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Colorado Regulation 7

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  1. Colorado Regulation 7 LDAR Monitoring Frequency and Cost Control

  2. Facebook status update: In NOLA! Why did I have that last Hurricane?

  3. Choose Your Own Adventure! • Beer: Colorado has more microbreweries per capita than any other state! • South Park: Is it Real? • Recreation: Snowpack was 31% higher than the 30-year average. • Oil and Gas: First-in-the-nation to limit methane emissions. • Football: Was that an Epic Meltdown or What? Can the Broncos fix their issues?

  4. 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

  5. Outline…. • Background • The Story • Methodology • Results • Costs • Discussion

  6. 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

  7. Skip Period Monitoring…. • Accepted work practice • LDAR • National Uniform Emission Standards • Refinery Consent Decrees

  8. DJ Basin Piceance

  9. The Story…… • Evaluate the leak frequencies at facilities under LDAR programs. • Explore the impact of the emission calculations and the absence of skip-period monitoring.

  10. Study Methodology… Inlet Compressor • 14 Natural Gas Processing Plants • Inlet Processing Units • NTM - Valves Slug Receiver Inlet Meter Glycol Dehydrator

  11. 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

  12. Results: Case Study 1 Number of Inspections Completed Number of Components Inspected Components Inspections Time Time

  13. Results: Case Study 1 Average Percent of New Leaks Found Number of New Leaks Found Percent (%) Leaks Time Time

  14. Results: Case Study 2 Number of Inspections Completed Number of New Leaks Found Leaks Inspections Time Time

  15. Results: Case Study 2 Average Percent of New leaks/Number of Inspections Percent (%) Time

  16. Results: Final Thoughts Point X (Initial Leak Frequency) Point F (Final Leak Frequency) Fraction Leaking Monitoring Cycle Figure 5-35, EPA-453/R-95-017

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

  18. Cost of Compliance…

  19. Discussion… • LDAR + good work practices = low leak frequency. • Low-leak frequency is sustainabile • Emission factors are overly conservative • No incentives for operators

  20. Jane Steere jsteere.@trihydro.com 307.745.7474 Meredith Knauf mknauf@trihydro.com 307.745.7474