proposed ghg emission standards for crude oil and natural
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Proposed GHG Emission Standards for Crude Oil and
Natural Gas Facilities
March 23, 2017
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∗ Background
∗ Proposed Regulation, with 15-Day Changes
∗ Environmental Analysis ∗ Implementation
∗ Staff’s Recommendation
Overview
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Background
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∗ Climate Change Scoping Plans identify oil & gas sector as large source of GHG emissions.
∗ Short-Lived Climate Pollutant (SLCP) Strategy includes a target of 40-45 percent reduction in methane from oil & gas sector as a whole by 2025.
∗ SB 4’s focus on well stimulation addressed, as is SB 887’s focus on underground storage monitoring.
∗ Over 5 million people in California live within one mile of at least one oil or gas well.
Policy Drivers
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California 2013 Methane Emission Sources (118 MMTCO2e)
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Agriculture 58%
Landfills 20%
Oil & Gas Extraction and
Storage 4%
Pipelines 9%
Industrial & Miscellaneous
5%
Wastewater 4%
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Other State and Local Regulations
∗ DOGGR Natural Gas Underground Storage air monitoring requirements transition to ARB.
∗ CPUC developing best practices per SB 1371 to be consistent with ARB’s regulation.
∗ Districts regulate oil & gas for VOC purposes.
∗ ARB’s proposed regulation covers leaking equipment not already covered by air district rules.
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Federal Actions on Oil & Gas
∗ ARB proposal covers new and existing sources, and is generally more stringent and broader than federal requirements.
∗ Worked to harmonize with federal regulations as much as possible.
∗ Some rules being challenged. We plan to closely monitor status of those programs and implications.
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Proposed Regulation with 15 Day Changes
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∗ Since August 2014, have had 5 workshops and dozens of meetings with working groups and stakeholders.
∗ July 2016: Proposed regulation presented to the Board with recommended 15-day changes.
∗ February 3, 2017: Released revised regulation for 15-day public comment.
∗ March 23, 2017: Presenting revised regulation for Board consideration of adoption.
Progress on Regulation
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∗ The proposed regulation addresses fugitive and vented emissions of methane from both new and existing oil and gas facilities.
∗ The covered facilities include: • Oil and Gas Production, Processing, and Storage • Gathering and Boosting Stations • Natural Gas Underground Storage • Compressor Stations
Applicability
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Proposed Regulation Standards
Separator and Tank Systems
∗ Applies to systems at all regulated facilities.
∗ Require flash testing to determine annual methane emissions.
∗ Require systems with annual emissions above 10 MT methane to install vapor collection.
∗ Exemptions for low throughput systems and small gauge tanks.
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Proposed Regulation Standards
Circulation Tanks
∗ Tanks used as part of a well stimulation treatment.
∗ Operators submit a Best Practices Management Plan, followed by a control equipment technical assessment.
∗ If technical assessment proves out, tanks controlled for emissions by January 1, 2020.
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Proposed Regulation Standards
Leak Detection & Repair (LDAR)
∗ Requires daily inspections and quarterly testing to check components for leaks.
∗ Builds on current requirements by some districts to control VOCs.
∗ Regulation would extend testing to methane at natural gas facilities.
∗ FSOR will clarify implementation; may also issue guidance.
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Proposed Regulation Standards
Underground Gas Storage
∗ Monitoring program designed for the early detection of leaks:
• Ambient air monitoring • Daily or continuous monitoring at
injection/withdrawal wells. • Incorporates SB 887 requirements.
∗ Operators submit monitoring plans to ARB for approval.
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Proposed Regulation Standards
Natural Gas Compressors
∗ Emission standards for reciprocating compressor rod packings and centrifugal compressor wet seals.
∗ Requires either (1) replacement of high-emitting rod packing or wet seal, or (2) collection of leaking gas.
∗ All compressors subject to LDAR.
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Pneumatic Devices & Pumps
∗ Continuous to no-bleed: • Air or electricity to operate; or, • Controlled with a vapor collection
system
Other Measuring and Reporting Requirements
Proposed Regulation Standards
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Proposed Implementation Dates
∗ January 1, 2018: • Flash testing • LDAR inspections • Natural gas storage monitoring plans • Registration and permitting
∗ January 1, 2019: • Vapor collection on separator & tank systems • Pneumatic devices and compressor seal change-outs • Circulation tank technology assessment
∗ January 1, 2020: • Circulation tank vapor collection, pending technology
assessment
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GHG Emission Reductions & Costs
∗ Overall estimated annualized cost, with natural gas savings, of $27,300,000
∗ Estimated continuing reductions of more than 1.4 million MT of CO2e per year, using a 20 year Global Warming Potential for methane.
∗ Estimated overall cost-effectiveness of $19 per MT of CO2e reduced.
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Emission Reduction Co-Benefits
∗ Over 3,600 TPY of VOC reductions statewide.
∗ Over 100 TPY of reductions statewide of Toxic Air Contaminants, such as Benzene, Toluene, Ethyl-Benzene, and Xylenes.
∗ Neutral statewide NOx impact.
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Environmental Analysis
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Environmental Analysis
∗ Draft Environmental Analysis (EA) 45-Day comment period June 3, 2016 – July 18, 2016.
∗ Final EA and written responses to comment on the Draft EA released on March 10, 2017.
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Implementation
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∗ Regulation allows both ARB and the districts to implement; district implementation is preferred.
∗ ARB is developing a registration program for equipment not covered by districts.
∗ Districts can charge fees and retain enforcement penalties.
∗ Working on additional resource options to aid with personnel and test equipment.
Implementation
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∗ ARB and districts developed a model Memorandum of Agreement (MOA) to specify roles and responsibilities.
• Enforcement coordination, and support information and data sharing
• MOAs may be tailored for specific district needs.
∗ Expect MOAs to be finalized this summer, prior to implementation of the regulation.
Implementation
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∗ Review data being reported under program.
∗ Update ARB Oil and Gas webpage throughout program implementation.
∗ Work with CAPCOA and stakeholders to develop implementation guidance.
∗ Monitor program implementation.
∗ Periodically update Board on status and propose adjustments as necessary.
Implementation
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Staff’s Recommendation
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∗ Adopt Board Resolution 17-10 to:
• Approve written responses to EA comments, certify Final EA, and make required CEQA findings.
• Adopt Final Regulation Order.
• Direct staff to continue working with districts to finalize MOAs.
Staff’s Recommendation
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