1995 Protocol for Equipment Leak Emission Estimates Source: U.S. EPA https://www3.epa.gov/ttnchie1/efdocs/equiplks.pdf Calculation: Emissions [kg/hr] = EF [kg/hr/source] × Weight Fraction of Pollutant × Number of Equipment x Op Hours Emissions [kg/hr] = (EF [kg/hr/source] × Leaker Count × Weight Fraction of Pollutant) + (EF [kg/hr/source] × Non-Leaker Count × Weight Fraction of Pollutant) 1. 40 40 2 – CAA, Combustion, Eq Lks 2-20 41 41 Equipment Leak Estimation Approaches 2. Emission Factors from Other Research Sources 42 42 2 – CAA, Combustion, Eq Lks 2-21 43 Source: Control Techniques Guidelines for the Oil and Natural Gas Industry, 2016 43 QUESTIONS? 44 44 2 – CAA, Combustion, Eq Lks 2-22 EXPLORATION AND DRILLING Chapter 3 1 Overview • How is natural gas and petroleum found? • How do companies decide where to drill wells? • Understand the process of drilling a well • What is horizontal drilling? 2 2 3 - Drilling 3-1 Steps of Oil and Natural Gas Development • Finding the right geology • Leasing • Geologic evaluation • Complying with regulatory requirements • Drilling • Completing the well, which may include hydraulic fracturing • Getting the product to market This Photo by Unknown Author is licensed under CC BY-SA 3 3 HOW IS NATURAL GAS AND PETROLEUM FOUND? 4 4 3 - Drilling 3-2 Conventional vs. Unconventional Wells • Conventional Oil and Natural Gas Production: Crude oil and natural gas that is produced by a well drilled into a geologic formation in which reservoir and fluid characteristics permit oil and natural gas to readily flow to the wellbore • Unconventional oil and natural gas production: An umbrella term for oil and natural gas that is produced by means that do not meet criteria for conventional production • Hydrocarbon reservoirs that have low permeability and porosity Source: https://www.eia.gov/energyexplained/index.php?page=natural_gas_home 5 5 Oil and Gas Exploration • Exploration: the search by petroleum geologists and geophysicists for deposits of hydrocarbons, particularly petroleum and natural gas, in the Earth using petroleum geology • Visible surface features such as oil seeps, natural gas seeps, pockmarks (underwater craters caused by escaping gas) provide basic evidence of hydrocarbon generation (be it shallow or deep in the Earth) • Anticlinal slopes: areas where the Earth has folded up on itself, forming a dome shape that is characteristic of a great number of reservoirs 6 6 3 - Drilling 3-3 Surface Features • Geologists make inferences from outcroppings of rocks on the surface or in valleys and gorges, geologic information attained from the rock cutting, and samples obtained from digging of irrigation ditches, water wells, and other oil and gas wells This Photo by Unknown Author is licensed under CC BY-SA 7 7 Mapping Underground Formations • Once the geologist has determined an area where it is geologically possible for a natural gas or petroleum formation to exist, a geophysicist will use technology to find and map underground rock formations • Geophysicists often use seismology to determine the layers under the Earth’s surface • Seismology: the study of how energy, in the form of seismic waves, moves through Earth’s crust and interacts differently with various types of underground formations This Photo by Unknown Author is licensed under CC BY-SA 8 8 3 - Drilling 3-4 9 9 Other Tools Used to Map the Subsurface • The magnetic properties of underground formations can be measured to generate geological and geophysical data • Magnetometers: devices that can measure the small differences in the Earth’s magnetic field • Geophysicists can also measure and record the difference in the Earth’s gravitational field to gain a better understanding of what is underground using gravimeters • Different underground formations and rock types all have a slightly different effect on the gravitational field that surrounds the Earth 10 10 3 - Drilling 3-5 HOW DO COMPANIES DECIDE WHERE TO DRILL WELLS? 11 11 Leasing • Leasing allows exploration and production on a tract of land • Companies will enter into lease or purchase agreements with private landholders, local and state governments, the Department of Interior’s Bureau of Land Management (BLM) for onshore federal land, and the Bureau of Ocean Energy Management (BOEM) for offshore federal land This Photo by Unknown Author is licensed under CC BY-SA 12 12 3 - Drilling 3-6 Exploratory Wells • With lease in hand, companies move quickly to select the best drilling target • The best way to gain a full understanding of subsurface geology and the potential for natural gas deposits to exist in a given area is to drill an exploratory well • Exploratory well: a well drilled with the intent to discover a new petroleum reservoir • Exploratory wells are also known as “wildcat wells” or “exploration wells” • Drilling an exploratory well is an expensive, time consuming effort • Exploratory wells are only drilled in areas where other data has indicated a high probability of petroleum formations • Exploratory wells are usually drilled only vertically, with horizontal drilling only occurring if the well is believed to be productive 13 13 Logging • Logging refers to performing tests during or after the drilling process to allow geologists and drill operators to monitor the progress of the well drilling and to gain a clearer picture of subsurface formations • Various types of tests include standard, electric, acoustic, radioactivity, density, induction, caliper, directional and nuclear logging • Standard logging: examining and recording the physical aspects of a well • The drill cuttings (pieces of rock displaced by the drilling of the well) are all examined and recorded, allowing geologists to physically examine the subsurface rock • Electric logging consists of lowering a device used to measure the electric resistance of the rock layers in the down hole portion of the well 14 14 3 - Drilling 3-7 Producing Formations • Geologists evaluate logging data to determine whether it matches their geological model • If there is no oil and gas when the drill reaches the targeted rock layer, then the well is considered a “dry hole” • Dry holes must be plugged and abandoned • If oil and gas is found, it’s called a “discovery” 15 15 Appraisal and Delineation Phase • If oil or gas is discovered from an exploratory well, companies will assess the potential of the discovery – the “Appraisal Phase” or “Delineation Phase” • Appraisal/delineation wells may be drilled to collect more information to assess the size and viability of the new reservoir • Appraisal wells are nearly identical to exploration wells, except that they are drilled into a newly discovered reservoir • Reservoir engineers will provide recommendations on the number and positioning of future production wells 16 16 3 - Drilling 3-8 Development Phase • During the development phase, wells are drilled with the primary objective of hydrocarbon production • Development well: A well drilled within the proved area of an oil or gas reservoir to the depth of a stratigraphic horizon known to be productive • Also known as a “production well” 17 17 THE DRILLING PROCESS 18 18 3 - Drilling 3-9 Onshore Drilling Methods • Two main types of onshore drilling: percussion drilling and rotary drilling • Percussion, or “cable tool” drilling: process of raising and dropping a heavy metal bit into the ground, effectively punching a hole down through the Earth • Rotary drilling: a sharp, rotating metal bit is used to drill through the Earth’s crust • Torque (rotation) is applied to the Drill Pipe or Drill String (hollow steel tubing) with a drill bit attached to the end of the Bottom-Hole Assembly (BHA) 19 19 Drilling Rigs • Drilling Rig: a machine which creates the holes (usually called boreholes) and/or shafts in the ground. • The term “rig” generally refers to the complete complex of equipment that is used to make a well • Five major components of a drilling rig: 1. 2. 3. 4. 5. Power System Hoisting System Rotating System Circulating System Blowout Prevention System Source: https://www.e-education.psu.edu/png301/node/704 20 20 3 - Drilling 3-10 The Power System • Power System: provides the power for the other systems on the rig (e.g., electrical systems, pumps, etc.) • Consists of: • A prime mover: component of the power system that generates raw power • A means to transmit the power – either mechanical, direct current (DC) electrical generator, or alternating current (AC) electrical generator with silicon-controlled rectifier (SCR) to direct current (DC) • Fuel storage • Electric control house This Photo by Unknown Author is licensed under CC BY-SA-NC 21 21 The Hoisting System • Hoisting system: used to raise, lower, and suspend the drill string and lift casing and tubing for installation into the well • Consists of: • Derrick (or mast): provides structural support for the hoist system • Crown block & travel block: form a Block and Tackle System on rig • Drawworks: a winch that reels the drilling line in or out causing the traveling block to move up or down This Photo by Unknown Author is licensed under CC BY-SA-NC 22 22 3 - Drilling 3-11 Conventional Rotary Table Rigs • A conventional rotary rig is a drilling rig where the rotation of the drill string and bit is applied from a rotary table on the rig floor • Also known as a “rotary table rig” or “kelly drive rig” • The kelly is a hollow square or hexagonal piece of pipe in which the drill pipe can be passed through This Photo by Unknown Author is licensed under CC BY-SA 23 This Photo by Unknown Author is licensed under CC BY-SA-NC 24 23 Top-Drive Rig • A top-drive rig is a drilling rig that which uses a top drive (a motor that is suspended from the derrick) to rotate the drill string during the drilling process • The advantages of a top-drive rig are that longer sections of drill pipe can be either: 1. 2. 3. connected to the drill string when the rig crew is drilling ahead connected to the drill string when tripping into the hole unconnected from the drill string when tripping out of the hole 24 3 - Drilling 3-12 The Rotary System • The Rotary System: the rotating equipment on a rotary drilling rig consists of the components that actually serve to rotate the drill bit, which, in turn, sends the hole deeper and deeper into the ground This Photo by Unknown Author is licensed under CC BY-NC This Photo by Unknown Author is licensed under CC BY-SA 25 25 Drill Bit • A drill bit is a rotating apparatus that usually consists of two or three cones made up of the hardest of materials (usually steel, tungsten carbide, and/or synthetic or natural diamonds) and sharp teeth that cut into the rock and sediment below This Photo by Unknown Author is licensed under CC BY-SA This Photo by Unknown Author is licensed under CC BY-SA • It is what actually cuts into the rock when drilling an oil or gas well • Types of drill bits: • Roller Cone (or Tri-Cone) Bits • Fixed Cutter Bits This Photo by Unknown Author is licensed under CC BY-NC-ND 26 26 3 - Drilling 3-13 https://www.youtube.com/watch?v=Su3Rf5pFQyM 27 27 The Circulation System • The Circulation System: the system that allows for circulation of the Drilling Fluid (or “Mud”) down through the hollow drill string and up through the annular space between the drill string and wellbore • Mud: a mixture of water, clay, weighting material, and chemicals Source: https://www.osha.gov/SLTC/etools/oilandgas/drilling/mud_system.html 28 28 3 - Drilling 3-14 Uses of Mud • lift drill cuttings from the bottom of the • minimize reservoir damage (assure low skin wellbore to the surface • suspend cuttings to prevent them from falling downhole if circulation is temporarily ceased • cool the drill bit during drilling operations • lubricate the drill bit during drilling operations • release the cuttings when they are brought to the surface • allow for pressure signals from Logging While • stabilize the borehole during drilling operations • control formation pore pressures to assure desired well control • deposit an impermeable filter cake onto the wellbore walls to further prevent fluids from permeable formations from entering the wellbore values) when drilling through the reservoir section of the well Drilling (LWD) or Measurement While Drilling (MWD) tools to be transmitted to the surface • allow for pressure signals to be sent to the bottom of the well to pressure actuate certain downhole equipment • minimize environmental impact on subsurface natural aquifers 29 29 What actually is “mud”? • Options for mud: • Water-based muds (WBM) (most frequently used) • Base may be either fresh water or saltwater • Oil-based muds (OBM) • Synthetic materials • Foams • Air • Drilling muds typically have several additives (weighting materials, corrosion inhibitors, dispersants, etc.) Source: OSHA, https://www.osha.gov/SLTC/etools/oilandgas/drilling/drillingfluid.html 30 30 3 - Drilling 3-15 Mud and Drill Cuttings Disposal • Drilling mud is recirculated, which helps decrease waste by reusing as much mud as possible • Drilling mud is classified as “special waste,” which means they are exempt from many federal regulations • Pit burial is a common disposal technique for water-based mud and cuttings • Oil- and synthetic-based muds can be recycled at other well sites 31 31 The Blowout Prevention System • The Blowout Prevention System on a drilling rig is the system that prevents the uncontrolled, catastrophic release of high-pressure fluids (oil, gas, or salt water) from subsurface formations • Blowouts: uncontrolled flow of formation fluids from a well This Photo by Unknown Author is licensed under CC BY-SA 32 32 3 - Drilling 3-16 Blowout Preventer • Common types of valves in a blowout preventer: • Annual preventer - used to prevent This Photo by Unknown Author is licensed under CC BY-SA This Photo by Unknown Author is licensed under CC BY-SA flow through the annular space between the drill string or casing and the annular preventer • Blind rams - isolate both the pipe and the annular space by crushing the pipe and it pinching-off when closed • Pipe rams - isolate the annular space by wrapping around the pipe when closed • Shear rams - isolate both the pipe and the annular space by shearingoff the pipe when closed This Photo by Unknown Author is licensed under CC BY-SA 33 33 Kicks • Kick: a flow of formation fluids into the wellbore during drilling operations • A kick is physically caused by the pressure in the wellbore being less than that of the formation fluids, thus causing flow • Kick can be caused in two ways: 1. 2. If the mud weight is too low, then the hydrostatic pressure exerted on the formation by the fluid column may be insufficient to hold the formation fluid in the formation dynamic and transient fluid pressure effects, usually due to motion of the drillstring or casing, effectively lower the pressure in the wellbore below that of the formation 34 34 3 - Drilling 3-17 https://www.youtube.com/watch?v=9NQ8LehUWSE 35 35 How to Drill a Well – A Step by Step Guide Step #1: Plan the Well • Develop detailed drilling proposals • Obtain all necessary permits • Permits to drill typically require an application to the appropriate state, including evidence of mineral rights ownership/lease, a plan of operation, a site plan, and a fee to drill • Permits typically must be renewed annually until reclamation is complete Step #2: Perform a Shallow Gas Survey • A shallow gas survey is performed to identify the locations and depths of any potential shallow gas hazards This Photo by Unknown Author is licensed under CC BY-SA 36 36 3 - Drilling 3-18 Step #3: Land Drilling Preparation • Before an onshore well can be drilled: • The site must be prepared, including leveling the land on which the derrick will be assembled • Access roads must be created so workers and equipment can get to/from the rig • Reserve pits need to be dug or large metal bins brought in so cuttings, material, and used mud can be properly disposed of • Cellar: A pit in the ground to provide additional height between the rig floor and the well head to accommodate the installation of blowout preventers, ratholes, mouseholes, etc. Source: Mallone, Samantha. Rig in operation (currently drilling) in WV. 09/26/2013. Provided by FracTracker Alliance, fractracker.org/photos. 37 37 Step #4: Set the Conductor Casing • Before the drill rig arrives, a conductor hole is drilled approximately 100-200 ft deep • Conductor hole is then lined with conductor casing and cemented into place • Conductor casing is typically set through the topsoil and loose rocks to the bed rock Source: https://www.osha.gov/SLTC/etools/oilandgas/glossary_of_terms/glossary_of_terms_c.html 38 38 3 - Drilling 3-19 Step #5: Moving In and Rigging Up • “Rigging-up” begins as the rig is hoisted into position and the equipment substructure is centered over the conductor pipe • The mast or derrick is raised over the substructure and other equipment such as engines, pumps, and rotating and hoisting equipment are aligned and connected • Water and fuel tanks are filled • Additives for the drilling mud are stored on location Source: Donnan, Bob. Drilling pad, PA. 12/22/2014. Provided by FracTracker Alliance, fractracker.org/photos. 39 39 Step #6: Spudding In • “Spudding a Well” refers to starting the rotary drilling operations for that well This Photo by Unknown Author is licensed under CC BY-NC 40 40 3 - Drilling 3-20 Step #7: Drill Down to the Surface Casing Depth • The first section of the well to be drilled is the section that goes down to the surface casing point • Installation of surface casing puts the environmentally sensitive water table behind pipe and protecting it from future well (drilling and production) activities • Typically drilled with the most environmentally-friendly mud and cased and cemented ASAP Source: https://prd-wret.s3-us-west-2.amazonaws.com/assets/palladium/production/s3fspublic/Steel_Pipe_for_Gas_Well.jpg 41 41 Step #8: Run and Cement the Surface Casing • Once the surface casing point is reached, surface casing is run into wellbore and cemented into place • This process is performed by: • Pulling Out of Hole (POOH): Tripping out of the hole with the drill pipe to remove it from wellbore during cementing operations • Running the surface casing • Pumping a cement slurry down the interior of the casing • Chasing cement with drilling fluid to displace the cement up into the annular space between casing string and the wellbore (rock) • Allowing time for the cement to cure This Photo by Unknown Author is licensed under CC BY-NC-ND 42 42 3 - Drilling 3-21 Step #9: Continue this Process to Drill to Each of the Next Casing Points • Drilling process is continued to the next pre-determined casing point to create intermediate casing strings • The objectives of the intermediate casing strings are: • Isolate unstable hole sections behind pipe • Isolate lost circulation zones behind pipe • Isolate under-pressured zones behind pipe (prevent lost circulation) • Isolate over-pressured zones behind pipe (prevent a kick) • Isolate multiple producing zone This Photo by Unknown Author is licensed under CC BY-SA-NC 43 43 Final Steps Step #10: Continue this Process to Drill to Total Depth • Once final intermediate casing string is run and cemented, drilling process is continued until well reaches the TD (Total Depth) of well Step #12: Run and Cement Production Casing String or Liner Step #13: Complete the Well Step #14: Rig Down and Move Out Step #11: Log Well with OpenHole Logs • Open-hole logs are used to measure certain properties of subsurface formation 44 44 3 - Drilling 3-22 WHAT IS HORIZONTAL DRILLING? 45 45 Horizontal Drilling • Horizontal drilling: involves deliberately shifting a well’s path from the vertical until they are running horizontally • “Directional drilling” or “deviated drilling” • Reasons for horizontal drilling: • To avoid a surface site that is operationally difficult or environmentally sensitive • Drilling an offshore well from an onshore site • Reducing costs or surface impact by drilling several wells in different directions from the one surface location • Enhancing oil and gas production by drilling in a way that exposes more of the reservoir to the wellbore This Photo by Unknown Author is licensed under CC BY-NC-ND 46 46 3 - Drilling 3-23 How to Horizontally Drill • Vertical well is drilled to the Source: https://www.dmr.nd.gov/ndgs/documents/newsletter/2008Winter/pdfs/Horizontal.pdf kickoff point located just above targeted oil or gas layer • Curved section of a horizontal well is drilled using a hydraulic motor mounted directly above the bit and powered by drilling fluid • Steering of the hole is accomplished through employment of a slightly bent or “steerable” downhole motor 47 47 https://www.youtube.com/watch?v=eBOtXD_UQSo 48 48 3 - Drilling 3-24 QUESTIONS? 49 49 3 - Drilling 3-25 OIL AND GAS COMPLETIONS Chapter 4 1 Overview • What is the process of a well completion? • What is hydraulic fracturing and why is it controversial? • What is artificial lift and why is it needed? • What is a workover? 2 2 4 - Completions and Workovers 4-1 What is a well completion? • Well completion: the activities and methods of preparing a well for the production of oil and gas or for other purposes, such as injection • Purposes of a well completion are to: • Connect reservoir to surface so that fluids can be produced from or injected into reservoir • Provide a conduit for well stimulation treatments • Isolate producing reservoir from other zones • Protect integrity of reservoir, especially in unconsolidated formations • Provide a conduit to measure changes in flow rate and pressure needed to run a well test 3 3 Phases of Well Completions 1. Casing - many consider the setting of the casing to be the first step in a well completion 2. Perforation – where holes are blasted through the casing at precise locations for stimulation and production flow; often done in conjunction with tubing, packing, and setting up the Christmas tree 3. Stimulation – hydraulic fracturing, acidizing; preparing the rock formation for optimal flow 4 4 4 - Completions and Workovers 4-2 Three Types of Completion Methods • Open-Hole Completions: a well that is drilled to the top of the hydrocarbon reservoir; the well is then cased at this level, and left open at the bottom • Although not common in most areas, open hole completions are still used today in certain situations • Casing is set prior to drilling into the producing interval; a nondamaging fluid can then be used to drill into the pay section 5 This Photo by Unknown Author is licensed under CC BY-SA 5 Three Types of Completion Methods • Liner Completions: Many conventional well designs include a production liner set across the reservoir interval; this reduces the cost of completing the well and allows some flexibility in the design of the completion in the upper wellbore, such as when the fluid characteristics make it beneficial to increase the diameter of the conduit and components • Liner: any string of casing in which the top does not extend to the surface but instead is suspended from inside the previous casing string This Photo by Unknown Author is licensed under CC BY-NC-ND 6 6 4 - Completions and Workovers 4-3 Gravel Packing and Screens • To prevent sand from entering the wellbore, companies may also opt for a sand control technique – or combination of techniques – that include various types of sand screens and gravel packing systems • Wire screens and gravel pack work together to filter out sand that might have otherwise entered the wellstream with the hydrocarbons This Photo by Unknown Author is licensed under CC BY 7 7 Three Types of Completion Methods • Perforated Cased-Hole Completions: production casing is run along the entire length of the well and through the reservoir • The cased hole acts as a control mechanism for safe production of desired hydrocarbons and as a barrier preventing the reintroduction of unwanted fluids, gases, and solids into the wellbore • Casing must be perforated to stimulate production from viable sections of the reservoir called “pay zones” 8 8 4 - Completions and Workovers 4-4 Perforating the Casing • Purpose of perforating the production casing is to provide effective flow communication between the wellbore and the reservoir • Majority of wells use a shaped charge perforating system • Perforating guns can be expendable, semi-expendable, or retrievable Source: USGS, https://www.usgs.gov/media/images/perforating-gun-hydraulic-fracturing 9 9 Well Stimulation Techniques • Acidizing: injection of chemicals to eat away at any skin damage, "cleaning up" the formation, thereby improving the flow of reservoir fluids • Fracturing: creating and extending fractures from perforation tunnels deeper into the formation, increasing surface area for formation fluids to flow into well, as well as extending past any possible damage near the wellbore This Photo by Unknown Author is licensed under CC BY-SA 10 10 4 - Completions and Workovers 4-5 Production String • Production String: primary conduit through which reservoir fluids are produced to surface • Production string is typically assembled with tubing and completion components in a configuration that suits the wellbore conditions and the production method • An important function of production string is to protect primary wellbore tubulars, including the casing and liner, from corrosion or erosion by the reservoir fluid This Photo by Unknown Author is licensed under CC BY-ND 11 11 Production Tubing • Production Tubing: along with other components that constitute the production string, provides a continuous bore from the production zone to the wellhead through which oil and gas can be produced • Tubing is usually between five and ten centimeters in diameter • Purpose and design of production tubing is to enable quick, efficient, and safe installation, removal and re-installation • Tubing Packer: a sealing device that isolates and contains produced fluids and pressures within the tubing string 12 This Photo by Unknown Author is licensed under CC BY-NC-ND 12 4 - Completions and Workovers 4-6 Wellhead and Christmas Tree • Wellhead: surface termination of a wellbore that incorporates facilities for installing casing hangers during the well construction phase • Consists of the casing head, the tubing head, and the christmas tree • Christmas Tree: An assembly of valves, spools, pressure gauges and chokes fitted to wellhead of a completed well to control production • Primary function of a tree is to control flow into or out of the well • Additional functions include chemical injection points, well intervention means, pressure relief means, and well monitoring points This Photo by Unknown Author is licensed under CC BY-SA 13 13 14 https://www.youtube.com/watch?v=iXdq65xzsus 14 4 - Completions and Workovers 4-7 HYDRAULIC FRACTURING 15 15 What is hydraulic fracturing? • Hydraulic Fracturing: making use of a liquid to fracture the reservoir rocks by pumping the fracturing fluid into the wellbore at a rate sufficient to increase pressure downhole to exceed the strength of the rock • Also known as “Fracking” or “Frac” • Fracking can be completed on both horizontal and vertical wells • Multiple fracking intervals may be performed along the length of the well (“stages”) This Photo by Unknown Author is licensed under CC BY 16 16 4 - Completions and Workovers 4-8 The Hydraulic Fracturing Process Preparing • Before fracking begins, operators perform several tests to confirm that the well and associated equipment can withstand the pressures of the fracturing operation • A perforating tool is then lowered into the wellbore to create small holes in the production casing • Next the frac job begins • On a well with a long horizontal section in the hydrocarbon-bearing formation, the well is not perforated and fracked all at once; rather it is done in a series of stages each being several hundred feet in length 17 17 The Hydraulic Fracturing Process – Equipment • Wellhead: pipe extending up from the ground with a shut off valve above it and pipelines attached to carry a specific formula of water, sand, and chemicals to frac well • Pump trucks: positioned next to the well; powerful (1,200 to 2,500 horsepower) pumps move the materials into the formation • Blender truck: pulls together the material needed to frac the well; a long mixing machine that takes sand, or ceramic bead propping agent, water, and chemicals to prepare a gel that carries the propping agent into the formation as deeply as possible 18 18 4 - Completions and Workovers 4-9 The Hydraulic Fracturing Process – Equipment • Chemical supply trucks: a stake-body truck with placards showing if and what types of hazardous chemicals are on board • Sand hogs: sand or proppant multi-compartment containers; connected to the blender by an auger or conveyor • Water storage: ponds (“impoundments”) or tanks (“frac tanks”) • Frac operator van: has computers, electronic monitoring and communications equipment from which to direct all fracturing operations • Flowback tanks: collect flowback water 19 19 Fracturing Fluids • In general, a fracturing fluid can be thought as the sum of three main components: Fracturing Fluid = Base Fluid + Additives + Proppant • Base Fluids: Water, Foams, Oils, Emulsions, etc. • Additives: serve a variety of purposes to optimize the performance of the injected fluid, including viscosity control, corrosion inhibition, and control of microbial activity • Proppant: used to prop open the fractures, predominantly consists of quartz sand • The sand proppant is sometimes coated with resins to improve performance, and ceramic materials can also be used instead of sand Source: https://prd-wret.s3-us-west2.amazonaws.com/assets/palladium/production/s3fspublic/Hydraulic_Fracturing_Sand.jpg 20 20 4 - Completions and Workovers 4-10 Typical Chemical Additives 21 21 Typical Chemical Additives • Frac fluids typically contain 3-12 chemical additives, depending on the characteristics of the water and the shale formation being fractured • Typical additives include: • friction reducers to allows fracturing fluids and proppants to be pumped to the target zone at a higher rate and reduced pressure • biocides to prevent microorganism growth and to reduce biofouling of the fractures • oxygen scavengers and other stabilizers to prevent corrosion of metal pipes • acids that are used to remove drilling mud damage within the near-wellbore area 22 22 4 - Completions and Workovers 4-11 Source: https://prd-wret.s3-us-west-2.amazonaws.com/assets/palladium/production/s3fspublic/Withdrawing_Water_for_Hydraulic_Fracturing.jpg Water Use in Hydraulic Fracturing • Drilling and hydraulic fracturing of a horizontal shale gas well typically requires 2 - 6 million gallons of water • Water sources include groundwater, surface water, treated wastewater, and flowback or produced water • Although water needed for drilling an individual well may represent a small volume over a large area, withdrawals may have a cumulative impact to watersheds over the short term • Affects water availability during periods of low stream flow, which could affect fish and other aquatic life, fishing and other recreational activities, municipal water supplies, and other industries such as power plants • Companies may be required to provide a water management plan prior to withdrawals from water resources 23 23 Steps of Hydraulic Fracturing 1. Acid Stage: several thousand gallons of water mixed with a dilute acid are pumped into the well • Clears cement debris in wellbore and provide an open conduit for other frac fluids by dissolving carbonate minerals and opening fractures near wellbore 2. Pad stage: approximately 100,000 gallons of slickwater without proppant material are pumped into the well • High-pressure of the frac fluids and continual pumping increases pressure in the well, overcoming strength of the reservoir rocks to break them apart • Creates fractures and opens formation; helps to facilitate the flow and placement of proppant material 24 24 4 - Completions and Workovers 4-12 Steps of Hydraulic Fracturing 3. Prop sequence stage: water combined with proppant material are introduced into well to extend breaks and pack them with proppants 4. Flushing stage: consisting of a volume of fresh water sufficient to flush excess proppant from the wellbore • Stage may collectively use several hundred thousand gallons of water • Proppant material may vary from a finer particle size to a coarser particle size throughout this sequence 25 25 Fracturing and Fracture Monitoring • Fracking produces a break in the rock • Usually 2 to 3 mm in width (1/10th to 1/8th inch) • Formed in the direction perpendicular to the least stress • At depths < ~ 2000 ft, horizontal fractures are more likely (parallel to the plane of the formation) • At depths > 2000 ft, vertical fractures are more likely • Length/height of a fracture is This Photo by Unknown Author is licensed under CC BY-SA-NC controlled by upper confining zone or formation, and volume, rate, and pressure at which frac fluid is pumped 26 26 4 - Completions and Workovers 4-13 https://www.youtube.com/watch?v=qjP-K1VaI1k 27 27 Flowback Water • Flowback: fluid that initially returns to the surface after hydraulic fracturing after injection pressure applied to oil or gas production well is released • Flowback water is primarily fracking fluid, mixed with natural formation water and natural gas • Generally, flowback water has been found to contain: • Salts, including those composed from chloride, bromide, sulfate, sodium, magnesium, and calcium; • Metals, including barium, manganese, iron, and strontium; • Naturally-occurring organic compounds, including methane, benzene, toluene, ethylbenzene, xylenes (BTEX), VOCs, and oil and grease; • Radioactive materials, including radium; and • Hydraulic fracturing chemicals and their chemical transformation products 28 28 4 - Completions and Workovers 4-14 Flowback Water Volumes • Flowback water volumes vary by well, rock formation, and time after hydraulic fracturing • Hundreds of thousands to millions of gallons of flowback water need to be collected and handled at the well site • Volume of water produced per day generally decreases with time • Flowback water and produced water flows from well to on-site tanks or pits through a series of pipes before being transported offsite for disposal or reuse Source: Stern, Pete. Loyalsock State Forest, Flyover - PA 2013. 10/9/2013. Provided by FracTracker Alliance, fractracker.org/photos • Spills can occur, which may affect drinking water 29 29 Flowback Water Disposal • Dependent on each state’s regulations for disposal, energy companies often have four different methods to choose from: • Deep well injection - involves blasting of fluids deep into the earth’s core at high pressures • Injection wells are structurally similar to natural gas and oil wells with cement casings and pipe that run thousands of meters down into rock layers • Open air pits - flowback fluid is collected and often sent through pipelines to bodies of water which would appear to be man-made ponds to the untrained eye 30 30 4 - Completions and Workovers 4-15 Flowback Water Disposal • Dependent on each state’s regulations for disposal, energy companies often have three different methods to choose from: • Treatment of the water - the removal of any solids and dissolved inorganic substances, desalination, and special procedures for any radioactive or carcinogenic materials at a wastewater treatment plant (most expensive) • Reuse and recycle – wastewater that is going to be reused for the intended purpose of fracking • The wastewater must be treated initially and then combined with water to balance out the high salt concentrations • Newer and more expensive method 31 31 https://www.youtube.com/watch?v=qjP-K1VaI1k 32 32 4 - Completions and Workovers 4-16 ARTIFICIAL LIFT 33 33 Artificial Lift • Artificial lift: the application of pumps or gas injection to assist the lifting of the heavier reservoir liquids; a process used on oil wells to increase pressure within the reservoir and encourage oil to the surface • ~96% of oil wells in the US require artificial lift from the start of production • Even those wells that initially posses natural flow to the surface, that pressure depletes over time, and artificial lift is then required • Two main categories of artificial lift: pumping systems and gas lifts This Photo by Unknown Author is licensed under CC BY 34 34 4 - Completions and Workovers 4-17 Beam Pumps • Beam pumping: an artificial-lift pumping system using a surface power source to drive a downhole pump assembly • A beam and crank assembly (pumpjack) creates reciprocating motion in a sucker-rod string that connects to the downhole pump assembly • The pump contains a plunger and valve assembly to convert the reciprocating motion to vertical fluid movement This Photo by Unknown Author is licensed under CC BY-SA 35 35 https://www.youtube.com/watch?v=X0Dpd52pfp0 36 36 4 - Completions and Workovers 4-18 Hydraulic Pumps and Electric Submersible Pumps • Hydraulic Pumping: An • Electric Submersible Pump • A surface hydraulic pump • The pump typically comprises artificial-lift system that operates using a downhole pump that is hydraulically driven pressurizes crude oil called power oil, which drives the bottom pump • The power oil is pumped down the tubing and a mixture of the formation crude oil and power oil are produced through the casingtubing annulus System: An artificial-lift system that utilizes a downhole pumping system that is electrically driven several staged centrifugal pump sections that can be specifically configured to suit the production and wellbore characteristics of a given application • Electrical submersible pump systems are a common artificial-lift method, providing flexibility over a range of sizes and output flow capacities 37 37 Gas Lift • Gas Lift: An artificial-lift method in which gas is injected into the production tubing to reduce hydrostatic pressure of the fluid column; resulting reduction in bottomhole pressure allows the reservoir liquids to enter wellbore at a higher flow rate • Injection gas is typically conveyed down the tubing-casing annulus and enters the production train through a series of gas-lift valves • Gas-lift valve position, operating pressures and gas injection rate are determined by specific well conditions This Photo by Unknown Author is licensed under CC BY-SA 38 38 4 - Completions and Workovers 4-19 Enhanced Oil Recovery • Enhanced oil recovery (EOR): the process of recovering oil not already extracted from an oil reservoir through primary (natural) or secondary (gas or water injection) recovery techniques; EOR methods alter the chemical composition of the oil itself, to make it easier to extract. • AKA “tertiary recovery” • Three types of EOR: thermal recovery, gas (CO2) injection, chemical injection This Photo by Unknown Author is licensed under CC BY-SA-NC 39 39 Gas Well Liquids Unloading • Many gas wells produce some liquids at some stage in their life cycles • When the accumulation of liquid results in the slowing or cessation of gas production, removal of fluids (i.e., liquids unloading) is required in order to maintain production • Common courses of action to improve gas flow include: • Shutting in the well to allow bottom hole pressure to increase, then venting the well to the atmosphere (well blowdown) • Swabbing the well to remove accumulated fluids • Installing a plunger lift • Installing velocity tubing • Installing an artificial lift system 40 40 4 - Completions and Workovers 4-20 WORKOVERS 41 41 Workovers • Workover: Any work on the wellbore which changes the flowing characteristics of the well or repairs a problem within the wellbore • Some of the work and treatments which may be performed on a well are: • re-perforation job • complete the well in a different zone • stimulation treatments (acid, frac) • remedial cementing • chemical treatments to remove various types of deposits (dewaxing, asphaltenes (tar like oil compound), scale, sand, sulphur or hydrates (freezing off)) • repair leaking tubing or casing • parted or broken sucker rods • repair to a bottomhole pump 42 42 4 - Completions and Workovers 4-21 Reasons for Workovers • Workovers may be required for one or more of the following reasons: • Unsatisfactory production or injection rates • Supplemental recovery project requirements • Regulatory requirements • Competitive drainage • Reservoir data gathering • Lease requirements • Abandonments 43 43 Kill the Well • Before a workover can begin, the well usually has to be killed • This means that the pressure of the formation has to be equaled by pressure from above, usually by injecting treated water, oil, or formation water into the well • This brings the flow of formation fluid to a temporary halt • Well must be swabbed to unload liquids from the production tubing to reinitiate flow from the reservoir. 44 44 4 - Completions and Workovers 4-22 Refracturing a Well • Refracturing is a workover technique that involves reinvigorating wells by performing secondary or tertiary hydraulic fracture stimulation treatments • Declining production rates from shale wells usually are more rapid than wells in conventional reservoirs because of their ultralow permeability, limited reservoir contact, and the original completion strategy • Companies either use the original access points to the reservoir to extend existing fractures, or reperforate between the original access points to create new fractures 45 45 Types of Workover Rigs • Conventional Service Rig: looks very much like a small drilling rig except the conventional service rig is usually a truck mounted mobile unit with a derrick, which can be folded down for transporting • The conventional service rig performs basic workover jobs usually involved with the tubing • For well work to be conducted with a conventional service rig, the well must be "dead" • Coiled Tubing Units (CTU): are usually trucks or trailers mounted with a large reel containing a continuous coil of thin-walled, small diameter tubing (OD 20 to 38 mm, 3/4 to 1.5 ") which will fit inside the existing tubing of most wells • The coiled tubing is fed to the injector head, which will push the continuous tubing string down into the well. • The work which can be performed by the CTU can be done without removing the tubing • Tubing units can work on "live" wells (pressure at surface). 46 46 4 - Completions and Workovers 4-23 Types of Workover Rigs • Snubbing Units: also known as hydraulic workover rigs, they are set-up on top of the wellhead and can push, pull or rotate the tubing • Once a joint of tubing has been raised into the cylinder it can be isolated from the well and removed • Snubbing units are designed specially to handle work on "live" wells • Wireline Units: are typically mounted on the back of a truck with a wire on a reel • The wire is run into the well through a lubricator mounted on the top of the wellhead, which allows the wire to be run in or out of a “live” well • Three main types of units: • Slickline • Braided wireline • Electric wireline 47 47 48 48 4 - Completions and Workovers 4-24 EMISSIONS FROM EXPLORATION 49 49 Combustion Sources • Drilling rig engines, hydraulic fracturing pump engines, artificial lift engines • Process characteristics needed to estimate emissions: • Engine size and type (HP or KW) • Operating hours • AP-42 Emission Factors Auch, Ted. Pump jack and flaring from well site off of Starvation Lake Road in NE Michigan.05/20/2016. Provided by FracTracker Alliance, fractracker.org/photos. 50 50 4 - Completions and Workovers 4-25 Mud Degassing Emissions • A degasser is used to remove entrained gas in the drilling mud • Electric motor will power a vacuum pump which is applied to the vapor space in horizontal, vertical or round vessel • Extracted gas is then either vented to atmosphere or to a flare • Emissions can be estimated on a daily basis per EPA’s “Atmospheric Emissions from Offshore Oil and Gas Development and Production” (1977) This Photo by Unknown Author is licensed under CC BY-SA 0.4 Mg NG/day = 882 lb NG/day 51 51 Well Venting from Completions/Workovers • Emissions are generated as gas is vented before well brought into production • Emissions are generated as gas entrained in the flowback fluid is emitted through open vents at the top of flowback tanks • Gas released from the liquids is vented to the atmosphere or flared depending on regulatory requirements or other factors • If the gas is vented, this may generate a significant amount of CH4, VOC, and HAP emissions to the atmosphere • Flaring generates a significant amount of combustion emissions 52 52 4 - Completions and Workovers 4-26 Completions Control Techniques Green Completions • Green Completions: an alternate practice that captures gas produced during well completions and well workovers following hydraulic fracturing • Also known as “reduced emissions completions (RECs)” • Green completions involves installing portable equipment that is specially designed and sized for the initial high rate of water, sand, and gas flowback during well completion. • The objective is to capture and deliver gas to the sales line rather than venting or flaring this gas • 40 CFR 60 Subpart OOOOa requires use of green completion methods 53 53 Well Venting from Liquids Unloading • Well blowdowns involve the intentional manual venting of the well to the atmosphere to improve gas flow • The sales line connection is manually shut-off and well production is routed to an atmospheric tank with lower back-pressure than the production system • This allows reservoir (gas) pressure to lift the liquid from the well • The entrained gas is vented to the atmosphere at the tank, resulting in high CH4, HAP, and VOC emissions • Emission can be mitigated by using foaming agents or surfactants, velocity tubing, plunger lift, and/or downhole pumps rather than blowing down the well 54 54 4 - Completions and Workovers 4-27 Liquids Unloading Control Technologies - Plunger Lifts • Plunger Lift: an artificial-lift method principally used in gas wells to unload relatively small volumes of liquid • An automated system mounted on the wellhead controls the well on an intermittent flow regime • When the well is shut-in, a plunger is dropped down the production string; when the control system opens the well for production, the plunger and a column of fluid are carried up the tubing string • The surface receiving mechanism detects the plunger when it arrives at surface and, through the control system, prepares for the next cycle 55 Source: EPA, https://www.epa.gov/sites/production/files/2016-06/documents/ll_plungerlift.pdf 55 https://www.youtube.com/watch?v=tF2-HL_Yxtc 56 56 4 - Completions and Workovers 4-28 STATE REGULATIONS ON HYDRAULIC FRACTURING Chapter 5 1 Pennsylvania Exemption 38 • All Exemption 38 categories ((a), (b), and (c)) are not required to obtain a plan approval or operating permit • Exemptions 38(a) and 38(b) apply to wells drilled before August 7, 2018 • Exemption 38(a) to wells drilled before August 10, 2013 and Exemption 38(b) to wells drilled on or after August 10, 2013 but before August 8, 2018 2 2 5 - State Fracking Regulations 5-1 Pennsylvania Exemption 38(c) • Exemption 38(c) • Reduced emission completions (i.e., green completions) at hydraulically fractured well sites • LDAR – semiannually • Methane Emissions – Less than 200 tpy from each individual source • VOC Emissions – Less than 2.7 tpy facility-wide • Hazardous Air Pollutants (HAPs) – 0.5 tpy of individual HAP or 1 tpy of all HAPs facilitywide • NOx emissions from engines – Less than 100 lbs/hr, 1000 lbs/day, 2.75 tons per ozone season, and 6.6 tpy • Compliance Demonstration through recordkeeping and reporting - Operator must keep adequate records demonstrating compliance with the exemption criteria • Showing compliance with the exemption criteria is additional to the recordkeeping and reporting requirements of 40 CFR Part 60, Subparts OOOO and OOOOa 3 3 Pennsylvania GP-5A Permit • GP-5A is a new general permit that is applicable to unconventional well sites and remote pigging stations that do not meet Exemption 38 • Applicability: The GP-5A authorizes the construction, modification, and/or operation of sources listed below at an unconventional natural gas well site or remote pigging station: • Glycol Dehydration Units • Stationary Natural Gas-Fired Spark Ignition Internal Combustion Engines • Reciprocating Compressors • Storage Vessels • Tanker Truck Load-Out Operations • Fugitive Emissions Components • Natural Gas-Driven Pneumatic Controllers • Natural Gas-Driven Pneumatic Pumps • Enclosed Flares and Other Emission Control Devices • Pigging Operations • Wellbore Liquids Unloading Operations 4 4 5 - State Fracking Regulations 5-2 Pennsylvania GP-5A Permit Standards • Establishes state BAT determinations for compressors, engines • Incorporates state BAT and federal New Source Performance Standards (NSPS) requirements for LDAR • Incorporates state BAT for pigging operations • Incorporates emission control threshold for methane (200 tpy) for each glycol dehydration unit, storage vessel, natural gas-driven pump, and pigging operation • Applies indirectly to tanker truck load-out operations in that load-out operations must meet the control requirements if connected to a storage vessel that has reached the methane, VOC, or HAP emission threshold • Incorporates federal NSPS and state requirements for other sources (e.g. tanks, dehydrators, wellbore liquids unloading operations) 5 5 Pennsylvania GP-5A Permit – Recordkeeping and Reporting • Records retained for 5 years on site or at the nearest local field office • Records that demonstrate that the facility is not Title V • Records of all written notifications • Recordkeeping: • Submit copies of applicable NSPS and NESHAP requests, reports, applications, submittals, and other communications • Submit EPA reports via CEDRI • Annual reporting 6 6 5 - State Fracking Regulations 5-3 Pennsylvania Oil and Gas Surface Regulations • Chapter 78 – Conventional Wells • Chapter 78a – Unconventional Wells • Chapter 78 - Emergency Response Planning at Unconventional Well Sites • Chapter 79 - Oil and Gas Conservation • Chapter 91 - General Provisions • Chapter 95 - Wastewater Treatment Requirements • Chapter 102 - Erosion and Sediment Control • Chapter 105 - Dam Safety and Waterway Management 7 7 West Virginia Rule 13 • An air quality permit may be required prior to construction and operation of any air emissions units under 45CSR13 (Rule 13) • DAQ has developed General Permit G70-D, which covers a wide variety of emission sources at a well pad • “Rule of thumb” – brand new well sites that produce “Condensate” generally require an air permit – 0.5 bbl (21 gallons/day production triggers a permit) • Storage Tanks are considered “permanent” if they are “intended” to be located at a site for 180 consecutive days or more and could trigger Rule 13 permitting • Air emissions units may be “stored/ received” on-site prior to an air permit being issued, but you may not “install/erect” air emission units • Permanent flares, enclosed combustors, or other incinerators automatically trigger a Rule 13 permit (other than temporary flowback flares/combustors used for 30 days or less) • Rule 13 permitting threshold are facility-wide 6 lbs/hr VOC PTE or if the benzene emissions are greater than or equal to 1,000 lbs/year PTE • WVDAQ utilizes federal requirements (e.g., NSPS OOOOa) for completion activities 8 8 5 - State Fracking Regulations 5-4 West Virginia Horizontal Well Act • Horizontal Well Act • Passed December 14, 2011 • Regulates permitting, drilling, and fracking of horizontal wells • Applicability: Applies to any natural gas well, other than a coalbed methane well, drilled [after 12/4/2011] using a horizontal drilling method, and which disturbs three acres or more of surface, excluding pipelines, gathering lines and roads, or utilizes more than two hundred ten thousand gallons of water in any thirty day period. 9 9 West Virginia Horizontal Well Act – General Requirements • Obtain a horizontal well permit • Prepare a soil erosion and sediment control plan • Prepare a well site safety plan • Prepare a site construction plan • Prepare an after management plan • Well location must be > 250 ft from existing water well or spring • Meet minimum casing and cement standards • Follow plugging requirements (when abandoning well) 10 10 5 - State Fracking Regulations 5-5 West Virginia Horizontal Well Act – Recordkeeping and Reporting • Retain following records for 3 years • For production activities: • Quantity of flowback water from hydraulic fracturing the well; • Quantity of produced water from the well; and • Method of management or disposal of the flowback and produced water • For transportation activities: • Quantity of water transported; • Collection and delivery or disposal locations of water; and • Name of the water hauling company 11 11 West Virginia Horizontal Well Act • Enforcement by WV Department of Environmental Protection (DEP) oil and gas inspectors • The Horizontal Well Act required WV DEP to: • Perform an air quality study and rulemaking (if necessary) • Perform an impoundment and pit safety study and rulemaking (if necessary) • Studies were required to be completed by 2013 • In these reports, WV DEP determined that no additional rulemaking was necessary 12 12 5 - State Fracking Regulations 5-6 Virginia Hydraulic Fracturing Standards • The Oil and Gas Division within the Virginia Department of Mines, Minerals, and Energy (DMME) is responsible for regulating fracking in Virginia • The division enforces regulations on the following: • Well construction, casing, and cementing • Protection of underground and surface water • The reporting and disclosure of the types of fluids used in fracking and at what volume and a description of each chemical additive used in fracking • The maximum amount of surface and injecting pressure used during the process • Spill prevention and clean-up • All other information considered necessary for the regulation of fracking for safety and environmental protection • Virginia does not have gas-specific air quality regulations, rely on federal requirements 13 13 Virginia – Production Areas • Marcellus Shale (west side of state) and Taylorsville Basin (coastal plain) • Special requirements apply to wells drilled in the Tidewater region (coastal plain) • An application for a drilling permit must be accompanied by an Environmental Impact Assessment, which shall be reviewed by the Department of Environmental Quality, distributed to all appropriate state agencies, and be made available for public comment • DMME cannot issue a permit to drill until the recommendations of DEQ have been considered • As of early 2014, the only producing gas and oil wells in Virginia are in the southwestern part of the Commonwealth (Marcellus Shale). 14 14 5 - State Fracking Regulations 5-7 Virginia – Well Drilling / Groundwater Requirements • Independent lab test of any water well or spring within 500 feet of a proposed well bore before drilling begins (baseline) and ongoing groundwater testing • Water used in drilling must be equal to or better than any groundwater found within 500 feet of a proposed well • Water used to drill through fresh groundwater horizons is required to meet state water quality standards set by DEQ • The well casing/cementing program for each well must be designed to protect ground water resources and coal seams below the surface • Virginia's casing program is a multi-casing and cementing program with the cement circulated to surface • This prevents contamination of groundwater, protects the coal resources, and isolates the gas production 15 15 Virginia – Produced Water and Fracking Fluid Requirements • All waters and fluids produced during drilling and fracking must be captured in an approved and properly constructed pit or approved tank for temporary storage. • The Virginia Gas and Oil Act and Regulations do not allow off-site impacts or discharges to surface waters. • Virginia regulations provide for the option of ground application of fluids if lab tests, conducted by an independent lab, show the fluids meet water quality standards. • If the produced fluids do not meet quality standards, the operator is required to transport fluids to an approved Class II EPA waste disposal well or other properly permitted facility for permanent disposal. • As of March 2017, Virginia regulations required fracking operators to complete and submit a list of chemicals used during the fracking process on the website FracFocus.org. • Operators that consider a chemical or the concentration of a chemical to be a trade secret are allowed to withhold these chemicals from public disclosure and thus disclosure to potential competitors. 16 16 5 - State Fracking Regulations 5-8 North Carolina • North Carolina lifted a ban on horizontal drilling and hydraulic fracturing in March 2015 • Finalized oil and gas standards in November 2014, which included the following hydraulic fracturing requirements: • Well stimulation operations must be approved by the state through application • Treating pressure cannot exceed 80% of the minimal internal pressure of production casing • Non-cemented portions of well must be tested to confirm that the wellbore can meet 70% of the activating pressure for sleeve completions or 70% of formation integrity for open-hole completions • Notification to the DENR by phone and mail of commencement of stimulation operations • Monitoring of pressure and flow that would be indicative of a potential loss of wellbore integrity 17 17 North Carolina (Cont.) • Finalized oil and gas standards in November 2014, which included the following hydraulic fracturing requirements: • Monitoring and installation of a PRD for well treatments that do not allow the surface casing annulus to be open to atmosphere • Monitoring and recording, at all times, the following parameters: surface injection pressure, in pounds per square inch (psi), fluid injection rate in barrels per minute (BPM), proppant concentration in pounds per thousand gallons, fluid pumping rate in BPM, identities, rates, and concentrations of additives used, and all annuli pressures. • Submission of well stimulation report 30 days after conclusion • Chemical disclosure data on fracfocus.org • Fracking fluids cannot include BTEX, diesel, fuel oil, or kerosene 18 18 5 - State Fracking Regulations 5-9 New Jersey & Delaware • On November 30, 2017 the DRBC released proposed rules that would ban fracking in all shale formations in the Delaware River Basin • Delaware River Basin Commission (DRBC) includes PA, NY, NJ, & DE • New Jersey and Delaware otherwise do not have specific regulations regarding well completions Source: Delaware River Basin Commission, https://www.state.nj.us/drbc/programs/natural/ 19 19 Maryland Fracking ban since October 1, 2017 This Photo by Unknown Author is licensed under CC BY 20 20 5 - State Fracking Regulations 5-10 OIL AND GAS OPERATIONS Part 1 Chapter 6 1 Overview • Well Pad Equipment Operation and Emissions • Combustors • Separators and Heater Treaters • Atmospheric Storage Tanks 2 2 6 - Oil and Gas Ops Pt 1 6-1 3 Donnan, Bob. Drilling pad, PA. 12/22/2014. Provided by FracTracker Alliance, fractracker.org/photos 3 Donnan, Bob. Five wells on one pad, PA. 12/22/2014. Provided by FracTracker Alliance, fractracker.org/photos 4 4 6 - Oil and Gas Ops Pt 1 6-2 5 Donnan, Bob. Cross Creek County Park 41-44H well pad, PA. 12/22/2014. Provided by FracTracker Alliance, fractracker.org/photos 5 Equipment On a Well Pad • • • • • • Wellheads Separation Units Tanks Combustors Lease Automatic Custody Transfer (LACT) Unit Remote Telemetry Unit (RTU) Stern, Pete. Loyalsock State Forest, Flyover - PA 2013. 10/9/2013. Provided by FracTracker Alliance, fractracker.org/photos 6 6 6 - Oil and Gas Ops Pt 1 6-3 Basic Crude Oil Process Gas to Gathering Line or Flare Separator Associated Gas Oil to Truck Oil Stock Tanks Water to Truck 7 Produced Water Tank(s) 7 Basic Natural Gas Process Separator Dehydration; Compression Water/Condensate to Truck Water/Condensate Tank(s) Gas to Gathering and Boosting 8 8 6 - Oil and Gas Ops Pt 1 6-4 https://www.youtube.com/watch?v=lWBhk6BAIao 9 9 Key Terms in Oil and Gas Production API Gravity: measured as the inverse of the density of a petroleum liquid relative to water • The higher the API gravity, the lower the density of the petroleum liquid, so light oils and condensates have high API gravities Gas/Oil Ratio (GOR): amount of gas dissolved in oil • Heavy oils (lower API gravity) has lower capacity to contain dissolved gas than lighter oils Gas Hydrates: ice-like solids that form when free water and natural gas combine at high pressure and low temperature 10 10 6 - Oil and Gas Ops Pt 1 6-5 Associated Gas Venting • Associated gas: a form of natural gas which is found with deposits of petroleum, either dissolved in oil or as a free "gas cap" above the oil in reservoir • Associated gas is generally regarded as an undesirable byproduct, which is either reinjected, flared, or vented • Flaring is most common way of disposing of associated gas 11 11 Control Techniques – Flares and Combustors • Flaring is the controlled burning of natural gas • A flare system consists of a flare stack and pipes that feed gas to the stack • Emissions of SO2, CO2 and NOX are formed as products of combustion • Emissions of VOC and CH4 emissions may result from incomplete combustion • Typical control efficiency of a flare is 98-99.5% Auch, Ted. Flare on well pad, Belmont County, Ohio May 2017. 5/3/2017. Provided by FracTracker Alliance, fractracker.org/photos 12 12 6 - Oil and Gas Ops Pt 1 6-6 Control Techniques – Flares and Combustors • Combustors utilize a high- temperature oxidation process to destroy hydrocarbons and VOCs • Certain types of “enclosed flares” and thermal oxidizers are other examples of combustors This Photo by Unknown Author is licensed under CC BY-SA 13 13 Flares This Photo by Unknown Author is licensed under CC BY This Photo by Unknown Author is licensed under CC BY-ND 14 14 6 - Oil and Gas Ops Pt 1 6-7 Flare Emissions Estimation Methods 1. Conversion of flare gas carbon to CO2 Calculation: where Molar volume conversion = conversion from molar volume to mass (379.3 scf/lbmole or 23.685 m3/kgmole); MW CO2 = CO2 molecular weight; Mass conversion = tonnes/2204.62lb or tonne/1000 kg; A = the number of moles of Carbon for the particular hydrocarbon; and B = the moles of CO2 present in the flared gas stream. 15 15 Flare Emissions Estimation Methods 1. CH4 emissions from flares Calculation: where CH4 E = emissions of CH4 (lb); V = volume Flared (scf); % residual CH4 = noncombusted fraction of flared stream (default =0.5% or 2%); Molar volume conversion = conversion from molar volume to mass, (379.3 scf/lbmole or 23.685 m3/kgmole); and MW CH4 = CH4 molecular weight. 16 16 6 - Oil and Gas Ops Pt 1 6-8 SEPARATORS & HEATER TREATERS 17 17 What is a separator? • Separator: A cylindrical or spherical vessel used to separate oil, gas and water from the total fluid stream produced by a well • AKA “Free water knockout” or “Trap” • Separators can be classified into two-phase and three-phase separators • Two-phase type deals only with oil and gas; three-phase type handles oil, water and gas • Separators work on the principle that the three components have different densities, which allows them to stratify when moving slowly with gas on top, water on the bottom and oil in the middle • Any solids such as sand will also settle in the bottom of the separator 18 18 6 - Oil and Gas Ops Pt 1 6-9 Horizontal vs. Vertical Separators • Separators can be either horizontal or vertical • Horizontal – used to separate mixtures with a high GOR; more efficient at handling large volumes of gas; better phase separation capability • Vertical – used to separate mixtures with a low GOR; good at solids handling; requires less space This Photo by Unknown Author is licensed under CC BY-SA-NC 19 This Photo by Unknown Author is licensed under CC BY-SA 19 How does a separator work? • To remove oil from gas in separators: • Gravity separation: particles of liquid This Photo by Unknown Author is licensed under CC BY-SA hydrocarbon in a stream of natural gas will settle out if the velocity of the gas is sufficiently slow • Impingement: Mist is impinged against a surface and the liquid mist may adhere to and coalesce on the surface • Change of flow direction: When the direction of gas flow is changed abruptly, inertia causes the liquid to continue in the original direction of flow • Change of flow velocity: A sudden increase or decrease in gas velocity, using the difference in inertia of gas and liquid • Centrifugal force: Centrifugal force throws the liquid mist outward against the walls of the 20 container 20 6 - Oil and Gas Ops Pt 1 6-10 How does a separator work? • Methods used to remove gas from crude oil in separators: • Agitation: Agitation usually will cause the gas bubbles to coalesce and to separate from the oil • Heat: This reduces surface tension and viscosity of the oil and thus assists in releasing gas that is hydraulically retained in the oil • Centrifugal force: Centrifugal force throws the oil mist outward against the walls of the container 21 This Photo by Unknown Author is licensed under CC BY 21 Heater Treater • Heater treaters are heated vertical or horizontal separators that are typically used for the following purposes: • Break up emulsions to separate the oil from produced water and inorganic salts • Solids (sediment) removal • Stabilize the crude oil or condensate by separating volatile, lighter hydrocarbon fraction (C1-C4) from the heavy, less volatile fraction (C5+) for safety reasons • Prevents the formation of ice and natural gas hydrates Donnan, Bob. 7 'heater treaters' and a vapor destruction unit (left), PA. 12/22/2014. Provided by FracTracker Alliance, fractracker.org/photos 22 22 6 - Oil and Gas Ops Pt 1 6-11 How does a heater treater work? • Mixture of hydrocarbon liquids, gases, and water from the wellbore enters top of the treater into a gas separation section • Oil and water travel down through vessel to the heated section where heat breaks the emulsion, allowing water and oil to separate • The water settles to the bottom of vessel while the oil rises to the top 23 Source: TCEQ, https://www.tceq.texas.gov/assets/public/implementation/air/am/contracts/reports/ei/5821199776FY131720130831-erg-upstream_oil_gas_heaters_boilers.pdf 23 GPUs • Gas Production Units (GPUs) consist of an indirect heater and separator, skid mounted with interconnecting piping and instrumentation, ready for operation • AKA “Gas Processing Units” • It is self-contained; GPUs arrive on a skid and are prepared to begin processing once they are tied into the flowline, stock tanks, and sales line Leiter, Leann. Equipment near Johnston Compressor Station, Chartiers Twp. PA, April 2017. 4/23/2017. Provided by FracTracker Alliance, fractracker.org/photos 24 24 6 - Oil and Gas Ops Pt 1 6-12 Emissions from Separators, Heater Treaters, and GPUs • Separators do not have any direct emission points • Separated gas flows to gas line • Oil/condensate and water flows to storage tanks through dump valve • Separator temperature and pressure affect emissions quantities from storage tanks • Heater Treaters and GPUs have combustion emissions from the burner used to provide heat • Combustion emissions (NOX, CO, PM, VOC, HAP, etc.) 25 25 ATMOSPHERIC STORAGE TANKS 26 26 6 - Oil and Gas Ops Pt 1 6-13 Atmospheric Storage Tanks • Oil and condensate produced from the separator are piped to storage tanks until they can be transported offsite • Tanks may also store produced water (water occurring naturally from underground formations and brought to the surface during exploration and production) • During storage, light hydrocarbons dissolved in the crude oil or condensate vaporize or "flash out" and collect in the space between the liquid and the roof of the tank • As liquid level in the tank fluctuates, these vapors are often vented to atmosphere Auch, Ted. Morrow Co. Ohio Clinger Nelson Class II Injection Well.10/16/2015. Provided by FracTracker Alliance, fractracker.org/photos. 27 27 Type of Storage Tanks • Fixed roof (vertical and horizontal) • External floating roof • Domed external (or covered) floating roof • Internal floating roof • Variable vapor space • Pressure (low and high) This Photo by Unknown Author is licensed under CC BY 28 28 6 - Oil and Gas Ops Pt 1 6-14 Tank Batteries • A group of tanks that are connected to receive crude oil or condensate production from a well or a producing lease • In the tank battery, the oil volume is measured and tested before pumping the oil into the pipeline system 29 This Photo by Unknown Author is licensed under CC BY 29 Types of Storage Tank Emissions • Process Emissions: • Flashing Losses: emissions that occur when a liquid with entrained gases goes from a higher-pressure to a lower-pressure • Working Losses: emissions due to displacement of the vapors within the storage tank as a tank is filled or emptied • Breathing Losses: emissions due to displacement of vapor within the storage tank due to changes in the tank temperature and pressure throughout the day and throughout the year • Also known as “standing losses” • Leaks: Open or leaking thief hatches are a significant source of emissions 30 30 6 - Oil and Gas Ops Pt 1 6-15 Storage Tank Emissions • The largest component of tank vapors is methane, but also may include ethane, butane, propane, CO2 and HAP such as BTEX and nhexane • Emissions are generally affected by the separator temperature, separator pressure, annual average daily throughput, reid vapor pressure (RVP), stream composition • Last stage separator will have direct impact on storage tank emissions • Throughput may be determined based on well production or turnover in tank • The higher the separator pressure, the larger the pressure drop the separator liquid experiences when reaching the storage tank, the more emissions expected • The higher the RVP of the final liquid, the more volatile it is, and the higher the emissions 31 31 Storage Tank Emissions Estimation Methods Flashing Emissions - Laboratory GOR • A pressurized liquid sample is collected from a point between the last stage separator and the first storage tank, and then analyzing the sample in a laboratory to determine the gas-oil ratio (GOR) • The pressurized sample is allowed to flash in the laboratory to ambient conditions, and the relative volumes of gas and oil are measured to determine the GOR • GOR may then be multiplied by the number of barrels produced from that well site for a given time period in order to determine the volume of flash gas generated during that time period • Laboratory speciation of the flash gas is conducted to determine the molecular weight of the gas, as well as to determine the contribution of individual constituents to arrive at a value of VOC gas per barrel of oil produced 1. 32 32 6 - Oil and Gas Ops Pt 1 6-16 Storage Tank Emissions Estimation Methods Flashing Emissions - Direct Measurement • Tank vent emissions can be measured directly, providing accurate emissions estimates for the measured tanks, but this approach is generally expensive and time consuming for large numbers of tanks 3. Flashing Emissions - Computer Simulation Modeling • E&P Tanks – Calculates flashing, working, and breathing losses • EPA TANKS – Calculates working and breathing losses • Other software (Promax, Aspen HYSYS, etc.) – Calculated flashing, working, and breathing losses • Requires site-specific sampling of separator liquids & operational data 2. 33 33 E&P Tanks Example http://content.4cmarke tplace.com/presentatio ns/TanksWastewater1Nesvacil_ Tanks_UpstreamO_GE missionsInventoryCalc ulationsStorageTanks.pdf http://vibe.cira.colostate.edu/oge c/docs/meetings/2015-0312/NationalOGEmissionWorkGro up_031215_GLYCalc_EPTank4.pd f 34 34 6 - Oil and Gas Ops Pt 1 6-17 Storage Tank Emissions Estimation Methods 4. Flashing Emissions - Vasquez-Beggs Equation Calculation: Step 1 – Calculate the specific gravity of the gas at 100 psig: SGX = SGi x [1.0 + 0.00005912 x API x Ti x Log(Pi+14.7/114.7) where SGX = dissolved gas gravity at 100 psig; SGi = dissolved gas gravity at initial conditions, where air = 1. A suggested default value for SGi is 0.90 API = API gravity of liquid hydrocarbon at final condition; Ti = temperature of initial conditions (°F); and Pi = pressure of initial conditions (psig). 35 35 Storage Tank Emissions Estimation Methods 4. Flashing Emissions - Vasquez-Beggs Equation Calculation: Step 2 – Calculate the flash GOR: RS = C1 x SGX x (Pi + 14.7)C2 x exp(C3 x API/Ti + 460) where RS = ratio of flash gas production to standard stock tank barrels of oil produced, in scf/bbl oil (barrels of oil corrected to 60°F); SGX = dissolved gas gravity, adjusted to 100 psig. Calculated using Equation 5-16; Pi = pressure in separator, in psig; API = API gravity of stock tank oil at 60°F; and Ti = temperature in separator, °F. For API ≤ 30°API: C1 = 0.0362; C2 = 1.0937; and C3 = 25.724 For API > 30°API: C1 = 0.0178; C2 = 1.187; and C3 = 23.931 36 36 6 - Oil and Gas Ops Pt 1 6-18 Storage Tank Emissions Estimation Methods Working & Breathing Emissions - Calculations using AP-42 Equations Source: EPA’s AP-42 Emission Factors, Chapter 7, Section 1, “Organic Liquid Storage Tanks” 1. Calculations: Several detailed equations, see AP-42 Chapter 7.1 Use EPA TANKS or E&P Tanks to calculate Working and Breathing Losses! 37 37 Applicable Federal Regulations • Tanks requirements can be found in: • 40 CFR Part 60, Subpart Kb: Requires either fixed roof and internal floating roof, external floating roof, or closed vent system and a control device that reduces VOC emissions by 95% • 40 CFR Part 60, Subpart OOOO & Subpart OOOOa: Maintain actual VOC emissions < 4 tpy, or control VOC by 95% if PTE VOC > 6 tpy • 40 CFR Part 63, Subpart HH: 95% control and inspect/monitor using Method 21 • Part 98 Subpart W: GHG emissions reporting for atmospheric storage tanks 38 38 6 - Oil and Gas Ops Pt 1 6-19 Storage Tank Control Techniques • Generally two options for controlling emissions from storage tanks: • Vapor Recovery Units • Combustion/Flaring This Photo by Unknown Author is licensed under CC BY-SA 39 39 Storage Tank Control Techniques – Vapor Recovery Unit (VRU) • Hydrocarbon vapors are drawn out of the storage tank under lowpressure and are first piped to a separator (suction scrubber) to collect any liquids that condense out • The liquids are usually recycled back to the storage tank • From the separator, the vapors flow through a compressor that provides the low-pressure suction for the VRU system. • The vapors are then metered and removed from the VRU system for pipeline sale or onsite fuel supply. Source: EPA Natural Gas Star, “Installing Vapor Recovery Units on Storage Tanks” 40 40 6 - Oil and Gas Ops Pt 1 6-20 Potential Additional Equipment on a Well Pad • Lease Automatic Custody Transfer (LACT) Unit: used to meter oil into a pipeline if it is not trucked • Dehydrators: remove water from gas stream before entering gathering pipeline • Compressors: pressure of gas may need to be increased before entering gathering pipeline • Pneumatic Controllers: used to control equipment onsite • Remote Telemetry Unit: equipment to remotely monitor gas production 41 41 QUESTIONS? 42 42 6 - Oil and Gas Ops Pt 1 6-21 OIL AND GAS OPERATIONS Part 2 Chapter 7 1 Overview • What is a compressor station? • Natural Gas Compressors and Drivers • Blowdowns • Generators 2 2 7 - Oil and Gas Operations Pt 2 7-1 U.S. Natural Gas Pipeline Network, 2009 3 3 U.S. Natural Gas Pipeline Compressor Stations Illustration, 2008 4 Source: Energy Information Administration, Office of Oil & Gas, Natural Gas Division, Natural Gas Transportation Information System. 4 7 - Oil and Gas Operations Pt 2 7-2 What is a compressor station? 5 Lenker, Savanna. Compressor station within Loyalsock State Forest, PA.06/01/2016. Provided by FracTracker Alliance, fractracker.org/photos. 5 Components of a Compressor Station • Separators • Piping • Compressors & Compressor Engines • Generators • Pigging Operations • Storage Tanks • Line Heaters • Dehydrators • Pneumatic Pumps Donnan, Bob. Redd Compressor Station, PA. 12/22/2014. Provided by FracTracker Alliance, fractracker.org/photos. • Pneumatic Controllers 6 6 7 - Oil and Gas Operations Pt 2 7-3 Yard Piping and Suction Scrubber • As the pipeline enters the compressor station the natural gas passes through scrubbers, strainers or filter separators (coalescing filter) • Yard piping is used to move the gas from the separators to the gas compressors • Leak emissions from valves, flanges, connectors, etc. This Photo by Unknown Author is licensed under CC BY 7 7 NATURAL GAS COMPRESSORS AND DRIVERS 8 8 7 - Oil and Gas Operations Pt 2 7-4 Natural Gas Compressors • Two main types of compressors at an oil and gas compressor station: • Reciprocating Compressor: A piece of equipment that increases the pressure of a process gas by positive displacement, employing linear movement of the driveshaft • Centrifugal Compressor: Any machine for raising the pressure of a natural gas by drawing in low pressure natural gas and discharging significantly higher pressure natural gas by means of mechanical rotating vanes or impellers • Other compressor types include screw compressors and axial compressors 9 9 Reciprocating Compressors • In a reciprocating Source: US EPA Natural Gas Star, “Reducing Methane Emissions From Compressor Rod Packing Systems” compressor, natural gas enters the suction manifold, and then flows into a compression cylinder where it is compressed by a piston • Piston is driven in a reciprocating motion by the crankshaft powered by an internal combustion engine 10 This Photo by Unknown Author is licensed under CC BY-SA 10 7 - Oil and Gas Operations Pt 2 7-5 11 https://www.youtube.com/watch?v=ITCu7gNMicc 11 Types of Reciprocating Compressors • Separable vs. Integral Compressors • Separable Compressors: the compressor and engine are two separate pieces of equipment • Integral Compressors: the compressor and engine are one single piece of equipment • Single Stage vs. Multi Stage Compressors This Photo by Unknown Author is licensed under CC BY-NC-ND 12 12 7 - Oil and Gas Operations Pt 2 7-6 Emissions from Reciprocating Compressors • Leaks occur when high pressure gas escapes through the rod packing (“rod packing vent” and “doghouse vent”) • The piston is connected to its prime mover by a rod, and the rod utilizes rod packings to reduce wear on the compressor components and to seal in the gas pressure • Emissions of CH4, VOC, and HAP • Equipment leaks from flanges, valves, connectors, etc. • Identified using OGI camera Source: US EPA Natural Gas Star, “Reducing Methane Emissions From Compressor Rod Packing Systems” 13 13 14 Source: http://www.gaselectricpartnership.com/GArielFugitiveEmissions.pdf 14 7 - Oil and Gas Operations Pt 2 7-7 Reciprocating Compressor Control Techniques & Federal Regulations Req’s • Regular replacement of rod packing greatly reduces emissions • Schedule of rod packing replacement required by NSPS OOOO (for gathering & boosting compressor stations) and NSPS OOOOa (for transmission compressor stations) • Must replace rod packing before either of the following occur: • Compressor has operated for 26,000 hours • 36 months from the last replacement Lenker, Brook. Compressor station within Loyalsock State Forest, PA.06/01/2016. Provided by FracTracker Alliance, fractracker.org/photos. 15 15 Reciprocating Compressor Drivers RICE • Reciprocating compressors are typically driven by natural gas-powered reciprocating internal combustion engines (RICE) • RICE are grouped into two categories: richburn and lean-burn • Rich-burn engines operate with a minimum amount of air required for combustion • Lean-burn engines use 50% to 100% more air than is necessary for combustion • 2-stroke vs. 4-stroke • 2-stroke: power cycle completed in 1 revolution of crankshaft • 4-stroke: power cycle completed in 2 revolutions of crankshaft This Photo by Unknown Author is licensed under CC BY-SA 16 16 7 - Oil and Gas Operations Pt 2 7-8 https://www .youtube.co m/watch?v= LuCUmQ9F xMU 17 17 https://www.youtube.com/watch?v=OGj8OneMjek 18 18 7 - Oil and Gas Operations Pt 2 7-9 RICE Emissions and Control Techniques • Combustion emissions - NOX, CO, VOC, formaldehyde, SOX, PM, and GHGs • AP-42 Chapter 3.2 (Natural Gas-fired Reciprocating Engines) • Control methods involve combustion control and post-combustion control • Combustion control – temperature control • Higher temperatures favor complete consumption of the fuel and lower residual hydrocarbons and CO but result in increased NOX formation • Lean combustion dilutes the fuel mixture and reduces combustion temperatures and therefore reduces NOX formation, but increases CO and VOC emissions • Post-combustion controls: NSCR, SCR, Oxidation Catalyst 19 19 RICE Control Techniques - NSCR • Nonselective catalytic reduction (NSCR) is an add-on NOX control technology for exhaust streams with low O2 content (rich-burn engines) • Nonselective catalytic reduction uses a catalyst reaction to simultaneously reduce NOX, CO, and hydrocarbon to water, carbon dioxide, and nitrogen • The catalyst is usually a noble metal • Reduction level for NOX is > 95%, CO is >95%, and VOC is >50% 20 20 7 - Oil and Gas Operations Pt 2 7-10 RICE Control Techniques – Oxidation Catalyst • Oxidation catalysts convert CO and hydrocarbons to CO2 and H2O • Applied to lean-burn engines – conversion requires oxygen • Catalysts are usually platinum or palladium 21 21 RICE Control Techniques - SCR • Selective Catalytic Reduction (SCR) systems are add-on controls that specifically target NOX • Converts NOX to N2 and H2O • SCR uses ammonia or urea injected into the exhaust stream upstream of a catalyst • SCR systems reduce NOX emissions by 90% • Best suited for lean-burn engines • Ammonia slip: emissions of unreacted ammonia that result from incomplete reaction of the NOX and the reagent • Permitted ammonia slip levels are typically 2 to 10 ppm (10 ppmvd in PADEP) 22 22 7 - Oil and Gas Operations Pt 2 7-11 RICE Applicable Federal Regulations – 40 CFR Part 60, Subpart JJJJ 23 23 RICE Applicable Federal Regulations – 40 CFR Part 63, Subpart ZZZZ 24 24 7 - Oil and Gas Operations Pt 2 7-12 Centrifugal Compressors • Centrifugal compressors use a rotating disk or impeller to increase the velocity of the natural gas where it is directed to a divergent duct section that converts the velocity energy to pressure energy • These compressors are primarily used for continuous, stationary transport of natural gas in the processing and transmission systems • Single stage vs. Multi stage centrifugal compressors This Photo by Unknown Author is licensed under CC BY-SA 25 25 26 https://www.youtube.com/watch?v=s-bbAoxZmBg 26 7 - Oil and Gas Operations Pt 2 7-13 Components of a Centrifugal Compressor • Inlet: typically a simple pipe • Centrifugal impeller: contains a rotating set of vanes (or blades) that gradually raises the energy of the working gas • Diffuser: downstream of the impeller in the flow path; converts the kinetic energy (high velocity) of the gas into pressure by gradually slowing (diffusing) the gas velocity • Collector: gathers the flow from the diffuser discharge annulus and delivers this flow to a downstream pipe This Photo by Unknown Author is licensed under CC BY-SA 27 This Photo by Unknown Author is licensed under CC BY-SA 27 Emissions from Centrifugal Compressors • The majority of methane emissions occur through seal oil degassing which is vented to the atmosphere • Centrifugal compressor wet seals: high pressure seal oil circulates between rings around the compressor shaft • Oil absorbs the gas on the inboard side • Little gas leaks through the oil seal • Seal oil degassing vents to the atmosphere (heaters, flash tanks, and degassing techniques) Source: EPA Natural Gas STAR, https://www.epa.gov/sites/production/files/201606/documents/ll_wetseals.pdf • Equipment leaks from flanges, valves, connectors, etc. 28 28 7 - Oil and Gas Operations Pt 2 7-14 29 Source: EPA Natural Gas STAR, “Routing Centrifugal Compressor Seal Oil De-gassing Emissions to Fuel Gas as an Alternative to Installing Dry Seal,” October 10, 2012. 29 Centrifugal Compressor Control Techniques & Federal Requirements • Centrifugal compressor dry seals • Dry seal springs press stationary ring in seal housing against rotating ring when compressor is not rotating • At high rotation speed, gas is pumped between seal rings by grooves in rotating ring creating a high pressure barrier to leakage • 2 seals are often used in tandem • Vent oil degassing vent to control device • Per NSPS OOOO (for gathering & boosting compressor stations) and NSPS OOOOa (for transmission compressor stations) – centrifugal compressors using wet seals must reduce emissions by 95% 30 Source: EPA Natural Gas STAR, https://www.epa.gov/sites/production/files/2016-06/documents/ll_wetseals.pdf 30 7 - Oil and Gas Operations Pt 2 7-15 Centrifugal Compressor Drivers – Turbines • Natural gas-fired turbines are used mainly as prime movers to drive centrifugal compressors • Turbine is composed of three major components: • Compressor • Combustor • Power turbine This Photo by Unknown Author is licensed under CC BY-SA 31 31 Turbine Emissions and Control Techniques • Combustion emissions - NOX, CO, VOC, formaldehyde, SOX, PM, and GHGs • AP-42 Chapter 3.1 (Stationary Gas Turbines) • Control methods involve combustion control and post-combustion control • Combustion Controls: • Steam or Water Injection - increases the thermal mass by dilution and thereby reduce peak temperatures in the flame zone, reduces NOX emissions by >60%, increases CO and VOC emissions • Dry Controls - either lower the combustor temperature using lean mixtures of air and fuel, fuel staging (Dry-Low NOX (DLN), Dry-Low Emissions (DLE), or SoLoNOX), or decreasing the residence time of the combustor • Post-Combustion Controls: • Oxidation Catalyst (for CO, VOC, and HAP reduction) • SCR (for NOX reduction) 32 32 7 - Oil and Gas Operations Pt 2 7-16 Turbine Applicable Federal Regulations • NSPS Subpart KKKK: • Regulates stationary combustion turbines with a heat input at peak load of ≥ 10 MMBtu per hour that commence construction, modification, or reconstruction after Feb 18, 2005 • NOX limits and SO2 limits • Annual performance testing and fuel testing • NESHAP Subpart YYYY • Only applies to stationary combustion turbines located at major sources of HAP • Formaldehyde limit of 91 ppbvd (currently only for oil-fired turbines) • Annual performance testing 33 33 BLOWDOWNS 34 34 7 - Oil and Gas Operations Pt 2 7-17 Compressor Blowdowns • Natural gas compressors cycled on- and offline to match fluctuating gas demand • Peak and base load compressors • When compressor units are shut down, typically the high pressure gas remaining within the compressors and associated piping between isolation valves is vented to the atmosphere (‘blowdown’) or to a flare • Emissions are calculated based on the volume of piping blown down 35 Source: EPA Natural Gas STAR, https://www.epa.gov/sites/production/files/2016-06/documents/ll_compressorsoffline.pdf 35 Suction Header Blowdown Gas to Atmosphere Blowdown Valve Discharge Header Isolation Valve Isolation Valve 36 36 7 - Oil and Gas Operations Pt 2 7-18 https://www.youtube.com/watch?v=IIqYh-OF4aA 37 37 Isolation and Blowdown Valve Leaks • Leaks from isolation or blowdown valve identified during LDAR survey (OGI) • Isolation valves are closed to isolate the compressor from the pipeline • Blowdown valves are closed during normal operations and when the compressor is pressurized 38 Source: EPA Natural Gas STAR, https://www.epa.gov/sites/production/files/2016-06/documents/ll_compressorsoffline.pdf 38 7 - Oil and Gas Operations Pt 2 7-19 Blowdown and Valve Leaks Control Techniques • Significant reduction in emissions from compressors taken off- line can be done in the following ways: 1. Maintain pipeline pressure on the compressor during shutdown 2. Keep the compressor at fuel gas pressure and connect to the fuel gas system 3. Keep the compressor at pipeline pressure and install a static seal on the compressor rods 4. Install Ejector 39 39 https://www.youtube.com/watch?v=WtSH5V1YQvQ 40 40 7 - Oil and Gas Operations Pt 2 7-20 Pipeline Blowdowns and Pigging • Pipelines can require repairs or maintenance throughout their lifetime as a result of interior and exterior corrosion, gasket and weld leaks, failures of defective materials, and damage caused by external factors • Pipeline repairs and maintenance activities typically require depressurizing the affected section of the pipeline • Companies block off impacted pipeline segment and vent the gas in that segment to atmosphere • Pigging operations remove accumulated water and condensate liquids in natural gas gathering pipelines or conduct pipeline integrity checks • The “pig” is a spherical or bullet-shaped device that travels through the pipeline to push liquids to their eventual destination • When pig is launched and recovered, some of the natural gas in the chamber is vented to the atmosphere 41 41 https://www.youtube.com/watch?v=IkQK4zhMM6w 42 42 7 - Oil and Gas Operations Pt 2 7-21 GENERATORS 43 43 Power Generators • Generators provide power to the compressor station • If station is not connected to power grid, generators provide power at all times • If station is connected to power grid, generators provide power only when there is a disruption of primary electrical service to station • Powered by reciprocating engines or microturbines This Photo by Unknown Author is licensed under CC BY-SA • Combustion emissions - NOX, CO, VOC, formaldehyde, SOX, PM, and GHGs 44 44 7 - Oil and Gas Operations Pt 2 7-22 QUESTIONS? 45 45 7 - Oil and Gas Operations Pt 2 7-23 OIL AND GAS OPERATIONS Part 3 Chapter 8 1 Components of a Compressor Station • Separators • Piping • Compressors & Compressor Engines • Generators • Pigging Operations • Storage Tanks • Line Heaters • Dehydrators • Pneumatic Pumps Donnan, Bob. Redd Compressor Station, PA. 12/22/2014. Provided by FracTracker Alliance, fractracker.org/photos. • Pneumatic Controllers 2 2 8 - Oil and Gas Operations Pt 3 8-1 Storage Tanks • Storage tanks are used at compressor stations to: • Collect and store condensate liquids from separators on pipeline, compressors, dehydrators, etc. • Store chemicals for use in on site processes (e.g., triethylene glycol, methanol, mercaptan, etc.) • Vented VOC, HAP, GHG emissions • Emissions calculated using modeling programs Leiter, Leann. Tanks near Johnston Compressor Station, Canonsburg PA, April 2017 . 04/26/2017. Provided by FracTracker Alliance, fractracker.org/photos. 3 3 Indirect Line Heaters • Line heaters: used to maintain temperatures as pressure decreases to prevent formation of hydrates • A line heater typically consists of three components: shell, firetube, and coil • Process stream flows through the coil, which is immersed in upper portion of the liquid media bath (typically water) of the shell • Coil preheats the flow stream before reducing pressure across a restricting choke followed by post-heating coils • Fuel is burned in firetube and indirectly transfers heat to media, then to coil, and finally to process stream • Combustion emissions from natural gas burner 4 4 8 - Oil and Gas Operations Pt 3 8-2 https://www.youtube.com/watch?v=qTP4JkQru2I 5 5 DEHYDRATORS 6 6 8 - Oil and Gas Operations Pt 3 8-3 Natural Gas Dehydrators • Dehydrators are devices used to remove excess water from natural gas through contact with a dewatering agent • Dewatering agents may be triethylene glycol (TEG) (most common), diethylene glycol (DEG), or ethylene glycol (EG) • Both liquid and solid desiccants can be used for dehydration • Water content in pipeline quality natural gas should not exceed 7 lbs/MMscf This Photo by Unknown Author is licensed under CC BY-SA 7 7 Dehydration Process Lean glycol is pumped through top of contact tower Hot lean glycol is pumped through a heat exchanger Wet natural gas is pumped through the bottom of contact tower Glycol absorbs water from the natural gas stream and becomes rich glycol GHGs, HAP (BTEX), VOC Rich glycol enters the reboiler where the glycol is heated to boil off water to become lean glycol Rich glycol leaves the bottom of the contact tower and is pumped through a heat exchanger Dry natural gas leaves the top of the contact tower 8 8 8 - Oil and Gas Operations Pt 3 8-4 Dehydrator Equipment • Contact Tower: the vessel in which the mass transfer of the water occurs from the gas to the glycol • AKA “Contactor” or “Absorber” • Bubble cap trays or packing inside • Stripping gas may be used to remove water • Reboiler: heats the glycol to near its boiling point which releases all of the absorbed water and any other compounds This Photo by Unknown Author is licensed under CC BY-SA • AKA “Regenerator” or “Still” • Rich glycol is preheated through heat exchanger before entering reboiler • Heat is supplied through fire tubes in reboiler • Fire tube heat is provided by burning natural gas 9 This Photo by Unknown Author is licensed under CC BY-SA 9 Dehydrator Equipment • Flash tank: allows light hydrocarbons to flash off from rich glycol prior to regenerator • Flash gas typically routed to reboiler burner or fuel line, but may be flared or vented to atmosphere • Glycol Pump: either gas- assisted pumps or electric pumps move glycol through the dehydration system • Gas-assisted pumps send more gas to be boiled off in the reboiler, resulting in more emissions Source: EPA Natural Gas STAR, https://www.epa.gov/sites/production/files/2016-06/documents/ll_flashtanks3.pdf 10 10 8 - Oil and Gas Operations Pt 3 8-5 https://www.youtube.com/watch?v=SZIr2Esnp-E 11 11 Dehydrator Emissions & Control Techniques • 3 dehydrator emission sources: still vent, flash tank vent, and reboiler burner • Emissions of GHGs, BTEX, and VOC from still vent and flash tank vent • Combustion emissions from reboiler burner • Control techniques include process optimization (installation of a flash tank, optimization of glycol circulation rate) and add-on controls (condensers, flares/combustion, and vapor recovery units) This Photo by Unknown Author is licensed under CC BY-SA 12 12 8 - Oil and Gas Operations Pt 3 8-6 Dehydrator Control Techniques – Process Optimization 1. 2. Adding a Flash Tank Reduce Glycol Circulation Rate • Emissions from a glycol dehydrator are directly proportional to the amount of TEG circulated through the system • Over-circulation of glycol results in more emissions without significant and necessary reduction in gas moisture content • Minimum Glycol Circulation Rate: ∗ ∗ Given: 24 ℎ/ F = gas flow rate (MMcf/d) I = Inlet water content (lb/MMcf) O = Outlet water content (lb/MMcf) (Rule-of-thumb is 4) G = Glycol-to-water ratio (gal TEG/lb water) (Rule-of-thumb 3) L(min) = minimum TEG circulation rate (gal/hr) 13 13 Dehydrator Control Techniques – Process Optimization 3. Replace Gas-Assisted Glycol Pumps with Electric Pumps • Electric motor driven pumps have less design-inherent emissions and no pathway for contamination of lean TEG by the rich stream • Using electric glycol pumps reduces methane emissions by > 33% 14 Source: EPA Natural Gas STAR, https://www.epa.gov/sites/production/files/2016-06/documents/ll_glycol_pumps3.pdf 14 8 - Oil and Gas Operations Pt 3 8-7 Dehydrator Control Techniques – Condenser • Condensers can be natural convection air cooled (NCAC), fan cooled, or use a liquid cooling medium such as rich TEG • The liquids condensed from a condenser are primarily water and are usually routed to a storage tank • Hydrocarbon liquids are decanted and sold, water is decanted and routed for disposal • The uncondensed vapors from a condenser are routed to the atmosphere, or to a flare or burner box 15 15 Absorption vs. Adsorption • Absorption occurs when water vapor is taken out by a dehydrating agent • Glycol dehydration is an example • Glycol solution will absorb water from wet gas • Adsorption occurs when water vapor is condensed and collected on the surface of a dehydrating agent • Solid-desiccant dehydration is primary form of dehydrating natural gas using adsorption 16 16 8 - Oil and Gas Operations Pt 3 8-8 Desiccant Dehydrators • Desiccant dehydrators use moisture- absorbing salts to remove water from the gas • Salts naturally attract and adsorb moisture, gradually dissolving to form a brine solution • Process: • Wet gas flows upward through a drying bed of desiccant salts • Desiccant salts mix with water vapor to form brine, which collects at the bottom of the unit • The only gas emissions occur during desiccant vessel depressurizing for salt refilling, typically one vessel volume per week 17 Source: EPA Natural Gas STAR, https://www.epa.gov/sites/production/files/2016-06/documents/ll_desde.pdf 17 Dehydrator Federal Regulations • NESHAP Subpart HH: • Includes both major and area sources of HAP at production sites • Major source dehydration unit: 95% control; inspect and monitor using Method 21 • Area source TEG dehydration units: • In urban areas, use same control as for major sources • In rural areas, operate at optimal glycol recirculation rate • NEHSAP Subpart HHH: • Only major sources of HAP at transmission sites • Large units must route emissions to a control device • reduce TOC/HAP by 95%, or • reduce outlet concentration of TOC/HAP to 20 ppmv, or • reduce benzene emissions to less than 0.90 Mg/year (1 tpy) • Small units must limit BTEX emissions • route emissions to a control device, or • meet an emissions limit through process modifications 18 18 8 - Oil and Gas Operations Pt 3 8-9 PNEUMATIC PUMPS 19 19 Pneumatic Pumps • Pneumatic pumps are primarily used for glycol circulation or for injecting chemicals used in normal operations • AKA “Kimray pumps” • Two common types of pneumatic pump: piston and diaphragm • Pressurized gas provides energy to driver side of pump, which operates a piston or flexible diaphragm to draw fluid into pump • Motive side of pump delivers energy to fluid being moved in order to discharge fluid from the pump • The pressurized natural gas, after being used to operate the pump, is often vented to atmosphere through an exhaust port • Emissions of CH4, VOC, and HAP 20 20 8 - Oil and Gas Operations Pt 3 8-10 https://www.youtube.com/watch?v=Y6To-bgL4GE 21 21 Pneumatic Pump Control Techniques & Federal Regulations Replace pneumatic pumps with electric pumps, including solar electric pumps for smaller applications such as chemical and methanol injection 2. Routing natural gas-driven pump emissions to an existing combustion device or vapor recovery unit 1. • Emissions from natural gas-driven chemical/methanol pumps and diaphragm pumps can be reduced by 95 percent if an existing control device is already available on site • Control of pneumatic pumps is required by NSPS OOOOa • Zero bleed rate at natural gas processing facilities • 95% reduction if control or process available onsite at well sites 22 22 8 - Oil and Gas Operations Pt 3 8-11 PNEUMATIC CONTROLLERS 23 23 Controllers • Controllers are automated instruments used for maintaining liquid levels, pressure, and temperature at gas sites • Controllers are either pneumatic, electrical, or mechanical • Majority are pneumatic controllers using high-pressure natural gas • Variables most commonly controlled in upstream oil and gas are: • Fluid level • Pressure • Temperature • Differential pressure • Position • Safety 24 24 8 - Oil and Gas Operations Pt 3 8-12 This Photo by Unknown Author is licensed under CC BY-SA This Photo by Unknown Author is licensed under CC BY-SA 25 25 How does a pneumatic controller work? • Clean, dry, pressurized natural gas is regulated to a constant pressure, usually around 20 psig • A small stream is sent to a device that measures a process condition (liquid level, gas pressure, flow, temperature) • This device regulates pressure of this small gas stream (from 3 to 15 psig) in proportion to process condition • Stream flows to pneumatic valve controller, where its variable pressure is used to regulate a valve actuator Source: EPA Natural Gas STAR, https://www.epa.gov/sites/production/files/2016-06/documents/ll_pneumatics.pdf 26 26 8 - Oil and Gas Operations Pt 3 8-13 Classifying Pneumatic Controllers • Is controller used for on/off control, or does it throttle the process? • On/off controllers: when controller senses a change in a process variable, valve is either fully opened or fully shut • Throttling controllers: controller is required to control an end device in an intermediate position • Does controller bleed supply gas continuously (continuous bleed), or does it vent actuation gas at the end of on cycle (intermittent bleed)? • Continuous bleed devices: used to modulate flow, liquid level, or pressure and will generally vent gas at a steady rate • Intermittent bleed devices: release gas only when they stroke a valve open or closed or as they throttle gas flows • Zero-Bleed, self-contained devices: release gas into downstream pipeline, not to atmosphere 27 27 https://www.youtube.com/watch?v=FzpmciSfOa0 28 28 8 - Oil and Gas Operations Pt 3 8-14 https://www.youtube.com/watch?v=9djN5ukONAc 29 29 High Bleed vs. Low Bleed • Bleed rate of a pneumatic controller defines standard to which device is applicable • High bleed pneumatic controller: ≥ 6 scf/hr bleed rate • Low bleed pneumatic controller: <6 scf/hr bleed rate 30 Source: EPA Natural Gas STAR, https://www.epa.gov/sites/production/files/2016-06/documents/ll_instrument_air.pdf 30 8 - Oil and Gas Operations Pt 3 8-15 Pneumatic Controller Emissions & Control Techniques • When natural gas is vented or bled from a pneumatic controller, emissions of CH4, VOCs, and HAP are produced • Emissions determined by exhaust rate (continuous bleed) and actuation volume and frequency (intermittent bleed) • To reduce emissions from pneumatic devices: 1. 2. 3. 4. 5. Replacement of high-bleed devices with low-bleed devices having similar performance capabilities Installation of low-bleed retrofit kits on operating devices Enhanced maintenance, cleaning and tuning, repairing/replacing leaking gaskets, tubing fittings, and seals Convert gas pneumatic controls to instrument air, nitrogen gas, electric valve controllers, or mechanical control systems Implement a lower supply pressure 31 31 Pneumatic Controller Federal Regulations • Applicable federal regulations for pneumatic controllers include: • NSPS Subpart OOOO/OOOOa: • Pneumatic controllers at natural gas processing plants must have a bleed rate of zero • Typically done by converting to instrument air • Pneumatic controllers located elsewhere must have a bleed rate less than or equal to 6 scf/hr 32 32 8 - Oil and Gas Operations Pt 3 8-16 QUESTIONS? 33 33 8 - Oil and Gas Operations Pt 3 8-17 OIL AND GAS OPERATIONS Part 4 Chapter 9 1 Oil and Gas Industry - An Overview 2 Source: https://www.epa.gov/natural-gas-star-program/overview-oil-and-natural-gas-industry 2 9 - Oil and Gas Operations Pt 4 9-1 What is Natural Gas Processing? • A natural gas processing plant is a facility designed to “clean” raw natural gas by separating impurities and various nonmethane hydrocarbons and fluids to produce what is known as 'pipeline quality' dry natural gas • A gas processing plant is also used to recover natural gas liquids (condensate, natural gasoline and liquefied petroleum gas) and sometimes other substances such as sulfur This Photo by Unknown Author is licensed under CC BY-SA 3 3 Stages of Natural Gas Processing • Gas-oil-water separators • Condensate separator • Dehydration • Contaminant removal • Nitrogen extraction • Methane separation • Fractionation 4 4 9 - Oil and Gas Operations Pt 4 9-2 Condensate and Water Removal • Gas-oil-water separators: Pressure relief in a single-stage or multi-stage separator causes a natural separation of the liquids from gases in natural gas • Condensate separator: Natural gas flows into the separator comes directly from the wellhead; extracted condensate is sent to storage tanks • Dehydration: A dehydration process removes water that may cause formation of undesirable hydrates and water condensation in pipelines 5 5 Contaminant Removal • Contaminant removal: Nonhydrocarbon gases—such as hydrogen sulfide, carbon dioxide, water vapor, helium, nitrogen, and oxygen— must also be removed from the natural gas stream • Sour gas: Natural gas that contains more than 4 ppmv of hydrogen sulphide (H2S) • AKA “Acid gas” • The removal of H2S from sour gas is called “sweetening“ • Although most sour gas sweetening involves an amine absorption process, it is also possible to use solid desiccants like iron sponges to remove the sulfide and carbon dioxide • Sulfur can be sold and used if reduced to its elemental form 6 6 9 - Oil and Gas Operations Pt 4 9-3 Acid Gas Removal Units (AGRUs) • Acid gas removal refers to processes that use aqueous solutions of amines to remove H2S and CO2 from gases • AKA “amine gas treating,” “amine scrubbing,” and “gas sweetening” units • Many different amines are used in gas treating • E.g., Diethanolamine (DEA), Monoethanolamine (MEA), Methyldiethanolamine (MDEA) • Amine gas treating process includes an absorber unit/tower and a regenerator unit • CO2 (with methane) is typically vented to atmosphere or injected for EOR • H2S is typically flared or sent to sulfur recovery 7 This Photo by Unknown Author is licensed under CC BY-SA 7 Sulfur Recovery Units (SRUs) • Sulfur recovery: conversion of H2S to elemental sulfur • Claus Process: multistage catalytic oxidation of H2S to create SO2 • Tailgas treatment is added to achieve higher recovery • Elemental sulfur is collected and sold • SO2 emissions can be estimated This Photo by Unknown Author is licensed under CC BY using AP42 emission factors, Chapter 8.13 (Sulfur Recovery) 8 8 9 - Oil and Gas Operations Pt 4 9-4 Nitrogen Extraction • Nitrogen is inert and lowers energy value per volume of natural gas • Cryogenic nitrogen rejection units (NRUs) in gas processing plants are used to remove inert components from sales gas to meet transmission pipeline standards • Separated nitrogen, plus a small percentage of methane, is often vented to atmosphere through a reject stream 9 9 NGLs vs. LPGs 10 Source: EIA, https://www.eia.gov/conference/ngl_virtual/eia-ngl_workshop-anne-keller.pdf 10 9 - Oil and Gas Operations Pt 4 9-5 NGL Extraction • There are two principle techniques for removing NGLs from natural gas stream: • Absorption method: absorbing oil is used in an absorption tower to remove NGL, which are boiled off in a reboiler downstream • Cryogenic expander process: consist of dropping the temperature of the gas stream to around -120 degrees Fahrenheit • Produces both cleaner, purer natural gas, as well the NGLs themselves This Photo by Unknown Author is licensed under CC BY-SA 11 11 Fractionation • Fractionation uses the different boiling points of different hydrocarbons to separate NGLs into their base components • Particular fractionators are used in the following order: 1. Deethanizer – this step separates ethane from the NGL stream 2. Depropanizer – the next step separates propane 3. Debutanizer – this step boils off butanes, leaving pentanes and heavier hydrocarbons in the NGL stream 4. Butane Splitter or Deisobutanizer – this step separates the iso and normal butanes This Photo by Unknown Author is licensed under CC BY-SA 12 12 9 - Oil and Gas Operations Pt 4 9-6 Oil and Gas Industry - An Overview 13 Source: https://www.epa.gov/natural-gas-star-program/overview-oil-and-natural-gas-industry 13 Underground Natural Gas Storage • Storage of natural gas during periods of low demand helps to ensure that sufficient supplies of natural gas are available during periods of high demand • Natural gas is typically stored underground under pressure in three types of facilities: • Depleted reservoirs • Aquifers • Salt caverns 14 14 9 - Oil and Gas Operations Pt 4 9-7 Underground Storage Facilities • Owners/operators of underground storage facilities are interstate pipeline companies, intrastate pipeline companies, local distribution companies, and independent storage service providers • Owners/operators of storage facilities are not necessarily the owners of the natural gas held in storage • Typical equipment at storage facilities includes compressors, dehydrators, and separators Source: EIA 15 15 https://www.youtube.com/watch?v=QgtSoEJD9HE 16 16 9 - Oil and Gas Operations Pt 4 9-8 Liquified Natural Gas • Liquefied natural gas (LNG): natural gas that has been cooled to a liquid state, at about -260° Fahrenheit, for shipping and storage • Where natural gas pipelines are not feasible or do not exist, liquefying natural gas is a way to move natural gas from producing regions to markets • LNG is shipped in special ocean-going ships (tankers) between export terminals, where natural gas is liquefied, and import terminals, where LNG is returned to its gaseous state or regasified 17 17 LNG Process - Liquefication • Liquefaction Plants: where natural gas is treated to remove impurities and higher molecular weight hydrocarbons, and then liquefied and stored for subsequent shipment • Liquefaction process GHG emissions are primarily due – but not limited to: • Fuel gas combustion to power refrigeration compressors and electrical generators • Fired heaters, flares, incinerators, and other fired process heat generators • Venting of low pressure carbon dioxide • Fugitive losses of natural gas from the process due to leakage • Fugitive losses of other GHG’s used in the facility (i.e., SF6 used for switchgear) 18 18 9 - Oil and Gas Operations Pt 4 9-9 LNG Process - Storage • LNG Storage - Storage tanks that are designed to store LNG at atmospheric pressure • LNG storage tanks are typically double-walled tanks (i.e., a tank within a tank), with the annular space between the two tank walls filled with insulation • Emissions are minimal since tanks This Photo by Unknown Author is licensed under CC BY do not vent, leaks are captured, piping is welded, and there is minimal pressure difference 19 19 LNG Process – Loading, Shipping, and Unloading • Loading and Unloading - Marine or inland terminals designed for loading LNG onto tankers, or other carriers or unloading it for regasification • Fugitive emissions associated with ship loading or unloading process are minimal due primarily to the welding of all associated piping systems • Shipping - LNG tankers used for transporting LNG • Emissions are associated with the This Photo by Unknown Author is licensed under CC BY moving ship 20 20 9 - Oil and Gas Operations Pt 4 9-10 LNG Process - Regasification • Regasification Plants: typically co-located with unloading terminals, where LNG is pressurized, regasified, and injected into pipelines, or other receiving systems, for delivery of natural gas to end users • Emissions from combustion processes and venting from compressor operations This Photo by Unknown Author is licensed under CC BY-SA 21 21 Oil and Gas Industry - An Overview 22 Source: https://www.epa.gov/natural-gas-star-program/overview-oil-and-natural-gas-industry 22 9 - Oil and Gas Operations Pt 4 9-11 Natural Gas Distribution • Local Distribution Companies (LDCs): regulated utilities involved in the delivery of natural gas to consumers within a specific geographic area • LDCs typically transport natural gas from delivery points located on interstate and intrastate pipelines to households and businesses 23 This Photo by Unknown Author is licensed under CC BY-SA 23 Distribution Network • City Gate: the delivery point where natural gas is transferred from a transmission pipeline to the local gas utility • Natural gas moves through larger diameter “mains” and smaller diameter “services” until it reaches the customer’s meter • LDCs monitor flow rates and pressures at various points in the system This Photo by Unknown Author is licensed under CC BY-SA 24 24 9 - Oil and Gas Operations Pt 4 9-12 QUESTIONS? 25 25 9 - Oil and Gas Operations Pt 4 9-13 FEDERAL OIL & GAS AIR REGULATIONS Chapter 10 1 Federal Oil and Gas Air Regulations • New Source Performance Standards (NSPS) • Applies to new or modified sources • Subparts Kb, KKK, LLL, OOOO, and OOOOa • Subparts IIII, JJJJ (engines) • National Emissions Standards for Hazardous Air Pollutants (NESHAP) • Applies to sources of hazardous air pollutants • Subparts HH, HHH, ZZZZ • Part 98 Subpart W 2 2 10 - Federal Oil & Gas Air Regulations 10-1 Major vs. Area Sources • A major source has actual or potential emissions at or above the major source threshold for any air pollutant • The major source threshold for any air pollutant is 100 tpy • Lower thresholds apply in non-attainment areas (but only for the pollutant that is in non-attainment) • Major source thresholds for “hazardous air pollutants” (HAP) are 10 tons/year for a single HAP or 25 tons/year for any combination of HAP 3 3 New Source Performance Standards (NSPS) • Regulates Criteria Pollutants (e.g., VOC, NOx, CO, PM, SO2) • OOOOa adds GHG (as does Subpart TTTT) • Affected facilities at all types of sites • Only regulates New, Modified, or Reconstructed Sources • Proposal date is effective date • Established under CAA section 111 4 4 10 - Federal Oil & Gas Air Regulations 10-2 National Emission Standards for Hazardous Air Pollutants (NESHAP) • Regulates Hazardous Air Pollutants (HAP) • e.g., Formaldehyde, BTEX, etc. • Affected facilities at “major” or “area” sources • Major Sources must implement MACT (Maximum Achievable Control Technology) • Area Sources must implement GACT (Generally Available Control Technology) • Regulates both new and existing sources • Proposal date is effective date • More stringent requirements for new sources than existing sources, and more stringent requirements for major sources than area sources • Established under CAA section 112 5 5 NESHAP Risk and Technology Review • CAA requires EPA to conduct 2 types of reviews of NESHAPs for Major Sources: 1. Residual Risk – One time review 8 years after standard is initially developed 2. Technology Review – Every 8 years after standard is initially developed 6 6 10 - Federal Oil & Gas Air Regulations 10-3 NSPS Subpart Kb - Storage Vessels • Applicability • Tanks modified/constructed after 7/23/1984 • Storage vessels (tanks) ≥ 75 m3 (19,812 gal) containing volatile organic liquids • Tank size and vapor pressure cutoffs • Does not apply to vessels with a design capacity less than or equal to 1,590 m3 (420,000 gal) used for petroleum or condensate stored, processed, or treated prior to custody transfer • Requirements • Fixed roof and internal floating roof; or • External floating roof; or • Closed vent system and a control device that reduces VOC emissions by 95% 7 7 NSPS Subpart KKK – VOC Equipment Leak Standards Onshore Natural Gas Processing Plants • Applicability • Modified/constructed between 1/20/1984 and 8/23/2011 • Process units (dehydration, sweetening, storage tanks, etc.) • Requirements • Establishes standards for VOC • Refers to equipment leak standards in 40 CFR 60 Subpart VV (LDAR) • Leak = ≥10,000 ppm, 15 days to repair leak, attempt after 5 days • Closed vent systems and control devices used for compliance must achieve 95% VOC control 8 8 10 - Federal Oil & Gas Air Regulations 10-4 NSPS Subpart LLL- SO2 Standards for Onshore Natural Gas Processing • Applicability • Modified/constructed between 1/20/1984 and 8/23/2011 • Sweetening units and sulfur recovery units • Requirements • Establishes standards for SO2 • Achieve SO2 emissions reduction efficiency on a continuous basis • Monitor sulfur production rate, H2S concentration in the acid gas, acid gas flow rate, and sulfur dioxide emission reduction efficiency • If compliance is achieved via oxidation or reduction control systems, continuous monitoring of the sulfur emission rate is required 9 9 NSPS Subpart IIII – Stationary Compression Ignition Internal Combustion Engines • Applicability • Modified/constructed after 7/11/2005 (earliest date) • Stationary engines (not mobile) • Diesel engines • Requirements • NOx, Hydrocarbons (HC), CO, PM limits • Requirements depend on size, date, location, function (emergency) • Except for engines > 30 liters per cylinder (l/cyl) displacement, performance testing is not required - you achieve compliance by: • purchasing a new engine that has been certified by EPA, and • installing, configuring, operating, and maintaining the engine per the manufacturer’s instructions 10 10 10 - Federal Oil & Gas Air Regulations 10-5 NSPS Subpart JJJJ – Stationary Spark Ignition Internal Combustion Engines • Applicability • Modified/constructed after 6/12/2006 (earliest date) • Stationary engines (not mobile) • Natural gas and gasoline-fired engines • Requirements • Operators may comply by purchasing an engine certified by the manufacturer • For spark ignition engines, operators comply by meeting emission limits for an engine not certified by the manufacturer • NOx, CO, VOC limits • Fuel sulfur limits for gasoline • Requirements depend on size, type, and date • Performance testing • Performance/emissions monitoring • Recordkeeping/Notifications/Reporting 11 11 NESHAP Subpart HH- Oil and Natural Gas Production Facilities • Applicability • Proposal Date: 8/23/2011 • Covers major and area sources of HAP that process, upgrade, or store hydrocarbon liquids or that process, upgrade, or store natural gas • Major sources: Glycol dehydration units, storage vessels w/ potential to flash, and equipment in volatile HAP service (>10% by weight VHAP) not covered by another NSPS • Area sources: Triethylene glycol (TEG) dehydration units • Exemptions: • Facilities that exclusively process, store, or transfer black oil • A major source facility with a facility-wide actual annual average natural gas throughput less than 18,400 scm/d (~650,000 scf/d) and a facility-wide actual annual average hydrocarbon liquid throughput less than 39,700 L/d (~10,500 gal/d) 12 12 10 - Federal Oil & Gas Air Regulations 10-6 NESHAP Subpart HH- Oil and Natural Gas Production Facilities (Cont.) • Requirements • Glycol dehydration units • All large units (>3 MMscfd and >1.0 tpy benzene) • Send still vent emissions to a control device via a closed vent system achieving 95% reduction, or 20 ppmv TOC/HAP; or to control device via a closed vent system and reduce benzene emissions to < 1tpy • Small dehy units constructed before 8/23/2011 are existing; small dehy units constructed after 8/23/2011 are new • Use the equation in the rule to establish the emission limit; meet the limit through a control device, process changes, or show it meets the standard without control • All storage tanks with potential to flash: closed vent systems and 95% control • All equipment in volatile HAP service must comply with Subpart VV (LDAR) • Area source TEG dehydration units • In urban areas, use same control as for major sources • In rural areas, operate at optimal glycol recirculation rate 13 13 NESHAP Subpart HHH - Natural Gas Transmission and Storage Facilities • Applicability • Applies to major sources of HAP • New and existing glycol dehydration units • Exemptions: • A major source facility with a facility-wide actual annual average natural gas throughput less than 28,300 scm/d (~1,000,000 scf/d) where glycol dehydration units are the only HAP emission source • Requirements • All large units (>10 MMscfd and >1.0 tpy benzene) must route emissions to a control device • reduce TOC/HAP by 95%, or reduce outlet concentration of TOC/HAP to 20 ppmv, or reduce benzene emissions to less than 0.90 Mg/year (1 tpy) • Small dehy units constructed before 8/23/2011 are existing; small dehy units constructed after 8/23/2011 are new • Must limit BTEX emissions by routing emissions to a control device or meeting an emissions limit through process modifications 14 14 10 - Federal Oil & Gas Air Regulations 10-7 NESHAP Subpart ZZZZ - Stationary Reciprocating Internal Combustion Engines • Applicability • Applies to major and area sources of HAP • Applies to new and existing reciprocating engines • Tighter requirements for new engines • Exempt: existing emergency engines located at residential, institutional, or commercial area sources • Requirements • Includes emissions standards and O&M requirements • Oil and filter change, air filter, spark plugs • Formaldehyde, CO limitations • Oxidation catalysts or NSCR • Requirements complicated, dependent on major/minor status, size, type, location, function (emergency, limited use) 15 15 Part 98 Subpart W • Annual GHG reporting program • Facilities use uniform methods prescribed by the EPA to calculate GHG emissions, such as direct measurement, engineering calculations, or emission factors derived from direct measurement • In some cases, facilities have a choice of calculation methods for an emission source • Direct reporting to EPA electronically Source: EPA, https://www.epa.gov/ghgreporting/ghgrp-and-oil-and-gas-industry 16 16 10 - Federal Oil & Gas Air Regulations 10-8 Part 98 Subpart W Sources 2017 Reported Process Emission Sources Pneumatic Devices 31 Misc Equipment Leaks 14 Acid Gas Removal Units 12 Associated Gas Venting and Flaring 9 Other Flare Stacks 9 Atmospheric Storage Tanks 1 1 6 4 Distribution Mains 9 Blowdown Vent Stacks 7 Distribution Services 4 Reciprocating Compressors 3 Well Compl. and Work. with HF 2 1 Dehydrators 2 Pneumatic Pumps 3 Centrifugal Compressors 2 Liquids Unloading 2 Offshore Sources 2 Distribution M-R Stations Transmission Tanks Gas Well Compl. and Work. without HF Well Testing CO2 Emissions Enhanced Oil Recovery Liquids CH4 Emissions N2O Emissions Enhanced Oil Recovery Pumps 0 5 10 15 Emissions, MMT CO2e 20 25 30 35 17 Source: EPA, 2018 Stakeholder Presentation for Subpart W 17 10 - Federal Oil & Gas Air Regulations 10-9 NSPS SUBPART OOOO & SUBPART OOOOA Chapter 11 1 General NSPS Requirements • Regulates criteria pollutants (e.g., VOC, NOx, CO, PM, SO2) • NSPS Subpart OOOOa adds GHG • “Affected facilities” at all types of sites • Proposal date is effective date • Proposal/effective date for Subpart OOOO is August 23, 2011 • Proposal/effective date for Subpart OOOOa is September 19, 2015 2 2 11 - NSPS OOOO/OOOOa 11-1 General NSPS Requirements • Applies only to “new, modified or reconstructed sources” • Does not apply to existing sources • Requirements typically consist of: • Emissions limitations • Performance testing (e.g., stack testing) • Parametric and/or emissions monitoring • Recordkeeping • Notification • Reporting • The rules typically apply to the owner/operator 3 3 Construction/Affected Facility Definitions Construction means fabrication, erection, or installation of an affected facility. Affected facility means, with reference to a stationary source, any apparatus to which a standard is applicable. • e.g., a compressor, a storage tank, gas well completion • Relocating an affected facility is not construction, modification, or reconstruction under NSPS and does not trigger the rule 4 4 11 - NSPS OOOO/OOOOa 11-2 Modification Definition Modification means any physical or operational change to an existing facility (e.g., the engine) which results in an increase in the emission rate of any pollutant to which a standard applies (40 CFR 60.14) • Definition and concepts of “modification” in other subparts can be different if defined within another subpart 5 5 Modification Details “increase the amount of any pollutant” • Hourly emissions rate change (60.14(b)) • Interpreted as increase in short-term potential emissions • Increasing hours of operation alone without an increase in hourly emissions rate does not constitute a modification (60.14(e)(3)) “to which a standard applies” • An increase in emissions of a pollutant not regulated by the NSPS Subpart is not a modification • Applicability is pollutant-specific: the only applicable sections of an NSPS Subpart are those which regulate the pollutant whose emissions increased due to the modification (60.14(a)) 6 6 11 - NSPS OOOO/OOOOa 11-3 NSPS Modification Exemptions • Routine maintenance, repair, and replacement • An increase in production rate without a capital expenditure • An increase in hours of operation • Use of an alternative fuel or raw material if source could accommodate it prior to the standard • Addition of air pollution control device • Change in ownership 7 7 Capital Expenditure per Subpart A Capital expenditure means an expenditure for a physical or operational change to an existing facility which exceeds the product of the applicable “annual asset guideline repair allowance percentage” specified in the latest edition of Internal Revenue Service (IRS) Publication 534 and the existing facility's basis, as defined by section 1012 of the Internal Revenue Code. However, the total expenditure for a physical or operational change to an existing facility must not be reduced by any “excluded additions” as defined in IRS Publication 534, as would be done for tax purposes. 8 8 11 - NSPS OOOO/OOOOa 11-4 Capital Expenditure per Subpart OOOOa Capital expenditure means, in addition to the definition in 40 CFR 60.2, an expenditure for a physical or operational change to an existing facility that exceeds P, the product of the facility’s replacement cost, R, and an adjusted annual asset guideline repair allowance, A, as reflected by the following equation: P = R × A, where: 1. The adjusted annual asset guideline repair allowance, A, is the product of the percent of the replacement cost, Y, and the applicable basic annual asset guideline repair allowance, B, divided by 100 as reflected by the following equation: A = Y × (B ÷ 100); 2. The percent Y is determined from the following equation: Y = 1.0 – 0.575 log ×, where × is 2015 minus the year of construction; and 3. The applicable basic annual asset guideline repair allowance, B, is 4.5. 9 9 NSPS VVa Applicability through NSPS OOOO • NSPS Subpart OOOO gas processing plant fugitives (leaks) are addressed through Subpart VVa • Addition or replacement of equipment for the purpose of process improvement which is accomplished without a capital expenditure shall not by itself be considered a modification under this subpart • Process improvement means routine changes: • Safety and occupational health requirements • Energy savings • Ease of maintenance and operation • Correction of design deficiencies • Bottleneck removal • Changing product requirements • Environmental control 10 10 11 - NSPS OOOO/OOOOa 11-5 Reconstruction Definition • Reconstruction means the replacement of components of an existing facility to such an 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 entirely new facility, and • It is technologically and economically feasible to meet the applicable standards set forth in this part • Effects on emissions are not considered • “Fixed capital costs” = capital needed to provide all the depreciable components 11 11 Subpart OOOO vs. Subpart OOOOa • NSPS OOOO covers new, modified and reconstructed sources between 8/23/2011 and on or before 9/18/2015 • NSPS OOOOa covers new, modified and reconstructed sources after 9/18/2015 • Compliance with OOOOa is considered compliance with OOOO NSPS OOOO NSPS OOOOa August 23, 2011 ‐ September 18, 2015 September 19, 2015 ‐‐> 12 12 11 - NSPS OOOO/OOOOa 11-6 Subpart OOOO Affected Facilities • OOOO only regulated VOCs (not GHGs) • Affected facilities in Subpart OOOO: • Each natural gas well that is hydraulically fractured • Each centrifugal compressor using wet seals • Each reciprocating compressor • Each continuous bleed natural-gas driven pneumatic controller • Each storage vessel with a >6 tpy VOC PTE • Group of equipment (pump, pressure relief device, open-ended valve or line, valve, and flange or other connector in VOC or wet gas service), within a process unit located at onshore natural gas processing plants • Sweetening units located at onshore natural gas processing plants 13 13 Affected Facility Exceptions • Pneumatic controllers with a natural gas bleed rate ≤6 scfh not at gas processing plants are not affected • Intermittent pneumatic controllers are not affected • Centrifugal compressors using dry seals are not affected • Centrifugal and reciprocating compressors located at a well site are not affected • Well site means one or more areas that are directly disturbed during the drilling and subsequent operation of, or affected by, production facilities directly associated with any oil well, gas well, or injection well and its associated well pad. 14 14 11 - NSPS OOOO/OOOOa 11-7 15 15 16 16 11 - NSPS OOOO/OOOOa 11-8 OOOO Standards and Compliance Schedule NSPS OOOO Affected Facility Hydraulically fractured wildcat and delineation wells Hydraulically fractured low pressure non-wildcat and non-delineation wells Other hydraulically fractured wells Other hydraulically fractured wells Centrifugal compressors with wet seals Reciprocating compressors Pneumatic controllers at NG processing plants Pneumatic controllers between wellhead and NG processing plants Group 2 and 1 Storage Vessels Equipment Leaks Sweetening Units Standard Completion combustion Compliance Date October 15, 2012 Completion combustion Completion combustion October 15, 2012 Before 1/1/2015 REC and completion combustion After 1/1/2015 95% reduction October 15, 2012 Change rod packing October 15, 2012 Zero bleed rate October 15, 2012 6 scfh bleed rate October 15, 2013 95% reduction LDAR program Reduce SO2 as calculated April 15, 2014/2015 October 15, 2012 17 October 15, 2012 17 NSPS Subpart OOOOa This subpart establishes emission standards and compliance schedules for the control of [GHG], volatile organic compounds (VOC) and sulfur dioxide (SO2) emissions from affected facilities in the crude oil and natural gas source category that commence construction, modification or reconstruction after September 18, 2015. 18 18 11 - NSPS OOOO/OOOOa 11-9 Definition of the Source Category • Crude oil and natural gas source category means: 1. Crude oil production, which includes the well and extends to the point of custody transfer to the crude oil transmission pipeline or any other forms of transportation 2. Natural gas production, processing, transmission, and storage, which include the well and extend to, but do not include, the local distribution company custody station 19 19 Definition of Custody Transfer [60.5430a] Custody transfer means the transfer of crude oil or natural gas after processing and/or treatment in the producing operations, or from storage vessels or automatic transfer facilities or other such equipment, including product loading racks, to pipelines or any other forms of transportation. 20 20 11 - NSPS OOOO/OOOOa 11-10 21 21 22 22 11 - NSPS OOOO/OOOOa 11-11 OOOOa Standards and Compliance Schedule NSPS OOOOa Affected Facility Hydraulically fractured wildcat wells, delineation wells, or low pressure wells Standard Compliance Date Completion combustion August 2, 2016 August 2, 2016 November 30, 2016 for REC standard for non-gas wells REC, completion combustion unless GOR < 300 scf/bbl 95% reduction (P.E. Certification if equipped with CVS) Change rod packing or route emissions Reciprocating compressors (not on well sites, to process (P.E. Certification if equipped up to the LDC) with CVS) Pneumatic controllers at NG processing plants Zero bleed rate Continuous bleed pneumatic controllers between wellhead and the LDC (not at gas processing plants) ≤6 scfh bleed rate Other hydraulically fractured wells Centrifugal compressors with wet seals (not on well sites, up to the LDC) August 2, 2016 August 2, 2016 August 2, 2016 August 2, 201623 23 OOOOa Standards and Compliance Schedule NSPS OOOOa Affected Facility Standard Compliance Date Zero bleed rate November 30, 2016 Pneumatic pumps at well sites 95% reduction if control or process available onsite (P.E. Certification if equipped with CVS) November 30, 2016 Storage vessels 95% reduction (P.E. Certification if equipped with CVS) August 2, 2016 Equipment leaks at gas processing plants Equipment leaks at well sites and compressor stations Leak Detection and Repair (LDAR) program August 2, 2016 LDAR program June 3, 2017 Sweetening units at gas processing plants Reduce SO2 as calculated August 2, 2016 24 Pneumatic pumps at gas processing plants 24 11 - NSPS OOOO/OOOOa 11-12 WELL REQUIREMENTS 25 25 Subpart OOOOa Flowback Definitions Flowback means the process of allowing fluids and entrained solids to flow from a well following a treatment, either in preparation for a subsequent phase of treatment or in preparation for cleanup and returning the well to production. The term flowback also means the fluids and entrained solids that emerge from a well during the flowback process. The flowback period begins when material introduced into the well during the treatment returns to the surface following hydraulic fracturing or refracturing. The flowback period ends when either the well is shut in and permanently disconnected from the flowback equipment or at the startup of production. The flowback period includes the initial flowback stage and the separation flowback stage. Initial flowback stage means the period during a well completion operation which begins at the onset of flowback and ends at the separation flowback stage. Separation flowback stage means the period during a well completion operation when it is technically feasible for a separator to function. The separation flowback stage ends either at the startup of production, or when the well is shut in and permanently disconnected from the flowback equipment. 26 26 11 - NSPS OOOO/OOOOa 11-13 Subpart OOOOa Recovered Gas/Liquids Definitions Recovered gas means gas recovered through the separation process during flowback. Recovered liquids means any crude oil, condensate or produced water recovered through the separation process during flowback. 27 27 Well Affected Facility • The gas well requirements of subpart OOOO/OOOOa apply to well completion operations at each well affected facility. • A single well is an affected facility if: • It conducts a well completion operation after hydraulically fracturing of a well; or • It conducts a well completion operation after hydraulically refracturing • NSPS OOOOa added oil well completions requirements 28 28 11 - NSPS OOOO/OOOOa 11-14 Low Gas to Oil Ratio (GOR) Well Standards • A low GOR well is a well affected facility with less than 300 scf of gas per stock tank barrel of oil produced • No control or work practice requirements • Make the determination that the well has a GOR of less than 300 and maintain records that verify the determination of the GOR for the well • Safely maximize resource recovery and minimize releases to the atmosphere during flowback and subsequent recovery • Maintain a daily log for each well completion operation for the duration of the well completion 29 29 Low Pressure Wells • Calculation methods to determine if well is “low pressure” are in 60.5432a • Low pressure well: a well that satisfies at least one of the following conditions: 1. The static pressure at the wellhead following fracturing but prior to the onset of flowback is less than the flow line pressure at the sales meter; 2. The pressure of flowback fluid immediately before it enters the flow line, as determined under 60.5432a, is less than the flow line pressure at the sales meter; or 3. Flowback of the fracture fluids will not occur without the use of artificial lift equipment 30 30 11 - NSPS OOOO/OOOOa 11-15 Well Completion Standards – Wildcat, Delineation, & Low Pressure Wells • The operator is not required to have a separator onsite • Either: 1. 2. Route all flowback to a completion combustion device with a continuous pilot flame; or Route all flowback into one or more well completion vessels and commence operation of a separator unless it is technically infeasible for a separator to function • Any gas present in the flowback before the separator can function is not subject to control under OOOOa • Capture and direct recovered gas to a completion combustion device with a continuous pilot flame • For both options (1) and (2), combustion is not required in conditions that may result in a fire hazard or explosion, or where high heat emissions from a completion combustion device may negatively impact tundra, permafrost or waterways 31 31 Well Completion Standards – Non-Wildcat & Non-Delineation Wells • Reduced emissions completion (REC) (AKA GREEN COMPLETION) in combination with a completion combustion device; venting in lieu of combustion where combustion would present safety hazards • Initial flowback stage: Route to a storage vessel or completion vessel (frac tank, lined pit, or other vessel) and separator • Separation flowback stage: Route all salable gas from the separator to a flow line or collection system, re-inject the gas into the well or another well, use the gas as an onsite fuel source or use for another useful purpose that a purchased fuel or raw material would serve. • If technically infeasible to route recovered gas as specified above, recovered gas must be combusted • All liquids must be routed to a storage vessel or well completion vessel, collection system, or be re-injected into the well or another well • The operator is required to have a separator onsite during the entire flowback period 32 32 11 - NSPS OOOO/OOOOa 11-16 COMPRESSOR REQUIREMENTS 33 33 Centrifugal Compressor Affected Facility • A single centrifugal compressor using wet seals is an affected facility • NSPS OOOO: between the wellhead and the point of custody transfer to the natural gas transmission and storage segment • NSPS OOOOa: between the well site and up to (but not including) the point of custody transfer to the Local Distribution Company • If the centrifugal compressor is located at a well site, or an adjacent well site and services more than one well site, it is not considered an affected facility • Dry seal centrifugal compressors are not affected facilities 34 34 11 - NSPS OOOO/OOOOa 11-17 Centrifugal Compressor Standards • CH4 and VOC emissions from each centrifugal compressor wet seal fluid degassing system must be reduced by 95 percent • Equip with P.E. certified closed vent system to a control device (not required in Subpart OOOO) • Conduct initial inspection • Install and operate continuous parameter monitoring system (CPMS) on control device • Initial performance test required 35 35 Compliance Demonstration for Centrifugal Compressors • For centrifugal compressors with wet seals using control devices: • Initial performance test and periodic performance test within 60 months of previous test for certain control devices • Manufacturer tests can be used to replace on-site initial and periodic performance tests • Design analyses are allowed in lieu of a performance test for certain control devices (e.g., open flare, boiler, condensers, carbon adsorbers) • Maintain daily average control device parameters above (or below) the minimum (or maximum) level established during the performance test • Prepare site-specific monitoring plan for continuous monitoring system • Conduct initial and annual inspections of covers and closed vent systems for leaks or defects 36 36 11 - NSPS OOOO/OOOOa 11-18 Reciprocating Compressor Affected Facility • A reciprocating compressor affected facility is each single reciprocating compressor • NSPS OOOO: between the wellhead and the point of custody transfer to the natural gas transmission and storage segment • NSPS OOOOa: between the well site and up to (but not including) the point of custody transfer to the Local Distribution Company • A reciprocating compressor located at a well site, or an adjacent well site and servicing more than one well site, is not an affected facility 37 37 Reciprocating Compressor Standards • Primary requirement is to replace the rod packing or otherwise collect vapors • You can choose to replace rod packing before either of the following occur: • the compressor has operated for 26,000 hours; or • 36 months from the last replacement 38 38 11 - NSPS OOOO/OOOOa 11-19 PNEUMATIC CONTROLLERS 39 39 Pneumatic Controller Affected Facility • NSPS OOOO/OOOOa applies to each, continuous bleed, natural gas- driven pneumatic controllers as follows: • Each pneumatic controller affected facility located at a natural gas processing plant, which is a single continuous bleed natural gas-driven pneumatic controller • Each pneumatic controller affected facility located at other than a natural gas processing plant, which is a single, continuous bleed natural gas-driven pneumatic controller operating at a natural gas bleed rate greater than 6 scfh • Intermittent or snap-action pneumatic controllers and non-natural gas-driven pneumatic controllers are not affected facilities under Subpart OOOO/OOOOa 40 40 11 - NSPS OOOO/OOOOa 11-20 Pneumatic Controller Standards • Each affected continuous bleed pneumatic controller at natural gas processing plants must have a bleed rate of zero • Applies to those pneumatic controllers that are new, modified, or reconstructed after August 23, 2011 • Effective October 15, 2012 • OOOO: Each affected continuous bleed pneumatic controller between the wellhead and the natural gas transmission segment (excluding natural gas processing plants) must have a bleed rate of ≤6 scfh • Anything modified, constructed or reconstructed on or after October 15, 2013 between the wellhead and a natural gas processing plant • OOOOa: Each pneumatic controller located between the well site and up to (but not including) the point of custody transfer to the Local Distribution Company (excluding natural gas processing plants) must have a bleed rate of ≤6 scfh 41 41 Pneumatic Controller Standards • Each pneumatic controller not meeting the standard must be tagged with the month and year of installation and identification information • Pneumatic controllers required to have a greater bleed rate due to “functional needs” (positive actuation, safety, and response time) are exempt from the < 6 scfh limitation • These must be identified in the annual report, tagged, and justified 42 42 11 - NSPS OOOO/OOOOa 11-21 PNEUMATIC PUMPS 43 43 Pneumatic Pump Affected Facility • Each natural gas-driven diaphragm pump constructed, modified or reconstructed after September 18, 2015 and located at a natural gas processing plant or at a well site is an affected facility • Pneumatic pumps are a new source category in NSPS OOOOa • There are no requirements under the rule for pumps located in the gathering and boosting or transmission and storage segments • These requirement do not apply to piston pumps or pumps that are driven by means other than natural gas • Pumps located at a well site that operate for any period of time each day for less than a total of 90 days per year is a limited-use pneumatic pump and is not an affected facility • Lean glycol circulation pumps are not affected facilities. 44 44 11 - NSPS OOOO/OOOOa 11-22 Pneumatic Pump Standards • Natural gas pneumatic diaphragm pumps located at a gas processing facility must have a bleed rate of 0 scf/h • Natural gas pneumatic pumps at greenfield well sites must reduce emissions by 95% • If control device cannot meet 95% reduction, must still connect to the control device & report reduction efficiency; or • If no control device is on-site and unable to route to a process, maintain records and “report” Greenfield site means a site, other than a natural gas processing plant, which is entirely new construction. Natural gas processing plants are not considered to be greenfield sites, even if they are entirely new construction. 45 45 Pneumatic Pump Standards • Natural gas pneumatic diaphragm pumps at non-greenfield well sites must reduce emissions by 95% • If control device cannot meet 95% reduction, must still connect to the control device & report reduction efficiency; or • If no control device is on-site and unable to route to a process, maintain records and report; or • If infeasible to route to control or process, submit P.E. certification to support claim of infeasibility • Infeasibility could be based on safety, distance, pressure losses/differentials, or the ability of the control to handle pump emissions 46 46 11 - NSPS OOOO/OOOOa 11-23 STORAGE TANKS 47 47 NSPS OOOO Storage Tanks Affected Facility • NSPS OOOO/OOOOa applies to individual tanks that emit >6 tpy VOC PTE that: • were constructed, modified, or reconstructed after August 23, 2011; • are located in the: • oil and natural gas production segment • natural gas processing segment • natural gas transmission and storage segment • Contain crude oil, condensate, produced water or intermediate hydrocarbon liquids 48 48 11 - NSPS OOOO/OOOOa 11-24 NSPS OOOOa Storage Tanks Affected Facility • Exemptions: • A storage vessel with a capacity greater than 100,000 gallons used to recycle water that has been passed through two stage separation is not a storage vessel affected facility • Storage vessels subject to and controlled in accordance with the requirements for storage vessels in 40 CFR part 60, subpart Kb, 40 CFR part 63, subparts G, CC, HH, or WW • A storage vessel affected facility that subsequently has its potential for VOC emissions decrease to less than 6 tpy remains an affected facility • A storage vessel that is removed from service and subsequently reconnected to the original source of liquids is subject to the same requirements that applied before being removed from service • Any storage vessel that is used to replace a storage vessel affected facility is subject to the same requirements that apply to the storage vessel being replaced 49 49 Storage Tank Control Requirements • Tanks with emissions >6 tpy: • Reduce VOC emissions by ≥ 95.0 percent through use of a control device or floating roof • If using a control device, equip with specified cover and connect through a closed vent system to a control device • If constructed, modified or reconstructed after 9/18/2015, P.E. certification on CVS (Subpart OOOOa) • Tanks have 30 days from startup to calculate emissions and 60 days from startup to meet control requirements 50 50 11 - NSPS OOOO/OOOOa 11-25 Storage Tank Off Ramp • Once uncontrolled emissions drop <4 tpy, the control device can be removed from the storage vessel; • Must be demonstrated through 12 consecutive month demonstration of emissions less than 4 tpy • Must re-calculate emissions monthly to ensure not >4 tpy • Must take into account anything that could increase emissions (e.g., fracking of a nearby well) 51 51 GAS PROCESSING PLANTS Leaks & Sweetening Units 52 52 11 - NSPS OOOO/OOOOa 11-26 Equipment Leaks at NG Processing Plants Affected Facility • NSPS OOOO/OOOOa apply to the group of all equipment (except single compressors) within a process unit that is located at an onshore natural gas processing plant in VOC or wet gas service • and that commenced construction, reconstruction or modification after September 18, 2015 Process unit means components assembled for the extraction of natural gas liquids from field gas, the fractionation of the liquids into natural gas products, or other operations associated with the processing of natural gas products. A process unit can operate independently if supplied with sufficient feed or raw materials and sufficient storage facilities for the products. 53 53 VOC & Wet Gas Service In VOC service means that the piece of equipment contains or contacts a process fluid that is at least 10 percent VOC by weight. For a piece of equipment to be considered in wet gas service, it must be determined that it contains or contacts the field gas before the extraction step in the process. Field gas means feedstock gas entering the natural gas processing plant. 54 54 11 - NSPS OOOO/OOOOa 11-27 Natural Gas Processing Definition Natural gas processing plant (gas plant) means any processing site engaged in the extraction of natural gas liquids from field gas, fractionation of mixed natural gas liquids to natural gas products, or both. A Joule-Thompson valve, a dew point depression valve, or an isolated or standalone Joule-Thompson skid is not a natural gas processing plant. 55 55 Equipment Leaks at NG Processing Plants Standards • Comply with NSPS Subpart VVa • Leak definitions: Component Leak Definition (ppm) Pumps in light liquid service 2,000 Valves in gas/vapor service 500 Valves in light liquid service 500 Connectors Pumps, valves, and connectors in heavy liquid service; pressure relief devices in light liquid or heavy liquid service 500 AVO/10,000 56 56 11 - NSPS OOOO/OOOOa 11-28 Sweetening Unit Affected Facility • NSPS OOOOa applies to each sweetening unit that process natural gas or each sweetening unit that processes natural gas followed by a sulfur recovery unit • Sweetening units that have a design capacity less than 2 long tons per day (LT/D) of hydrogen sulfide (H2S) in the acid gas are required to comply only with recordkeeping and reporting requirements outlined in 60.5423a(c) and have no control or emission reduction requirements • Sweetening facilities producing acid gas that is completely reinjected into oil-or-gas-bearing geologic strata or that is otherwise not released to the atmosphere are exempt from the rule requirements 57 57 Sweetening Unit Standards • Comply with percent reduction requirements based on sulfur feed rate and hydrogen sulfide (H2S) content of acid gas • Initial performance test required • Must show compliance with required minimum initial SO2 emission reduction efficiency: Where X = The sulfur feed rate from the sweetening unit (i.e., the H2S in the acid gas), expressed as sulfur, Mg/D(LT/D), rounded to one decimal place Y = The sulfur content of the acid gas from the sweetening unit, expressed as mole percent H2S (dry basis) rounded to one decimal place 58 58 11 - NSPS OOOO/OOOOa 11-29 Sweetening Unit Standards • Monitoring of sulfur product accumulation, H2S content, and acid gas flow rate to show continual compliance with minimum SO2 emission reduction efficiency: Where X = The sulfur feed rate from the sweetening unit (i.e., the H2S in the acid gas), expressed as sulfur, Mg/D(LT/D), rounded to one decimal place Y = The sulfur content of the acid gas from the sweetening unit, expressed as mole percent H2S (dry basis) rounded to one decimal place 59 59 WELL SITES & COMPRESSOR STATIONS Fugitive Emissions 60 60 11 - NSPS OOOO/OOOOa 11-30 Fugitives at Well Sites and Compressor Stations Affected Facility • Affected facilities are oil or natural gas well site or a compressor station for which the owner/operator commenced construction, modification, or reconstruction after September 18, 2015 • Equipment leaks at well sites and compressor stations are a new source category in NSPS OOOOa 61 61 Fugitive Emission Components • “Fugitive emission components” required to be monitored include: • valves • connectors • pressure relief devices • open-ended lines • flanges • compressors • instruments • meters • covers and closed vent systems (i.e., piping) not subject to NSPS OOOOa monitoring • storage thief hatches or other openings on a controlled storage vessel • Pneumatic controllers and pumps designed to vent as normal part of operations are not defined as fugitive emission sources 62 62 11 - NSPS OOOO/OOOOa 11-31 Fugitives at Well Sites and Compressor Stations Standards • Monitor fugitive emission components with an optical gas imaging (OGI) device or using Method 21 • Conduct surveys semi-annually at new or modified well sites • Low production wells not exempted • Conduct surveys quarterly at new or modified compressor stations • Stations located in an area where average monthly temperature is <0 degrees for two consecutive months of a quarterly period can be waived – but not for two consecutive quarterly periods • Owner/operator must prepare a fugitive emissions monitoring plan for the collection of fugitive emissions components at well sites or compressor stations within each company defined area • Plans are not required to be submitted, but must be provided upon request 63 63 Fugitives at Well Sites and Compressor Stations Standards • Conduct leak surveys within 60 days of startup of production or modification or by June 3, 2017 (whichever is later) • Leaks are: • Any visible emission from a component using OGI; or • Reading of 500 ppm or more using Method 21 • Repair leaks within 30 days • Exceptions for repairs that would require a blowdown, shutdown, shut-in and other exceptions • Documentation requirements for such exceptions • Re-survey within 30 days of repair using Method 21, OGI, or alternative screening procedure 64 64 11 - NSPS OOOO/OOOOa 11-32 Definition of Well Site Well site means one or more surface sites that are constructed for the drilling and subsequent operation of any oil well, natural gas well, or injection well. For purposes of the fugitive emissions standards at 60.5397a, well site also means a separate tank battery surface site collecting crude oil, condensate, intermediate hydrocarbon liquids, or produced water from wells not located at the well site (e.g., centralized tank batteries). • Well sites are not subject to the requirements in subpart OOOOa if the well site contains only one or more wellheads (i.e., the well site does not have any equipment associated with the wellheads such as separators, compressors, heaters, or dehydrators) • A modification occurs when either: a new well is drilled at an existing well site, a well at an existing well site is hydraulically fractured, or a well at an existing well site is hydraulically refractured 65 65 Definition of a Compressor Station Compressor station means any permanent combination of one or more compressors that move natural gas at increased pressure through gathering or transmission pipelines, or into or out of storage. This includes, but is not limited to, gathering and boosting stations and transmission compressor stations. The combination of one or more compressors located at a well site, or located at an onshore natural gas processing plant, is not a compressor station for purposes of 60.5397a. • A modification to a compressor station occurs when an additional compressor is installed at the compressor station or when one or more compressors are replaced by compressors with a greater horsepower • If one or more compressors are replaced with compressors with equal or less horsepower, then installation of the compressors does not trigger a modification 66 66 11 - NSPS OOOO/OOOOa 11-33 GENERAL REQUIREMENTS 67 67 Notification Requirements • Hydraulically fractured wells • 2-day notification for completion activities • Also include in the annual report • Pneumatic controllers, pneumatic pumps, storage vessels, reciprocating compressors, and centrifugal compressors • Only include in annual report • Normal Subpart A notices for equipment leaks and sweetening units 68 68 11 - NSPS OOOO/OOOOa 11-34 Reporting Requirements • Annual report deadline is 90 days after the end of the reporting period • Subsequent reports due on the same date as initial report • Can combine reports for multiple affected facilities • Semiannual reports are required for equipment leaks (Subpart VVa) • Reporting will be required electronically once EPA has CEDRI forms available for 90 days 69 69 Recordkeeping • All information required in annual reports • Date, location, and manufacturer’s specifications for pneumatic controllers • Emission calculations for storage vessels • Number of days a skid mounted or mobile source mounted storage vessel is located on site • All instances of alarm of bypass to a control device 70 70 11 - NSPS OOOO/OOOOa 11-35 LITIGATION 71 71 NSPS OOOOa – 90 Day Stay • May 26, 2017: A 90-day stay for limited provisions of the rule (August 31, 2017 compliance deadline) • Pneumatic pump requirements (not at gas processing plants) • Closed vent system (CVS) design certification • Leak detection and repair (LDAR) surveys • Vacated by D.C. Circuit Court on July 3, 2017 • Court required “immediate enforcement” 72 72 11 - NSPS OOOO/OOOOa 11-36 NSPS OOOOa – 2-year Stay • June 12, 2017: EPA proposes a rulemaking to delay the following: • LDAR requirements for well sites and compressor stations • P.E. Certification for Closed Vent Systems (CVS) • Pneumatic pump requirements • Also proposed another 90-day stay that would apply after the initial stay expired until the two-year stay took effect • Comment period closed August 9, 2017 • D.C. Court decision does not impact EPA’s authority to implement a 2-year stay • The proposed 2‐year stay was never finalized 73 73 NSPS OOOOa – 2019 Proposed Revisions • August 28, 2019: EPA proposed amendments to the 2012 and 2016 New Source Performance Standards for the Oil and Natural Gas Industry that would “remove regulatory duplication and save the industry millions of dollars in compliance costs each year, while maintaining health and environmental protection from oil and gas sources that the Agency considers appropriate to regulate.” • The proposed amendments would remove all sources in the transmission and storage segment of the oil and natural gas industry from regulation under the NSPS, both for VOCs and GHGs • The amendments also would rescind the methane requirements in the 2016 NSPS that apply to sources in the production and processing segments of the industry 74 74 11 - NSPS OOOO/OOOOa 11-37 QUESTIONS? 75 75 11 - NSPS OOOO/OOOOa 11-38