Flare Gas Emission Regulations
40 CFR Part 98• Measure, Record and Report40 CFR Part 60 Subpart OOOO (a)• Referred to as Quad Oa• Includes “Reduced Emission Completions”
RECs also referred to as “Green Completions”• Effective Aug. 2nd 2016• Applies to wells brought into service after Sept. 18th 2015
Texas Statewide Rule 32• 45 day permits• Can be extended to 180 days max
Flare Gas Emission Regulations
40 CFR Part 60 Subpart OOOO (a)• (1) requiring that certain control devices or practices be
used to reduce methane and volatile organic compound (VOC) emissions from regulated equipment and during well completions, and
• (2) implementing leak detection and repair (LDAR) programs to prevent natural gas leaks at well sites and compressor stations.
• The rule only applies to well sites, compressor stations, natural gas processing plants, and certain equipment that is new or has been “modified” or “reconstructed” since Sept. 18, 2015.
Flare Gas Emission Regulations
40 CFR Part 60 Subpart OOOO (a)RECs or Green Completions• (1) requiring that certain control devices or practices be
used to reduce methane and volatile organic compound (VOC) emissions from regulated equipment and during well completions, and
• operators must route all salable gas from a separator to a flow line or collection system, re-injected it into the well or another well, use it as an onsite fuel source, or use it for “another useful purpose that a purchased fuel or raw material would serve.”
Flare Gas Emission Regulations
40 CFR Part 60 Subpart OOOO (a)• Cost of Regulations
Cost Proposed Rule
(millions)
Final Rule
(millions)
Capital Cost (2020) $170-$180 $250
Annualized Engineering Costs
$180-$200 $390
Estimated MethaneCaptured (2020)
16 (mcf)
By EPA’s Estimate : $40/mcf
Flare Gas Emission Regulations
Cost of Regulations
• EPA considers methane to be a far more potent GHG, in the preamble to Quad Oa they state methane has a 100-year global warming potential which is 28-36 times greater than CO2.
• EPA estimates that Quad Oawill reduce methane emissions by 6.9 million metric tons of CO2 in 2020.
Cost Proposed
Rule
(millions)
Final Rule
(millions)
Capital Cost (2020)
$170-$180 $250
Annualized Engineering Costs
$180-$200 $390
Estimated MethaneCaptured (2020)
16 (mcf)
By EPA’s Estimate : $40/mcf
Flare Gas Emission Regulations
Cost of Regulations
• EPA then used the Social Cost of Methane to determine that every ton of methane emissions that this rule prevents was worth $1,100 in present dollars.
• EPA estimates methane-related monetized climate benefits of the rule will be $360 million in 2020
Cost Proposed
Rule
(millions)
Final Rule
(millions)
Capital Cost (2020)
$170-$180 $250
Annualized Engineering Costs
$180-$200 $390
Estimated MethaneCaptured (2020)
16 (mcf)
By EPA’s Estimate : $40/mcf
Flare Gas Emission Regulations
Cost of Regulations
• Social Cost of Methane derived from Social Cost of Carbon
• Social Cost of Carbon working group has not endorsed social cost of methane
• Social Cost of Carbon has it’s own controversy• OMB recommends discount rate of
3% and 7%• 2.5%, 3% and 5% used by working
group• Carbon fertilization calculated to be
35%, yet working group used 8%
Cost Proposed
Rule
(millions)
Final Rule
(millions)
Capital Cost (2020)
$170-$180 $250
Annualized Engineering Costs
$180-$200 $390
Estimated MethaneCaptured (2020)
16 (mcf)
By EPA’s Estimate : $40/mcf
Flare Gas Emission Control / Produced Water
EvaporationFlare vs. Combustor
Patent Pending
Flares Combustors
Open Flame Enclosed Flame
Poor heat recovery Good heat recovery
Highly visible flame No visible flame
Visible flame leads to public perception issues
No visible flame reduces public perception issues
High noise level Lower noise level
Flare Gas Emission Control / Produced Water
Evaporation
• Flare Gas Emission Control– Wet Scrubber – Uses water to control acid gases,
NOx, SOx and particulate matter• Up to 98% effective
– Wet Scrubber Using Produced/Flowback Water• Testing in progress• Patent Pending
“another useful purpose that a purchased fuel or raw material would serve.”
Patent Pending
Flare Gas Emission Control / Produced Water
Evaporation
• Flare Gas Emission Control– Practical Applications• Emission Control (Stay Ahead of the Curve)
– Reduce NOx– Reduce SOx– Reduce acid gases– Reduce Particulate Matter
• Avoid cost of methane collection where not cost effective– Wells are too remote– Market price for gas is too low
Patent Pending
Flare Gas Emission Control / Produced Water
Evaporation
• Produced Water Evaporation– Practical Applications
• Management of Produced Water– Where disposal cost is high
» Remote wells– Where disposal capacity is an issue (induced seismicity)
» Oklahoma has shut down wells» Ohio has limited density of injection wells and require
seismic monitoring» Some Ohio wells have failed seismic monitoring on first
day of operation• Flowback Management
– More costly to dispose of» Disposal wells traditionally charge more for flowback
– More difficult to recycle» Residual frac additives, broken gels usually limit
recycling of flowback
Patent Pending
“another useful purpose that a purchased fuel or raw material would serve.”
Flare Gas Emission Control / Produced Water
Evaporation
• Gas Flaring and Flowback (Modified Flares)– Flaring is currently allowed during the
flowback period– While gas collection is being installed– Flowback is more expensive and difficult to
manage than produced water– Using Flowback as a scrubbing agent solves
two problems• Reduce Flare Emissions• Eliminates or significantly reduced Flowback
volumes
Patent Pending
Flare Gas Emission Control / Produced Water
EvaporationBasics:• Produced Water is used to
control emissions from flaring
• Produced water becomes a consumable resource
• Disposal of produced water or Flowback is eliminated
• Byproduct is evaporated solids and salts
Patent Pending
Flare Gas Emission Control / Produced Water
Evaporation Patent Pending
“another useful purpose that a purchased fuel or raw material would serve.”
Field Gas Combustor
Wet Scrubber usingProduced Water / Flowback
Screw Conveyor for solids/salts
Optional Reagent HopperFor Barium Stabilization
Solids for Disposal
Flare Gas Emission Control / Produced Water
Evaporation Patent Pending
“another useful purpose that a purchased fuel or raw material would serve.”
Flare Gas Options
• Flare Gas Emissions are already being reviewed
• Wet scrubbing is already widely used for emission control
• Eliminating Flowback, while controlling flare gas emissions is a win/win
• 0.4 mcf of gas for every bbl
Flare Gas Emission Control / Produced Water
Evaporation Patent Pending
“another useful purpose that a purchased fuel or raw material would serve.”
Produced Water Options
• Induced Seismicity has already created a produced water disposal under capacity
• In other areas, like the Marcellus reduced completions has reduced produced water reuse capacity
• In some areas transportation & disposal is already high
Flare Gas Emission Control / Produced Water
Evaporation Patent Pending
“another useful purpose that a purchased fuel or raw material would serve.”
Gas Collection Issues
• In remote locations gas collection may not be cost effective
• Low gas prices may not support gas collection and evaporation complies with REC or “Green Completions” requirements