Recent enforcement actions by the Environmental Protection Agency (EPA) required companies to invest more than $10 billion, in both equipment and actions, to control pollution. The cases before the EPA resulted in more than $170 million in combined federal administrative, civil and judicial penalties and criminal fines. EPA Emission Standards apply to virtually every industry, but especially to the oil and gas industry, which can include storage tank facilities, atmospheric flares used in drilling and production, and the petrochemical and refining side of the industry.
So, how can your company stay compliant with all of the regulations and laws? We’ve prepared some helpful background information and tips to help you avoid costly violations that can dramatically affect your bottom line.
Use of Flare for Compliance
Flares are an integral part of any oil and gas operation, whether it’s upstream, midstream or downstream. As a major component of eliminating waste gases either at a well pad, tank battery, compressor station, production facility or refinery, flares release large volumes of combustible gases, which are ignited at the flare tip into the atmosphere. Simply by the nature of the multitude of situations, volume, flow rate, pressures and composition of the gases can vary dramatically over a relatively short time frame. That’s why it is critical to have measuring systems which provide accurate, real-time data.
Know the Differences Between State Regulations
What may pass as acceptable in one state or one segment of the industry may not fly in another. The EPA doesn’t regulate the upstream side of the industry as much as it does the downstream petrochemical refining space. But, at the state level, depending on the jurisdiction, it can be very different.
For example, the New Mexico regulations and the Texas ones are very far apart, even though the states are right next to each other. You can be drilling in the Permian, which spreads across both states, and on the Texas side, you have the Texas Commission on Environmental Quality (TCEQ), which is very different in its regulations from the New Mexico Environment Department (NMED). When you cross the border into the Panhandle, it’s a very different regulatory environment. The general feeling is that the state regulations come first, then the EPA.
Mechanical Versus Ultrasonic Measurement
Traditionally, and prior to the emphasis on accuracy, there were two primary methods used in flare measurement to come up with the volume of gas being flared. The old methods were primarily accomplished via balancing calculation or, when it was measured at all, with the use of mechanical sensors which have many moving parts which can degrade, break or stick, resulting in inaccurate readings or a loss of flow data altogether. The most modern way to measure flare volumes is by using an ultrasonic sensor to measure volumetric flow, which can measure the entire flow range of a flare, very accurately, with no mechanical wear and tear.
Essentially, in its most basic form, you have two transducers that are shooting an ultrasonic signal back and forth. One is a little farther upstream and one is downstream, so you get a time difference with the flow. It’s really like a stopwatch. It’s the time difference between those two signals. German-based SICK products use ultrasonic measurement primarily because it’s robust and very accurate.
Implement Green Initiatives
For years, the oil and gas industry has been getting a bad rap – and most of it was justified since the industry has not done a good job in getting the correct messaging out.
Technologies are being developed that can help upstream, downstream and midstream become cleaner. Our focus is on flare measurement, which a lot of producers weren’t even measuring previously. They now have a have a super tool to use. And, by doing that, they’re able to clean up their industry. The SICK products have actually helped them realize some objectives that they’re setting for themselves these days regarding emissions targets.
These targets are generally tied into a company’s environmental, social, and governance (ESG) score, which is a measurement of a company’s level of sustainability. Many investors use an ESG score to determine whether or not they will invest in that company. The lower the score, the less chance of attracting investors.
Helping with “The Great Crew Change”
One of the things that the industry has had to deal with over the past several years is the “graying of the industry,” where veteran workers are retiring and being replaced by younger, less experienced workers. SICK has been working to make that transition easier for oil and gas companies through the utilization of its highly technical products, which are appealing to the younger, more tech-savvy workers.
One of the benefits of having this younger group come in is that they’ve grown up with technology. They have grown up with a smartphone, and the Internet, and they accept the new technology and the end of mechanical technology a lot more readily than some of the older guys, who might say, “It’s worked for the last 50 years; we’re going to stick with it.” But the new kids get it. And that generation is in the saddle right now, and they embrace the new technology.
Saving Time, Saving Money
Typically, most oil and gas wells are drilled in the most remote areas permittable. That means a lot of road time spent by the technicians between their service office and the well pad or tank battery facility. They are generally going there to check on a problem.
With the SICK meters, technicians can use diagnostics remotely through the control room level or smartphone level, so they know what those meters are doing in real-time. It saves windshield time and manhours which can translate over the course of a year to millions of dollars in savings. Also, from a safety perspective, the less time spent driving to remote locations, the less chance of any accidents.
Robust Diagnostics in Real-Time
Ultrasonic metering is the future. It can offer measurement under varying operating conditions at high gas velocities and with changing gas compositions. SICK’s products also have intuitive operating software and self-monitoring diagnostics for easy verification and maintenance of the system. The uninterruptable, flowthrough design, and non-mechanical measurement means virtually no maintenance.
When you have billions of cubic feet of gas going through a pipeline, it helps to have the best measurement possible. Not a molecule of gas that comes out of the burner tip hasn’t been measured by an ultrasonic meter somewhere.
TJ McIntyre is an experienced sales and business professional with more than 25 years of international and domestic work experience in sales, negotiations, strategic business planning, execution, and operations management for equipment manufacturers and suppliers in the oil and gas industry. Having spent the last 10 years within the hydrocarbon measurement industry, McIntyre has a proven history of expertise in the field. Underpinning this is his military acumen developed by the USAF, reflected in his dedication and fundamental belief that all obstacles are surmountable. McIntyre also has a bachelor’s degree in Russian studies from the University of Houston.
Oil and gas operations are commonly found in remote locations far from company headquarters. Now, it's possible to monitor pump operations, collate and analyze seismic data, and track employees around the world from almost anywhere. Whether employees are in the office or in the field, the internet and related applications enable a greater multidirectional flow of information – and control – than ever before.