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Colorado Regulation 7

LDAR Monitoring Frequency and Cost Control

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Colorado First State to Limit Methane

Pollution from Oil and Gas Wells

~Scientific American Colorado First State to Clamp Down

on Fracking Methane Pollution

~Bloomburg

Colorado First State to Clamp Down

on Fracking Methane Pollution

~Denver Post Colorado Becomes First State To Restrict Methane Emissions~NPR

Colorado seeks to regulate methane emissions~Washington Post

Outline….

• Background• The Story• Methodology• Results• Costs• Discussion

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The Background…

• Approved on February 23, 2014, effective on April 14, 2014.

• Applies from wellhead to the inlet of a gas processing plant

• Leak detection primarily targets piping, tanks, and compressors

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Skip Period Monitoring….

• Accepted work practice– LDAR– National Uniform

Emission Standards– Refinery Consent

Decrees

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DJ Basin Piceance

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1. Evaluate the leak frequencies at facilities under LDAR programs.

2. Explore the impact of the emission calculations and the absence of skip-period monitoring.

The Story……

Study Methodology…

• 14 Natural Gas Processing Plants

• Inlet Processing Units• NTM - Valves

10Glycol Dehydrator

Slug Receiver

Inlet Compressor

Inlet Meter

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CASE STUDY 1 – 8 Facilities with Initial LDAR Programs. Study Length: 1 year.

CASE STUDY 2 – 6 Facilities with Established LDAR Programs. Study Length: 3 years

Results: Case Study 1

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Number of Components Inspected

Time

Time

Number of Inspections Completed

Insp

ecti

ons

Com

pone

nts

Results: Case Study 1

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Time

Lea

ks

Number of New Leaks Found

Average Percent of New Leaks Found

Time

Per

cent

(%

)

Results: Case Study 2

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Time

Insp

ecti

ons

Number of Inspections Completed Number of New Leaks Found

Time

Lea

ks

Results: Case Study 2

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Time

Average Percent of New leaks/Number of Inspections

Per

cent

(%

)

Results: Final Thoughts

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Fra

ctio

n L

eaki

ng

Monitoring Cycle

Point X (Initial Leak Frequency)

Point F (Final Leak Frequency)

Figure 5-35, EPA-453/R-95-017

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“I am not one of those who in expressing opinions confine themselves to facts.” ~ Mark Twain

Cost of Compliance…

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Discussion…

• LDAR + good work practices = low leak frequency.

• Low-leak frequency is sustainabile

• Emission factors are overly conservative

• No incentives for operators

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Jane Steere

jsteere.@trihydro.com

307.745.7474

Meredith Knauf

mknauf@trihydro.com

307.745.7474

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