40 CFR Part 98 GHG Reporting for the Oil and Gas Industry...

40 CFR Part 98 GHG Reporting for the Oil and Gas Industry

Rule, Past, Present, and Future

Eric P. Anderson, PMP

President

EPA Systems, LLC

Austin, Texas



Background

Brief Outline of the Rule Applicability

Changes for RY 2014

Changes for RY 2015

Proposed Changes for RY 2016

Summary



GHG Mandatory Reporting Rule Program (GHGRP) 40 CFR Part 98

• Initially published 10/30/2009

• 46 emission source categories

• CO2, CH4, N2O, SF6, HFCs, and other fluorinated gases

Did not require control of GHG

Applicability

• >25000 MT CO2e per facility

Background



Offshore petroleum and

natural gas production

Onshore petroleum and


Onshore natural gas

processing

Onshore natural gas

transmission compression

Subpart W – Petroleum and Natural Gas Systems

Underground natural gas

storage

Liquefied natural gas (LNG)

storage

LNG import and export

equipment

Natural gas distribution

Boosting and Gathering (2016)



Continued

Natural gas pneumatic device and pneumatic pump venting

Well venting for liquids unloading

Gas well venting during well completions with and w/o hydraulic fracturing

Gas well venting during well workovers with and w/o hydraulic fracturing

Flare stack emissions

Storage tanks (production and transmission)

Reciprocating compressor rod packing venting

Subpart W - Source Types



Subpart W - Source Types

Well testing venting and flaring

Associated gas venting and flaring

Dehydrator vents

Blowdown vent stacks

EOR injection pump blowdown

Acid gas removal vents

EOR hydrocarbon liquids dissolved CO2

Centrifugal compressor venting

Equipment leaks

Combustion equipment (onshore production and distribution only)



Subpart C – Combustion

Subpart NN – Suppliers of Natural Gas Liquids (fractionators)

Subpart PP – Suppliers of Carbon Dioxide

Subpart RR – Geologic Sequestration of Carbon Dioxide

Subpart UU – Injection of Carbon Dioxide

Other Applicable Subparts



Confidential Business Information (CBI) elements back reported

for 2011, 2012, and 2013 (e.g., Deferred Reporting Elements)

• Potentially impacts Subpart C and a number of Subpart W

elements

Changes for RY 2014



In August 2011 [FR 56010], EPA deferred the reporting deadline for

a number of Subpart W equation inputs until March 31, 2015.

In October 2014 [FR 63750], EPA finalized the approach to reporting

these deferred inputs and in addition made several minor

modifications to the reporting requirements for Subpart W.

This results in reporters having to submit the deferred Subpart W

data for RY 2014 and deferred data for RY 2011, RY 2012, and RY

2013 as part of the facility’s RY2014 submission.

RY 2014 General Elements



EPA allows one of two methods for 2014 reporting:

• Submit CBI data in Inputs Verifier Tool (IVT) by web form or XML

schema; or

• Submit CBI data for 2014 using Web forms or Subpart C XML

schema and indivudla spreadsheets for 2010, 2011, 2012 and

2013 (to be developed)

Subpart C Deferred Reporting



Inputs to equations (e.g., number of high-bleed pneumatics)

Results of intermediate calculations (e.g., measured flow rate of

backflow)

Production / throughput data

Defined new CBI data elements applicable to reporters whose

ONLY wells in a sub-basin are either wildcat or delineation wells

(must report API well numbers)

Deferred Elements



Deferred Data Elements



If spreadsheet reporter, deferred elements must be reported in

individual yearly spreadsheets

If XML reporter, deferred elements can be reported as separate

nodes in RY 2014 reporting form

In either case must report file name for previous reporting year

How to Report



Wildcat or Delineation wells get 2-year reporting delay

• Applies to sub-basins where ONLY wells are delineation or

wildcat

• Delays reporting certain data associated with gas well

completions with hydraulic fracturing and production storage

tanks

Additional Elements Subject to Reporting Delay



Delineation well: a well drilled in order to determine the boundary

of a field or producing reservoir.

Wildcat well: a well outside known fields or the first well drilled in

an oil or gas field where no other oil and gas production exists.

Definitions consistent with NSPS OOOO

Definitions



Using IVT form assumes reporter wants all data to remain CBI

Subpart C web-form or XML Schema assumes reporter doesn’t

want data treated as CBI

If using IVT form (web-form or XML schema) relieves reporter

from reporting deferred data elements




CBI / Deferred elements include:

Total fuel usage (Tier 1)

Monthly fuel gas usage (Tier 2/3)

Monthly HHV values (Tier 2/3)

Average HHV value (Tier 2)

Average CC value (Tier 3)

Average MW value (Tier 3)




Pneumatic devices and pumps (onshore production)

• Counts (or estimated counts) by classification (high bleed, low

bleed, intermittent bleed)

Acid Gas Removal (onshore production, processing)

• Annual average fraction CO2 in or out of AGR

• Total throughput through AGR (million cubic feet per year)

• Annual quantity of CO2 recovered and transferred outside the

facility under Subpart PP

Dehydrators <0.4 mmscf/day (production, processing)

• Count

Subpart W Deferred Reporting



Dehydrators >0.4 mmscf/day (production, processing) must

report GRI Glycalc inputs

• Dehy feed flow rate (mmscfd)

• Absorbent circulation pump type

• Flash tank separator

• Stripper gas

• Type of absorbent

• Dehy operating hours

• Temperature and pressure of wet natural gas

• Concentration CH4 and CO2 in wet natural gas




Gas well completions and workovers with hydraulic

fracturing

If using Equation W-10A

• Measured flow rate of backflow during completions

• Measured flow rate of backflow during workovers

• Total number of day sof backflow from all well completions

• Total number of days of backflow from all well workovers

Number of reduced emission “green” completions




Gas well completions and workovers with hydraulic

fracturing

Volume of gas recovered to sales from green completions

Number of “green” workovers

Volume of gas recovered to sales from green workovers




Gas well completions and workovers without hydraulic fracturing

• Total number of completions

• Total count of workovers that flared or vented gas to the

atmosphere

Blowdown vent stacks (processing)

• Total number of blowdowns for each unique physical volume in

the calendar year if using Equation-14A (was already required for

those using 14B)




Atmospheric Storage Tanks > 10 bbls/d

• Quantity of CH4 and CO2 recovered using vapor recovery (VRU)

broken down by Methods 1 and 2 and Methods 3 and 4

• Total volume of oil from wellhead separators sent to tanks

• Total volume of oil from all wells

Atmospheric Storage Tanks < 10 bbls/d

• Number of wellhead separators

• Number wells without wellhead separators

• Quantity of CH4 and CO2 recovered using vapor recovery (VRU)




Centrifugal and reciprocating compressors (onshore production)

• Count

Centrifugal compressors (Processing)

• Total time in operating mode (hours)

• Total time in depressurized mode (hours)

• Reporter Emission factor for blowdown vents (operational mode)

(cfh)

• Reporter Emission factor for wet seal oil degassing vent

emissions (cfh)

• Reporter Emission factor for isolation valve emissions

depressurized mode (cfh)




Reciprocating compressors (Processing)

• Total time in operating mode (hours)

• Total time in standby pressurized mode (hours)

• Total time in depressurized mode (hours)

• Reporter Emission factor for blowdown vents (operating mode)

• Reporter Emission factor for standby pressurized mode

• Reporter Emission factor for isolation valve emissions

depressurized mode




Well venting for liquids unloading (onshore production)

• Average flow rate of the measured well

Combustion Emissions

• Volume of fuel (by fuel type) for:

External combustion units > 5 mmBtu/hr

Internal combustion units > 1 mmBtu/hr (and compressor engines)




Flares (onshore production, processing)

• Volume of gas combusted in cubic feet

• Combustion efficiency (normally defaulted to 98%)

Equipment leaks using emission factors (onshore production)

• Total count for each major equipment type (e.g., separators,

compressors, dehys, etc.)




EOR injection pump blowdown (production)

• Volume of critical phase gas between isolation valves

• Number of blowdowns per year

• EOR injection gas density

EOR dissolved liquids CO2 (production)

• Volume of oil produced per sub-basin

• Amount of CO2 retained in HC liquids




Transmission storage tanks – no change

Well testing venting/flaring – no change

Associated gas venting/flaring – no change




Greatly expands the reporting of inputs to equations (nearly 500

new or revised reporting outputs)

Eliminates the reporting of GHGs in CO2e

Modifies a number of equations (most notably the flowback

equations)

Modifies the data collection techniques for compressor venting

Applicable to all data collected starting 1 January 2015

Changes to RY 2015 Reporting



Number of pneumatic devices

Input parameters to equations for AGRs

More inputs to Glycalc Model

Additional inputs to well venting equations

Many more well type configurations for flowback reporting

2015 Reporting Changes



Many more well type configurations for flowback reporting (by

sub-basin)

• Completion/Workover

• Horizontal/Vertical

• With/Without flaring

• REC/Non-REC Completion

• Rec/Non-REC Workover

Volumetric flow rates during flowback and during period

immediately following turning gas to separation




Completions and Workovers w/o Fracing

• Average daily gas production rate

• Total hours gas vented to flare

• Average daily gas production rate for flared

completions/workovers

Blowdowns

• Total annual volume of gas vented from each source “unique

physical volume”

• Reporting by “equipment type”

• Total number of Blowdowns for each “equipment type”




Onshore Production Storage Tanks

• Changes number of calculation methods from 5 to 3

Associated Gas venting and flaring

• Changes definition of “stranded gas”

Compressor venting

• Must report reporter emission factors and associated data (e.g.,

hours in each op mode)

• Information on any Scheduled outages

• Information on venting configuration (manifolding)

• Individual measurement data




Flowback Calculations

• Requires the capture of the period from 1st gas appearance to

separation

• Must define reproducible procedure for how this will be done

• Requires this initial flowback gas volume to be captured

Changes to stuck dump valve calculations

Changes to associated gas venting Calculations

Addition of new compressor calculations

2015 Calculation Changes



Published 9 December 2014

Scheduled for 1 January 2016 Reporting Year

Add “boosting and gathering” to Subpart W

Adds oil well flowback emissions

Proposed 2016 Changes



Emissions from hydraulic fracturing of oil wells

• Uses similar equations currently used for gas wells but doesn’t

allow choke equations

Boosting and Gathering

• Facility is defined as HC Basin

• Includes pipelines, compressors, dehydration, AGR, and well

defined connection between production and downstream

• First proposed in April 2010 and then postponed




Defined as:

“gathering pipelines and other equipment used to collect

petroleum and/or natural gas from onshore production gas or oil

wells and used to compress, dehydrate, sweeten, or transport the

gas to a natural gas processing facility, a natural gas transmission

pipeline, or a natural gas distribution pipeline.”




Includes:

“would include, but would not be limited to, gathering pipelines,

separators, compressors, acid gas removal units, dehydrators,

pneumatic devices/pumps, storage vessels, engines, boilers,

heaters, and flares.”

Would still require 25,000 MT CO2e for reporting




Emission calculation methods generally in line with onshore


Would require reporting API well numbers

Provisions for advanced innovative monitoring methods such as

optical remote sensing technologies

Limits BAMM




Natural gas pneumatic device venting

Natural gas driven pneumatic pump venting

Acid gas removal vents.

Dehydrator vents

Blowdown vent stacks

Storage tank vented emissions

Flare stack emissions

Centrifugal compressor venting

Reciprocating compressor venting




Equipment leaks from valves connectors, open ended lines,

pressure relief valves, pumps, flanges, and other equipment leak

sources (such as instruments, loading arms, stuffing boxes,

compressor seals, dump lever

arms, and breather caps)

Gathering pipeline equipment leaks.

Combustion Emissions from stationary or portable equipment




Many changes happening to RY 2014, RY 2015, and potentially

RY 2016

Be aware of the changes to ensure smooth reporting in each of

the next three reporting years

Must have reporting procedures ready for 2015 and be ready to

implement new 2016 requirements

Summary



Thank You

And

Happy Reporting



Eric P. Anderson, PMP

EPA Systems, LLC

4201 W. Parmer Ln

Building B, Suite 280

[email protected]

512-821-1504

mailto:[email protected]

40 CFR Part 98 GHG Reporting for the Oil and Gas Industry...

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