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Breaking the Gridlock with Smart Regulations
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SMART REGULATIONS Balancing the economic, environmental, and social impacts of the regulated activity
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SMART REGULATIONS = EFFECTIVE RISK MANAGEMENT
Three Steps to Effective Risk Management 1 3 2 IDENTIFY the risks 1 Implement strategies to MITIGATE the risks 3 ASSESS the probability of occurrence and potential impact of each risk 2
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ENSURING SMART REGULATION
EFFECTIVE RISK MANAGEMENT PERCEIVED RISK ACTUAL COLLABORATION AND RISK COMMUNICATION PUBLIC TRUST & ACCEPTANCE COLLABORATION AND RISK COMMUNICATION ACTUAL RISK RISK PERCEIVED RISK ACTUAL RISK PERCEIVED RISK ACTUAL RISK PERCEIVED RISK INFORMATION GAP ACTUAL RISK EFFECTIVE RISK MANAGEMENT PERCEIVED RISK PUBLIC TRUST & ACCEPTANCE
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STRAIGHT TALK & OPEN DIALOGUE Three Examples
1 Protecting Underground Water Resources 2 Induced Seismicity 3 Methane Emissions
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1. PROTECTING UNDERGROUND WATER RESOURCES
Well Integrity is the Key!
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ENSURING WELL INTEGRITY
Evaluate Stratigraphic Confinement 1 Well Construction Standards 2 Evaluate Mechanical Integrity of Well 3 Monitor Frac Job & Producing Well 4
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GOOD WELL INTEGRITY CONDUCTOR PIPE SURFACE CASING PRODUCTION CASING
CEMENT FRESH WATER AQUIFER ZONE SHALLOW PRODUCING ZONE TARGET PRODUCING ZONE
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CEMENT CHANNELING PRESSURE BUILDS UP CONDUCTOR PIPE
SURFACE CASING PRODUCTION CASING PRESSURE BUILDS UP FRESH WATER AQUIFER ZONE FORMATION SHALLOW PRODUCING ZONE CASING CEMENT TARGET PRODUCING ZONE
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2. INDUCED SEISMICITY
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INDUCED SEISMICITY What is it?
Earthquakes or “seismic events” that are attributable to human activities In the context of oil and gas operations, the “human activity” is the injection of fluids into, or the withdrawal of fluids from, subsurface formations Current focus is on fluid injection operations
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INDUCED SEISMICITY – ASSESSING RISK
What factors are responsible for triggering the seismic event? Shear stress Normal stress Pore pressure What factors determine the magnitude of the seismic event? Shear strength of faulted rock Fault rupture area Fault displacement
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INDUCED SEISMICITY WATER DISPOSAL WELL HORIZONTAL SHALE WELL WATER DISPOSAL WELL SHALE SAND EARTH STRESS A typical seismic event generates the same amount of energy as dropping a gallon of milk from chest high to the floor. SHEAR STRESS BASEMENT NORMAL STRESS 25,000’
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INDUCED SEISMICITY EARTH STRESS SHEAR STRESS NORMAL STRESS
HORIZONTAL SHALE WELL SHALE SAND SHALE EARTH STRESS SHEAR STRESS BASEMENT NORMAL STRESS 25,000’
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RISK MITIGATION Regulatory Approaches
Ohio New permitting requirements Agency may require applicant to: Conduct pressure fall-off and bottomhole pressure testing Investigate potential faulting (including seismic surveys) Submit well logs, tracer and seismic monitoring plan Conduct “other tests” No drilling into Precambrian basement rock
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RISK MITIGATION Regulatory Approaches
Texas Applicant must survey 100 square mile area around well location for “historical seismic events” (USGS data) Commission may require applicant to provide well logs, cross sections, structure maps and/or pressure front boundary calculations if the disposal well is located in area of increased risk that injected fluids will not be confined to injection interval “Increased risk” areas – complex geology, injection interval is close to basement rock, presence of transmissive faults, and/or history of seismic events
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3. METHANE EMISSIONS Emission Sources Reduction Technology
Well Completions Storage Tanks Pneumatic Controllers Equipment Leaks Liquids Unloading's Compressors Reduction Technology Green Completions Vapor Recovery Units Low Bleed/No Bleed Pneumatics LDAR Program Plunger Lift Seal Maintenance Policy Solutions EPA Regulations State Regulations Voluntary Efforts Technology-Based-vs-Performance- Based Framework
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NATURAL GAS SUPPLY CHAIN
Source: Adapted from American Gas Association and EPA Natural Gas STAR Program
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MANAGING EMISSIONS - GOOD POLICY IS BASED ON SOUND SCIENCE
Allen et al. (2013) Allen et al. (2014) Roscioli et al. (2014) Zavala et al (2015) Mitchell et al. (2015) Marchese et al. (2015) RPSEA Project (NOAA, CSU, CSM, Aerodyne, U. of WY)- ~ 6 papers – 2016/2017 Emission Levels Measurements at the source (“bottoms-up”) indicate emissions are close to inventory estimates Measurements using aircraft (“top-down”) indicate emissions are higher than inventory estimates Regional Variations There are significant regional variations among emission sources Differences likely attributable to (i) type of natural gas production (i.e. wet gas-vs-dry gas) and (ii) the age, number and type of infrastructure Fat-Tail Phenomenon A relatively small number of emission sources are responsible for a disproportionately large number of emissions Cost-Effective Reduction Opportunities There are a number of cost-effective emission control technologies that can be employed today Advances in emissions detection/monitoring technologies should follow reduction opportunities
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REDUCTION OPPORTUNITIES
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MAXIMIZING THE REDUCTION OPPORTUNITIES
Source: Brandt et al. (2016)
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POLICY OPTIONS FOR ADDRESSING METHANE EMISSIONS
TECHNOLOGY-BASED DESIGN Command-and-Control Approach Pre-defined emission control technologies are applied to all “affected sources” Application of control technology is required regardless of the actual emission profile of the source Technology-based design is more appropriate for a smaller population of homogenous emission sources Monitoring, recordkeeping and reporting requirements are burdensome due to large number of emission sources PERFORMANCE-BASED DESIGN ONE Future Approach Performance-based design allows companies to focus on “super emitter/fat- tail” emission sources Each company optimizes emission reductions by focusing capital deployment on its highest emitting sources Technology-neutral approach encourages development of new technologies to achieve emission reduction goals Intensity-based metrics enable bench- marking between companies, regardless of size
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KEY POLICY DESIGN QUESTIONS
How do you design a policy that matches the science? Super-emitters and marginal wells are misunderstood Chronic super-emitter Episodic super-emitter Malfunctioning super-emitter Marginal wells Incorporate existing operating practices Does the policy optimize emission reductions by deploying capital on the highest emitting sources? Does the policy encourage development of new emission reduction technologies?
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ONE FUTURE POLICY DESIGN
Performance-based approach Methane intensity goal of 1% leak/loss rate across value chain Methane intensity “sub-goals” developed for each segment of value chain Recognizes variations among emission sources and the “super- emitter” phenomenon, thereby optimizing capital deployment Emissions inventory protocols approved by EPA Methane Emissions Intensity Methane Emission Intensity Goals
(percent of Gross Production) Industry Segment 2012 2020 2025 Gas Production and Gathering 0.55% 0.46% 0.36% Gas Processing 0.18% 0.15% 0.11% Gas Transmission and Storage 0.44% 0.37% 0.30% Gas Distribution 0.26% 0.24% 0.22% Total 1.44% 1.22% 1.00%
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WORK ON METHANE DETECTION TECHNOLOGIES
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