ARB GHG Oil & Gas Regulation Santa Barbara County APCD November 7 – Santa Maria November 14 – Santa Barbara (revised on 11/21/17)
Today’s Presentation • Purpose of the ARB Regulation • Who is Impacted? • Requirements • Rule 331 LDAR Exemptions • Implementation: MOA, Permits, Fees, Enforcement • Key Deadlines • Webpage & Resources
Purpose of the ARB Regulation • AB 32. California Global Warming Solutions Act. • Purpose is to reduce methane (CH 4 ) emissions. • Short-Lived Climate Pollutant (SLCP) Strategy target to reduce methane emissions from the oil & gas sector by 40-45 percent as a whole by 2025. • SB 887. Natural gas underground gas storage. • SB 4. Oil & gas well stimulation. • ARB’s regulation covers leaking equipment from compressor seals/rod packing to piping components such as valve and flanges.
Who is impacted? • Facilities that are impacted: • Oil and Gas Production, Processing, and Storage • Gas Processing Plants • Natural Gas Underground Storage Fields • NG Gathering and Boosting Stations • NG Transmission Compressor Stations • Crude Oil Pipeline Pump Stations • Facilities that are not impacted: • Utility Odorant & Metering Stations • Oil & Gas Platforms on the Outer Continental Shelf
Requirements • Separator and Tank Systems • Circulation Tanks for Well Stimulation Treatments • Natural Gas Compressors • Natural Gas Powered Pneumatic Devices and Pumps • Liquids Unloading of Natural Gas Wells • Well Casing Vents • Natural Gas Underground Storage Facilities • Leak Detection and Repair (LDAR), including Critical Components • Vapor Collection Systems and Vapor Control Devices • Recordkeeping and Reporting
Separator and Tank Systems • Definition: means the first separator in a crude oil or natural gas production system and any tank or sump connected directly to the first separator. • Includes upstream gauge tanks. • Applies to uncontrolled systems. • Exempted if already connected to a permitted Vapor Collection System (VCS). • Flash testing required to determine methane emissions. • VCS required if the annual emissions are above 10 metric tons methane. • Exemptions for low throughput systems and small gauge tanks.
Circulation Tanks for Well Stimulation Treatments • Best Practices Management Plan required • Inspection practices to minimize emissions from circulation tanks. • Practices to minimize venting of emissions from circulation tanks. • Practices to minimize the duration of liquid circulation. • Alternative practices to control vented and fugitive emissions. • Requires a technology assessment by Jan. 1, 2019. • Use of a VCS with 95% capture and control. • Allows for pooled testing amongst operators. • ARB will evaluate results of testing. • ARB will determine if VCS controls are required for these operations by July 1, 2019.
Natural Gas Compressors • Reciprocating Natural Gas Compressors • 200 hour/year exemption • LDAR required • Seal/Rod Packing Standards • Production: Install VCS or meet LDAR limits. • • Processing/Transmission/Storage: Install VCS or Annually measure leak rates and meet limits • • In compliance if already connected to permitted VCS • Centrifugal Natural Gas Compressors • 200 hour/year exemption • LDAR required • Install VCS or Annually measure leak rates and meet limits • In compliance if already connected to permitted VCS • Vapor Recovery Compressors. Typically are sliding vane (exempted) or reciprocating (subject to regulation). Other types…
Natural Gas Powered Pneumatic Devices and Pumps • A pneumatic pump is not a pneumatic device. • Bifurcated b/n continuous bleed and intermittent bleed • Standards for devices and pumps • Pneumatic devices installed prior to 2016 • Cease venting to atmosphere by January 1, 2019, or • Annually measure leak rates and meet limits • LDAR. • Intermittent bleed devices: January 1, 2018 • All others: January 1, 2019 • All NG pneumatic pumps phased out by January 1, 2019
Liquids Unloading of Natural Gas Wells • Natural gas wells do not include wells that produce crude oil emulsion. • Three options to comply: • Connect to VCS • Measure volume of gas vented by direct method • Calculate the amount of gas vented
Well Casing Vents • Requires annual direct measurement of NG from well casing vents open to the atmosphere. • District Rule 325 ( Crude Oil Production and Separation ): • Prohibits venting of NG from casing vents, whether opened continuously or intermittently. • Does not apply to wells that are undergoing routine maintenance.
Leak Detection and Repair LDAR • How are facilities subject to local LDAR rules handled? • Whose LDAR rule applies when NG Compressor and NG Pneumatics sections cite the ARB LDAR requirements? • Do facilities that are exempt from Rule 331 have to submit an Inspection & Maintenance Plan? • What happens to components exempted under Section B of Rule 331? Produced water lines? Utility natural gas lines? • Can I retract my prior Rule 331 exemptions? How and when? • Which Rule 331 exemptions should I retract to avoid having to implement two LDAR programs? • B.2.a – Natural Gas (partial request) • B.3.b – Process fluids < 10 ROC by wt. (partial request) • B.3.c – Totally contained or enclosed • B.3.e – NG Pneumatic control valves
Rule 331 LDAR Exemptions
Critical Components • District retains critical component determinations for components subject to local LDAR rule. • This applies to prior as well as future determinations. • All critical components must be listed in the District approved I&M Plan for the facility/source. • ARB makes critical component determinations for components subject to the ARB regulation (unless otherwise noted in the ARB/District MOA)
Vapor Collection Systems and Vapor Control Devices • VCS systems servicing Separator and Tank Systems that are permitted as of January 1, 2018 are exempt. • Section (d) Low NOx requirements do not apply to: • NG compressor vents and/or NG pneumatics that are currently connected to a VCS. • Replacement separators, tanks, compressors that are currently connected to a VCS. • New devices that are subject to NSR and will be connected to a VCS. • Section (d) Low NOx requirements do apply when: • The operator needs to install a flare in order to comply with the regulation’s VCS requirements. • Operators of an existing facility already with a flare are required to control additional vapors in order to comply with the regulation .
Recordkeeping and Reporting • Records are required for equipment/components subject to the regulation. • Recordkeeping/Reporting required for: • Production data, reagrdless if separator/tank connected to VCS. • LDAR records for components subject to local rule (per local rule). • Recordkeeping/Reporting is required for: • Flash testing data. • Circulation tank BPM Plan. • LDAR records for components not subject to local rule. • NG compressor emission flow rate measurements/other. • NG pneumatic emission flow rate measurements. • Liquids unloading from NG well information. • Well casing emission flow rate data. • All Underground NG Storage facility required data. • Initial Compliance Status Reports due January 1, 2018, the annually. • ARB regulation reports due July 1 to the District, then... • District will align reporting to match existing permits at renewal.
Implementation • District/ARB Memorandum of Agreement (in process). • District will implement and enforce the ARB regulation. • Exceptions : Circulation tank study, Monitoring Plan approval for NG Underground Storage, and Critical Components. • No Registration program. Existing permits already list the equipment subject to the regulation. • Initial January 1, 2018 report for facility compliance per Section 95674(b)(2)(A). GHG Compliance Status Checklist Long/Short Form. • Permit renewal process will incorporate terms of regulation. • Permits are required for modifications or new controls. • No new fees. Existing fee schedule works. • Cost reimbursement provisions will be set up for implementation of NG Underground Storage requirements. • On case-by-case basis, cost reimbursement to be used for facilities subject to ARB regulation LDAR requirements.
Key Deadlines • Now: Revise your District I&M Plan (retract R331 exemptions). • Now: Complete a GHG Compliance Status Checklist for each facility. Use either the Long/Short form. Submit to District. • January 1, 2018: • Revise local I&M Plans (optional) • Initial Section 95674(b)(2)(A) reports (Long/Short Form). • Comply with LDAR requirements (Table 1/2 standards). • Flash testing results due. • Obtain Critical Component pre-approvals. • Circulation tank Best Practices Management Plan in place. • Measure seal/packing flow rates. ( annual requirement) • Submit Monitoring Plan for NG Underground Storage sites. • Measure gas volumes: open well casing vents/NG well unloading.
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