Air Quality and Greenhouse Gas Issues Upstream and Mid ... · Air Quality and Greenhouse Gas Issues...

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

November 10, 2016

The business of sustainability

Agenda

ICR FrameworkPreparing for ICRPart 1 execution planPart 2 execution planQ&A Session

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ICR FrameworkDenise Grubert

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EPA’s Stated Goals of the ICRWhat does EPA want ? Methane emissions information

From ALL oil and gas industry existing sources (to some extent) About technologies available to reduce the methane emissions Costs to apply control technologies

Why? Base to write new regulations on existing sources (ESPS) and the next generation of NSPS OOOO

The ICR process is not optional under

Section 114 of the CAA

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How is the ICR Organized?

Underground NG Storage & LNG Storage & Import/Export

City Gate

Onshore Natural Gas Processing

Gathering Booster Stations & Gathering Pipelines

Onshore Oil & Natural Gas Production

In!

Onshore Natural Gas Transmission Compression

Part 2: Sample Facilities for all Sectors


City Gate


Gathering Booster Stations & gathering Pipelines



In! No exemptions

Part 1 and Part 2 requests will occur at the same time

5

Part 1: For All Upstream



Part 1: For All Upstream Underground NG Storage & LNG Storage & Import/Export

City Gate


Gathering Booster Stations & gathering Pipelines



In! No exemptions


Part 1 will be distributed to every onshore production operator in US• All wells (actively producing and temporarily shut-in) and

associated major equipment by well site• All associated central production facilities (as defined in the ICR)• EPA using Part 1 as census data - to extrapolate data from Part 2

to entire well population• 60 day response time

6


Part 1 for Upstream Production OperatorsApplicability: All known onshore production operators

All production well sites and associated central production surface sites operated, including those that receive a Part 2 request

What type of information is being requested? Wells at well surface sites (as defined in the ICR)

Major equipment

Linkage to central production sites (as defined in the ICR)

Basin and County Location of each Surface Site

Identification of NSPS OOOOa LDAR applicability

Lat/Longs of well sites

7




City Gate


Gathering Booster Stations


In!


Part 2: Randomly Selected for all Sectors


Part 2 will be distributed to a sample of facilities across different industry sectors

• Random sample by industry sector; well sites by GOR and production (stripper and non-stripper wells)

• EPA using Part 2 data to develop model plants to support existing source rulemaking

• 180 day response time

8


Part 2 for Upstream and Midstream Operators Applicability: Select upstream and midstream facilities

What type of information is being requested?

Inventory

Well Sites

Tanks/Separators

Pneumatics

AGRU

Dehys

Equipment and Component Counts

Compressors

Control Devices

Event-Based

Blowdowns

Liquids Unloading

Measurements/Testing

Flash Liberation Testing

Direct Measurements (if

available)

Cost Data

Control Costs

Operation and Maintenance Costs

Leak Survey Costs

9


Who will receive Part 2 ICR?

EPA will send Part 2 ICR to a selection of facilities based on the following sampling approach

Industry Sector

EPA's Estimated Count of Facilities

Target Number

Requests to be Sent

Percentage of

Population Sampled,

%Subtotal for Onshore petroleum and natural gas production facility

698,717 2,615 0.4%

Onshore petroleum and natural gas gathering and boosting facility

5,000 N/A 10%

Onshore natural gas processing plant (or facility)

668 272 41%

Onshore natural gas transmission compressor station

1,400 336 24%

Natural gas transmission pipeline facility

939 304 32%

Underground natural gas storage facility

418 224 54%

Liquefied natural gas (LNG) storage facility

100 100 100%

LNG import and export facility 11 11 100%TOTALS 707,336 4,505 1%

Onshore ProductionEPA will select US Well IDs based on GOR for Part 2.

Gathering and BoostingOperators must identify 10% of gathering and boosting compressor station facilities and gathering and boosting pipeline facilities (new definition) using a separate Excel workbook “Gathering and Boosting Tool”

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Details to pay attention to Definitions are specific to the ICR and do not align with other EPA programs

Gathering and booting was split into two separate categories: compressor stations and gathering pipelines

Delineation between facility boundaries in part 1 and Part2 (central production versus gathering and boosting)

EPA added gathering lines into the definition of well surface site when connecting to central production

Part 1 can be submitted electronically or by hard copy

Part 2 reported in e-GGRT with fixed structure

Consider submitting extension requests upon receipt

Data is in multiple systems of record – dealing with various stakeholders and data managers within your organization

Do not have to report any data parameter already reported under subpart W

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Timeline and Resource Hurdles

Resource Constraints

EPA finalized deadlines for the ICR:Part 1: 60 days from receiptPart 2: 180 days from receipt

Q1 Reporting Periods

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Preparing for ICRKevin Madry

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Understanding of Challenges

Inconsistent Data Sources

Certification

Time Crunch

14


ERM’s Data Management Solution

Collect Core Data

CB

I

Decisions

Data Sources

Counts

Calcs

Filters

Export to Workbooks

Operator

Production Site

Well Tank

Facility

Compressor

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Summary/Benefits

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Added Value■ Organized normalized data collection

■ Logical counts, calculations

■ More rigorous QA/QC

■ Documented process/details

■ Increased efficiency through multiple data paths/automated export

Future Data Reuse■ Facility-level regulatory cost assessments

■ Compliance planning and tracking

■ Compilation for other regulations


Part 1 Execution PlanLisa Campbell

20


Part 1 Execution - Example Schedule…

Activity Nov 14

Nov 21

Nov 28

Dec 5

Dec 12

Dec 19

Dec 26

Jan 2

Jan 9

Jan 16

Compliance Plan

Data Systems Mapping / Gaps

Well to Facility Mapping

Well to CentralProduction Mapping

Field Data Collection

Data Aggregation

QA/QC

Reporting

ICR Letters Received

Part 1 Deadline

Applies to all companies with active production wells

HolidaysThanksgiving

21

GHG Reporting


Suggested Program Management Approach

Develop a Compliance Plan Who will be involved – roles/responsibilities? What data is needed? Where is data located (systems of record)? How will data get

collected/aggregated/reviewed/reported? When – schedule to meet 30 day timeframe?

Organize the Team Leveraging company and 3rd party resources IT, EHS, operations/engineering, management

Data Systems Mapping Systems of Record where data elements reside

Now!

22


Part 1 – Well MappingWell and equipment mapping exercise: Associating wells and equipment with Well Surface Sites

(WSS)

Identifying plugged & abandoned wells at production well sites

Associating Central Production Surface Sites (CPSS) with wells/WSS

Do you need ‘boots on the ground’ to fill data gaps?

WSS and CPSS definitions are NOT aligned with Subpart W

Prod Well

P&A Well

WSS

CPSS

Prod Well

23


Key considerations for Part 1

60 days, including holidays!!!!!!

Time lost getting to appropriate contact?

Data housed in multiple systems of records

Data on Plugged & Abandoned wells at production well sites

Delineating between Gathering & Boosting and Central Production Surface Sites

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Part 2 Execution PlanAndy Woerner

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Part 2 for Upstream and Midstream Operators

Inventory

Well Sites

Tanks/Separators

Pneumatics

AGRU

Dehys


Compressors

Control Devices

Event-Based

Blowdowns

Liquids Unloading

Measurements/Testing

Flash Liberation Testing

Samples

Cost Data

Control Costs

Operation and Maintenance

Costs

Leak Survey Costs

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Example Schedule… Part 2

Activity Nov Dec Jan Feb Mar April May June

Compliance Plan

Project KO

Training

Field Data Collection

Sampling / Testing

Non‐Field Data Collection

Data Management, QA/QC

Sign‐off &Reporting

> 10 bbl/day

GHG Reporting

Pilot Location All Locations

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Provide Confidence to Your Management Ability to complete in tight timeframe Level of QA/QC

Well-Coordinated Approach Leveraging company and 3rd party resources

Develop a Compliance Plan / Road Map Clear understanding of required data Clarity on roles and responsibilities (SWIM lanes) Establish lines of communication

Now!

28



Kick-off Meeting(s) Key stakeholders within various business segments, facilities Confirm level of resource availability / commitment

Training for Field Data Collection Scope, Templates – equipment / component counts Recommend pilot / dry run(s)

Field Sampling Efforts Ensure Lab(s) lined up early Seek to complete any sampling as early as possible

Data Management Reach Agreement on Preferred Approach Database vs. Spreadsheets

Now -December

29


Suggested Program Management ApproachField and Non-field Data Collection / Generation Component Counts, Separator Sampling Cost Information Types of compressor seals, Verifying types of pneumatics Emission test data, blowdowns, liquids unloading Generation of Emission Estimates

QA/QC Start as early as possible, likely breaking up by data type Regular dialogue / engagement of agreed stakeholders

Status Tracking Regular (Weekly / Bi-weekly) status update calls Progress Tracker List of Open Issues

Then celebrate… or at least sleep!

December -April

January to

May

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Part 2 Road Map… Pneumatics Example

Inventory

Well Sites

Tanks/Separators

Pneumatics

AGRU

Dehys


Compressors

Control Devices

Confirm Presence of Air vs. NG Pneumatics All Air All done

For NG Pneumatics - Leverage Existing Data Sources Asset Inventory Tools (Maximo, etc.) Emission Inventories P&IDs (not expected to be adequate)

Leverage Facility Staff to Flush Out Inventories

3rd Party staff visits to facilities to complete inventories Leverage Regional Resources Potential combined visits with other activities?

Categorize Controller Types

31


The Road Ahead

Develop / Finalize Compliance Plan

Right-size plan - burden & available resources

Evaluate Overall Data Management Approach

Stay Active in the Trades

Data will still be collected… and eventually used

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Q&A Session

33


Contact Information

Denise GrubertRaleigh, NC919-855-2282 [email protected]

Kevin MadryDenver, CO 720-200-7168 [email protected]

Lisa CampbellRaleigh, NC919-855-2279 [email protected]

Andy WoernerPhiladelphia, [email protected]

Today’s Speakers:

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