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Flowback Emissions and Regulations


Phil Norwood Lisa Campbell

December 3 – 4,. 2013 Dallas, Texas


Outline

Completions Flowback Emissions Regulations

Aerial photo of a gas well site. © iStockphoto / Edward Todd.


What is a Completion?

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To perform activities in the final stages of well construction to prepare a well for production. The well is completed once zones of interest have been identified.

Source: Schlumberger Oil Field Glossary - http://www.glossary.oilfield.slb.com/

http://www.glossary.oilfield.slb.com/en/Terms/p/production.aspx



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A generic term used to describe the assembly of downhole tubulars and equipment required to enable safe and efficient production from an oil or gas well. The point at which the completion process begins may depend on the type and design of well. However, there are many options applied or actions performed during the construction phase of a well that have significant impact on the productivity of the well.


http://www.glossary.oilfield.slb.com/en/Terms/t/tubulars.aspx

http://www.glossary.oilfield.slb.com/en/Terms/p/production.aspx

http://www.glossary.oilfield.slb.com/en/Terms/g/gas_well.aspx



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Emissions During a Completion

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Emissions from Completions Grouped into Three Categories: ■ Gas Well Completions without Hydraulic Fracturing

■ Gas Well Completions with Hydraulic Fracturing

■ Oil Well Completion Venting


Completions without Hydraulic Fracturing

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733 scf methane/completion (assuming 98% control from flaring)

Methane Emissions from the Natural Gas Industry. EPA/GRI (1996)

http://www.google.com/url?sa=i&rct=j&q=&esrc=s&frm=1&source=images&cd=&cad=rja&docid=Coio9VQf1okh6M&tbnid=0nOSMNLBQTPSsM:&ved=0CAUQjRw&url=http://www.pbs.org/newshour/multimedia/campaignposters/10.html&ei=cMdWUqPXCdfe4APn24Bo&bvm=bv.53760139,d.dmg&psig=AFQjCNGbbBJO5mMtNt2yDxiYNtGLa2LUng&ust=1381505177303862

http://www.google.com/url?sa=i&rct=j&q=&esrc=s&frm=1&source=images&cd=&cad=rja&docid=_dCq5Q4my6STtM&tbnid=_IIJi4Qp14qnqM:&ved=0CAUQjRw&url=http://www.ecu.edu/renci/StormsToLife/Fran/maps.html&ei=usdWUq3aG9XJ4APB9oDIAw&bvm=bv.53760139,d.dmg&psig=AFQjCNHMBSPYIeGyX-CJmxiB2AjVlACy0w&ust=1381505299372785

http://www.google.com/url?sa=i&rct=j&q=&esrc=s&frm=1&source=images&cd=&cad=rja&docid=UebIi4pQs_ehyM&tbnid=UNr7-xkslPMn_M:&ved=0CAUQjRw&url=http://bleacherreport.com/articles/811769-michael-jordans-bulls-vs-magic-johnsons-lakers-which-dynasty-was-greater&ei=sshWUsbzKdPI4AOy54CoCA&bvm=bv.53760139,d.dmg&psig=AFQjCNFr43vxvsbB9PzB6WwHfn3E6dApSA&ust=1381505527668709

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Completions with Hydraulic Fracturing

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Completion Definition

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40 CFR 60, subpart OOOO

Well completion means the process that allows for the flowback of petroleum or natural gas from newly drilled wells to expel drilling and reservoir fluids and tests the reservoir flow characteristics, which may vent produced hydrocarbons to the atmosphere via an open pit or tank.


What is Flowback?

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Flowback: The process of allowing fluids to flow from the well following a treatment, either in preparation for a subsequent phase of treatment or in preparation for cleanup and returning the well to production.


http://www.glossary.oilfield.slb.com/en/Terms/c/cleanup.aspx


What is Flowback?

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The flowback period begins when material introduced into the well during the treatment returns to the surface immediately following hydraulic fracturing or refracturing. NSPS Subpart OOOO

The flowback period ends with either well shut in or when the well is producing continuously to the flow line or to a storage vessel for collection, whichever occurs first. NSPS Subpart OOOO

http://www.google.com/url?sa=i&rct=j&q=&esrc=s&frm=1&source=images&cd=&cad=rja&docid=tDrWvv5qDwKS7M&tbnid=CXrOUwmRb-CgWM:&ved=0CAUQjRw&url=http://www.nutri-tech.com.au/blog/2008/09/beating-the-chloroplast-count/&ei=ZT5XUv-WDNPE4APfhYHwDQ&bvm=bv.53899372,d.dmg&psig=AFQjCNHg7sXCNiaS0OeS6j60UErB7hRcGA&ust=1381535710652556

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Flowback Emissions

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Source: USEPA - http://www.epa.gov/gasstar/methaneemissions/onshore_petrol_gas_prod.html


Flowback Emissions

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Flowback Emissions

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Subpart W Background Document ■ 6,000 Mcf/completion

■ Natural Gas STAR presentation reported 45 Bcf emissions in 2002 from all completions ■ Six steps of assumptions using number and type of wells completed

■ 10,000 Mcf/completion ■ Natural Gas STAR partner reported average volume of recovered methane per well ■ Assumed 90% capture

■ 700 Mcf/completion ■ Vendor/service provider of REC provided recovered gas for 3 completions ■ Assumed 90% capture

■ 20,000 Mcf/completion ■ Average flowback reported by a Natural Gas START partner rounded to nearest 10,000 Mcf

Average of these four values = 9,175 Mcf/completion

Also used for National Inventory & NSPS Subpart OOOO Background


Flowback Emissions – Natural Gas STAR

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Estimated Well Completion Emissions (Mcf

gas/completion)* Company Year of Presentation

(Reference #)

24,400 Williams 2007 (1)

3,700 BP 2004 (2) 700 Weatherford

13,200 Devon 4,900 Anadarko 2008 (3)

9,000 Anadarko 2010 (3)

* Values calculated from information provided in Natural Gas STAR presentations. Where the reported value was gas recovered, an assumption was made that the gas recovered represented 90% of the total emissions from the completion.


Flowback Emissions – Other Sources Cited

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Reference (#) Completion Emissions Factor "Green Completions"

Fact Sheet (5) 3,000 Mcf NG/completion

ENVIRON (6) 1,000 – 5,000 Mcf NG/well Fernandez (7) 7,000 Mcf NG/completion Eckhardt (8) 6,800 Mcf methane/ completion

Green Completions. Lessons Learned (9)

370 Mcf methane/ completion


Flowback Emissions – Other Sources Cited

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Natural Gas STAR Reference

#

Natural Gas Star Presentation

Armendariz (2009) Emissions from Natural Gas Production

in the Barnett Shale

Howarth (2010). Methane and the greenhouse-gas

footprint of natural gas from shale formations

1 24,400 Mcf NG/ completion

24,000 Mcf NG/completion






9

3,700 700

13,200 Mcf Ng/completion



Flowback Emissions

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0

5,000

10,000

15,000

20,000

25,000

30,000

Nat

ural

Gas

Em

issi

ons

(Msf

/com

plet

ion)


Flowback Emissions

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Summary ■Reasonable to expect large variations due to

many factors including gas and liquid composition and reservoir characteristics

■“Data” very limited ■Poorly documented


Flowback Emissions

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Measurements of methane emissions at natural gas production sites in the United States (2013) ■ Direct measurements at 190 onshore natural gas sites

■ 27 well completions measured

■ Average uncontrolled methane emission rate was 20% lower than level used for national inventory (based on 9,175 Mscf/event)

■ More control in place than assumed in national inventory


Controls

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GREEN COMPLETION PRACTICES shall mean those practices intended to reduce emissions of salable gas and condensate vapors during cleanout and flowback operations prior to the well being placed on production.

Code of Colorado Regulations 2 CCR 404-1, 10 Series Definitions

Ohio EPA File Photo

Temporary, Mobile Surface Facilities, Source: BP

Completion combustion device means any ignition device, installed horizontally or vertically, used in exploration and production operations to combust otherwise vented emissions from completions. NSPS Subpart OOOO

Reduced emissions completion means a well completion following fracturing or refracturing where gas flowback that is otherwise vented is captured, cleaned, and routed to the flow line or collection system, re-injected into the well or another well, used as an on-site fuel source, or used for other useful purpose that a purchased fuel or raw material would serve, with no direct release to the atmosphere. NSPS Subpart OOOO


Regulations

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Green completion practices are required on oil and gas wells where reservoir pressure, formation productivity, and wellbore conditions are likely to enable the well to be capable of naturally flowing hydrocarbon gas in flammable or greater concentrations at a stabilized rate in excess of five hundred (500) MCFD to the surface against an induced surface backpressure of five hundred (500) psig or sales line pressure, whichever is greater. Green completion practices are not required for exploratory wells, where the wells are not sufficiently proximate to sales lines, or where green completion practices are otherwise not technically and economically feasible.

http://www.google.com/url?sa=i&rct=j&q=&esrc=s&frm=1&source=images&cd=&cad=rja&docid=NdYNlbKEtyY84M&tbnid=M0wyD2-BuIHXQM:&ved=0CAUQjRw&url=http://www.mobileedproductions.com/school-assembly-programs/states-that-we-visit/colorado-school-assemblies-13-14/&ei=2mxYUsb3I7az4APv_YCgDw&bvm=bv.53899372,d.dmg&psig=AFQjCNGntDApUXCyoY8g-BwqH3KtN3T-gg&ust=1381612984482175


Regulations

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Emissions of volatile organic compounds (VOC) and hazardous air pollutants (HAP) associated with the flaring and venting of hydrocarbon fluids (liquids and gas) associated with well completion and re-completion activities shall be eliminated to the extent practicable by routing the recovered liquids into storage tanks and routing the recovered gas into a gas sales line or collection system.


NSPS Subpart OOOO

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Affected Facility Each gas well

Revised definition for gas well: “onshore well drilled principally for production of natural gas”

Preamble Language: “… four formation types generally accepted

as gas-producing formations: (1) High-permeability gas, (2) shale gas, (3) other tight reservoir rock or (4) coal seam.”

Low-pressure well - formula provided in definition: function [(vertical depth, reservoir pressure) relative to sales line

pressure] Rule also defines wildcat and delineation well types


NSPS Subpart OOOO

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Control Requirements • If emissions cannot be directed to gathering line they must

be captured and vented to a completion combustion device with reliable/continuous ignition source (exclusions for fire hazard, negative environmental impacts)

• “General duty” to maximize recovery & minimize releases • Includes “Wildcat”, “delineation”, and “low pressure” gas

wells

Key Compliance Provisions • Email notification > 2 days prior to commencement of well

completion (notification to local authority satisfies requirement)

• Keep daily completion logs • Annual reporting - all the records required for completions

and deviations (location, duration of flows, reasons for venting, exemption claims)

Affected Facility

Each gas well

Applicability Criteria

All hydraulically fractured well completions and workovers

Phase I – Applies to Gas Wells Completed Until December 31, 2014


NSPS Subpart OOOO

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Control Requirements • Recovered liquids: route to storage vessels or re-inject • Recovered gas: route into a gas gathering line or collection

system, re-inject, or use for fuel / useful purpose • All salable quality gas: route to gas gathering line as soon as

practicable • If emissions cannot be directed to flow line, capture and direct

to completion combustion device with reliable continuous ignition source

• “General duty” to maximize recovery & minimize releases • “Wildcat”, “delineation”, and “low pressure” gas wells – capture

or route to combustion device

Key Compliance Provisions • Email notification > 2 days prior to commencement of well

completion (notification to local authority satisfies requirement) • Keep daily completion logs • Annual Reporting • Photos of recovery/control equipment

Affected Facility Each gas well

Applicability Criteria All hydraulically fractured well completions and workovers

Phase II – Applies to Gas Wells Completed on January 1, 2015 or after


NSPS Subpart OOOO

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Beginning January 1, 2015 NSPS Subpart OOOO requires:

For the duration of flowback, route the recovered liquids into one or more storage vessels or re-inject the recovered liquids into the well or another well, and route the recovered gas into a gas flow line or collection system, re-inject the recovered gas into the well or another well, use the recovered gas as an on-site fuel source, or use the recovered gas for another useful purpose that a purchased fuel or raw material would serve, with no direct release to the atmosphere.


Duration of Flowback?

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Source: Measurements of Methane Emissions at Natural Gas Production Sites in the United States - Supporting Information, Center for Energy and Environmental Resources, University of Texas at Austin

The flowback period begins when material introduced into the well during the treatment returns to the surface immediately following hydraulic fracturing or refracturing.

http://www.google.com/url?sa=i&rct=j&q=&esrc=s&frm=1&source=images&cd=&cad=rja&docid=PoW9qWLV54MHeM&tbnid=vapyJgVX55YsTM:&ved=0CAUQjRw&url=http://onpoint.wbur.org/2012/05/02/edvard-munchs-the-scream-up-for-auction&ei=13RYUtutOJPl4AOgm4HIBw&bvm=bv.53899372,d.dmg&psig=AFQjCNESi4XSjQh3LkBW77vR7-IdY3bHKQ&ust=1381615171465721



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Excerpts from 9/28/13 EPA Letter to API

"flowback emissions," . . . refers to the recovered gas and vapor after separation that cannot be directed to the flow line.

the initial gas and vapor are not "flowback emissions,"



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Source: Measurements of Methane Emissions at Natural Gas Production Sites in the United States - Supporting Information, Center for Energy and Environmental Resources, University of Texas at Austin

http://www.google.com/url?sa=i&source=images&cd=&cad=rja&docid=Bd7fLRdGD_HDRM&tbnid=cSSK6rD4-JqyrM:&ved=0CAgQjRwwAA&url=http://www.rpersen.no/norwegian-publisher-drops-drm-on-ebooks.html&ei=WXVYUpzXJaH_4AOk8IGADw&psig=AFQjCNGQ6_V4Jqt8lpU6pcgoCA-ThDqaAw&ust=1381615321659878



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First Date of Production - The date permanent production equipment is in place and product is consistently flowing to sales lines, gathering lines or storage tanks. Production occurring during well completion activities which is routed to temporary production equipment is considered to occur prior to the First Date of Production.

Source: OIL AND GAS PRODUCTION FACILITIES, CHAPTER 6, SECTION 2 , PERMITTING GUIDANCE WYOMING DEPARTMENT OF ENVIRONMENTAL QUALITY AIR QUALITY DIVISION

NSPS Subpart OOOO

The flowback period ends with either well shut in or when the well is producing continuously to the flow line or to a storage vessel.



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Beginning January 1, 2015 NSPS Subpart OOOO requires:

For the duration of flowback, route the recovered liquids into one or more storage vessels or re-inject the recovered liquids into the well or another well, and route the recovered gas into a gas flow line or collection system, re-inject the recovered gas into the well or another well, use the recovered gas as an on-site fuel source, or use the recovered gas for another useful purpose that a purchased fuel or raw material would serve, with no direct release to the atmosphere.

Storage vessel excludes temporary vessels.



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Flowback ends when producing to storage vessel

During flowback you must produce to a storage vessel

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NSPS Subpart OOOO - Impacts

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Type of Pollutant

Gas Well Fracked Completion Emission Reductions

(tons/yr) Methane 1,400,000

VOC 200,000 HAP 15,000

Oil and Natural Gas Sector: Standards of Performance for Crude Oil and Natural Gas Production, Transmission, and Distribution. Background Technical Support Document for Proposed Standards. EPA-453/R-11-002. July 2011.


Flowback Emissions - GHGRP Subpart W

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Requires reporting of emissions from Gas well venting during well workovers with hydraulic fracturing

Many Reporters Used Best Available Monitoring Methods for 2011 and 2012 reporting

Most Reporters Will Have Full Compliance for 2013 and Beyond


Flowback Emissions – GHGRP Subpart W

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Flowback for every well measured OR Representative flowback measured or calculated:

• One for less than or equal to 25 completions • Two for 26 to 50 completions • Three for 51 to 100 completions • Four for 101 to 250 completions • Five for greater than 250 completions

For Each “Bucket”

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Flowback Emissions – The Future

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Better emission estimates More regulation and control Lower emissions More refined life cycle analyses


References

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Number Reference

1 Reducing Methane Emissions During Completion Operations. 2007 Natural Gas STAR Production Technology Transfer Workshop. Glenwood Springs, CO. September 11, 2007.

2

Green Completions. Lessons Learned from Natural Gas STAR. Producers Technology Workshop. ExxonMobil Production Company, American Petroleum Institute, and EPA’s Natural Gas STAR program. September 21, 2004.

3 Reduced Emissions Completions in DJ Basin and Natural Buttes. Producers Technology Transfer Workshop. May 1, 2008. Rock Springs, WY.

4 Emission reduction strategies in the greater natural buttes. Anadarko Petroleum Corporation. EPA Gas STAR, Producers Technology Transfer Workshop Vernal, Utah, 23 March 2010.

5 "Green Completions." PRO Fact Sheet No. 703. EPA Natural Gas Star, Partner Reported Opportunities for Reducing Methane Emissions. September 2004.


References

40

Number Reference

6 ENVIRON International Corporation, "An Emission Inventory of Nonpoint Oil and Gas Emissions Sources in the Western Region," 15th Annual Emissions Inventory Conference, New Orleans, LA. May 2006.

7 Fernandez R. et al, "Cost-Effective Methane Emissions Reductions for Small and Midsize Natural Gas Producers." Journal of Petroleum Technology, June 2005.

8 Eckhardt M, Knowles B, Maker E, Stork P (2009) IHS U.S. Industry Highlights. (IHS) Houston, TX, Feb–Mar 2009

9

Green Completions. Lessons Learned from Natural Gas STAR. Producers Technology Workshop. ExxonMobil Production Company, American Petroleum Institute, and EPA’s Natural Gas STAR program. September 21, 2004.


Contact Information

Phil Norwood 919 855 2281 [email protected]

Lisa Campbell 919 855 2279 [email protected]

mailto:[email protected]

mailto:[email protected]

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