1. Standards Certification Education & Training Publishing Conferences & Exhibits Colorado Regulation 7 LDAR Monitoring Frequency and Cost Control

2. 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? 3

4. 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 5

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 6

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

8. 8 DJ Basin Piceance

9. 9 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……

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

11. 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 12 Number of Components Inspected Time Number of Inspections Completed Inspections Components

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

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

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

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

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

18. Cost of Compliance… 18 Assumptions 25 compressor stations 1 field tech = $80/hour 1-8 hour day/facility FLIR Camera = $500/day Annual/Quarterly/Monthly Annual = $28,500/year Quarterly = $114,000/year Monthly = $342,000/year

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

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