Post on 05-Jan-2016
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Colorado Regulation 7
LDAR Monitoring Frequency and Cost Control
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Choose Your Own Adventure!
• Beer: Colorado has more microbreweries per capita than any other state!
• South Park: Is it Real?
• Recreation: Snowpack was 31% higher than the 30-year average.
• Oil and Gas: First-in-the-nation to limit methane emissions.
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Colorado First State to Limit Methane
Pollution from Oil and Gas Wells
~Scientific American Colorado First State to Clamp Down
on Fracking Methane Pollution
~Bloomburg
Colorado First State to Clamp Down
on Fracking Methane Pollution
~Denver Post Colorado Becomes First State To Restrict Methane Emissions~NPR
Colorado seeks to regulate methane emissions~Washington Post
Outline….
• Background• The Story• Methodology• Results• Costs• Discussion
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The Background…
• Approved on February 23, 2014, effective on April 14, 2014.
• Applies from wellhead to the inlet of a gas processing plant
• Leak detection primarily targets piping, tanks, and compressors
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Skip Period Monitoring….
• Accepted work practice– LDAR– National Uniform
Emission Standards– Refinery Consent
Decrees
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DJ Basin Piceance
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1. Evaluate the leak frequencies at facilities under LDAR programs.
2. Explore the impact of the emission calculations and the absence of skip-period monitoring.
The Story……
Study Methodology…
• 14 Natural Gas Processing Plants
• Inlet Processing Units• NTM - Valves
10Glycol Dehydrator
Slug Receiver
Inlet Compressor
Inlet Meter
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CASE STUDY 1 – 8 Facilities with Initial LDAR Programs. Study Length: 1 year.
CASE STUDY 2 – 6 Facilities with Established LDAR Programs. Study Length: 3 years
Results: Case Study 1
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Number of Components Inspected
Time
Time
Number of Inspections Completed
Insp
ecti
ons
Com
pone
nts
Results: Case Study 1
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Time
Lea
ks
Number of New Leaks Found
Average Percent of New Leaks Found
Time
Per
cent
(%
)
Results: Case Study 2
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Time
Insp
ecti
ons
Number of Inspections Completed Number of New Leaks Found
Time
Lea
ks
Results: Case Study 2
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Time
Average Percent of New leaks/Number of Inspections
Per
cent
(%
)
Results: Final Thoughts
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Fra
ctio
n L
eaki
ng
Monitoring Cycle
Point X (Initial Leak Frequency)
Point F (Final Leak Frequency)
Figure 5-35, EPA-453/R-95-017
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“I am not one of those who in expressing opinions confine themselves to facts.” ~ Mark Twain
Cost of Compliance…
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Discussion…
• LDAR + good work practices = low leak frequency.
• Low-leak frequency is sustainabile
• Emission factors are overly conservative
• No incentives for operators
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Jane Steere
jsteere.@trihydro.com
307.745.7474
Meredith Knauf
mknauf@trihydro.com
307.745.7474
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