The Environmental Protection Agency (EPA) recently announced its proposal to update and revise the Greenhouse Gas Reporting Rule as covered in 40 CFR Part 98. The rule effectively sets the requirements for reporting methane, carbon dioxide, and nitrous oxide emissions in the oil and gas production, processing, and transmission industry sector. The EPA’s most recent proposed change to it would significantly expand the program with a direct effect on oil and gas producers.
Proposed updates to the program fall into four categories:
- Expanded reporting to include new emission sources
- The addition of emissions calculation methodologies to incorporate additional empirical data and improve the accuracy of reported emission data
- Refinement of existing emissions calculation methodologies to reflect an improved understanding of emissions or to incorporate more recent research on GHG emissions
- In some cases, removal of calculation methodologies where more accurate calculation methodologies are available
The “new sources” EPA proposes adding to the list of required emission reporting will impact upstream oil and gas operators. The new sources include:
- Other “large release events”
- Nitrogen rejection units
- Produced water storage tanks
- Mud degassing
- Crankcase venting & combustion slip from reciprocating and gas turbine compressors
Large Release Events
Large release events are hydrocarbon gas releases that occur outside of normal operations and include both unplanned and planned events. Examples of unplanned events would include situations such as well blowouts, well releases, and emissions from equipment failure, fire, or explosion.
EPA also wants to obtain emissions data on releases from planned activities, such as wellsite maintenance and repair. In the proposal, EPA wrote that “emptying, degassing, and cleaning a tank is an example of a maintenance activity for which emissions would need to be reported” if the release is considered a “large release.”
Two thresholds are proposed for classification of a “large release.” An event is considered “large” if the total volume released exceeds 250 metric tonnes of carbon dioxide equivalent (CO2e), an approximate gas volume of 500 MCF according to the Agency. An additional instantaneous threshold of 100 kilograms CO2e per hour would trigger a reportable event.
EPA is requesting comments on different threshold values as well as their method of determining the length of a large release as well as the figure for combustion efficiency (92%) if the release involved an explosion or fire.
Produced Water Tanks
Produced water tanks are another proposed new source of emissions to be reported. Given the number of water storage tanks and facilities, this addition has the potential to significantly increase the reporting workload of upstream producers and water processors and will likely present some significant challenges in reporting.
Methane emissions from water tanks are to be reported using either software using the Peng-Robinson equation of state, or emission factors developed in a 1996 GRI/EPA study and further reported in API’s 2021 Compendium of GHG Emission Methodologies.
The E&P Tanks category is specifically called out as not accurate for estimating flashing in water tanks. In addition to estimated emissions, the proposal requires operators to report:
- Total annual produced water volumes by pressure ranges
- Estimated fraction of the emissions from produced water tanks that is controlled by vapor recovery and/or flares (flared emissions are reported in a separate section)
- Counts of controlled and uncontrolled water tanks
- Annual methane emissions vented directly to the atmosphere from produced water tanks
EcoVapor Emissions Control and Reduction Technology
Increasingly, oil and gas operators have turned to innovation and technology for cost-effective compliance and improving the sustainability and profitability of their operations. EcoVapor, a DNOW company, has been helping oil and gas operators reduce tank flaring and well site emissions since 2010.
Our proven solutions include:
ZerO2™ Vapor Recovery System. ZerO2 technology enables you to directly capture 100% of your BTU-rich vapor from storage tanks for crude oil and produced water, eliminating the need for routine flaring while generating more revenue. With no moving parts, ZerO2 units are typically one of the most reliable pieces of equipment on the well site.
Tank Commander™ Vapor Management System. The Tank Commander™ Vapor Management System (VMS) provides you with the ability to directly capture 100% of your tank vapor while minimizing tank venting emissions and maximizing the value of your oil and gas producing assets.
MobileZerO™ Trailer Unit. Put gas treating capacity when and where you need it with our MobileZerO trailer-mounted gas treating solution. MobileZerO helps you eliminate flaring and emissions associated with routine oilfield operations, such as tank degassing and cleaning.
Emissions Scout™ Site Assessment Unit. If you don’t measure it, you can’t manage it. Emissions Scout provides cost-effective, reliable, hard data on tank vapor gas quality, tank pressures and flare line volumes for analyzing your emissions performance and preparing the best approach for resolving any emissions issues from your tank batteries.
About EcoVapor
EcoVapor, a DNOW company, provides gas treating solutions to both geologic and biogas production problems. Our fleet of proprietary ZerO2 oxygen removal (deoxo) units has grown to a fleet of nearly 300 since 2010, operating reliably for leading producers in all major U.S. basins. ZerO2 technology helps Oil & Gas and biogas producers convert waste gas streams into revenue by treating gas to meet pipeline specifications so it can be sold instead of vented or flared, generating incremental value while reducing emissions and improving environmental performance.
EcoVapor is headquartered in Denver, Colorado and has field locations in Greeley, Colorado and Midland, Texas.
Contact
EcoVapor Recovery Systems (a DNOW Company)
Email: ecovapor.info@dnow.com
Phone: 844-NOFLARE (844-663-5273)
Sales: Joe Hedges (281-615-2072)