United Stdtes
Environmental Protection
Agency
GRi-94 / 0257.23
EPA-600/R-96-0801
June 1996
                                                       PB97-142970
METHANE EMISSIONS FROM THE

NATURAL GAS INDUSTRY

\ ,>lume 6: Vented and Combustion Source Summary
Energy Information Administration (U. S.  DOE)
 National Risk Management
 Research Laboratory
 Research Triangle Park, fsJC 27711
                   REPRODUCED fiY:
                U.S. Daparlmont ofCommarc
               Nationni Tachnlcal {nfDimstion So
                 Springfiold, VH-fiinia 221^1

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                                TECHNICAL REPORT DATA
                          (Please read Insfmctiotis on *kt f*.ver*c before contpi
i. .REPORT NO.
EP.A-600/R-96-080f
                            Hi I
4. TITLE AND SUBTITLE
Methane Emissions from :he Natural Gas Industry,
 Volumes 1-15  (Volume 6:  Vented and Combustion
 Source Summary)
            5. REPORT DATE
             June 199C
            6. PERFORMING ORGANIZATION CODE
7. AUTHORIS) L> Campbell, M. Campbell, M. Cowgill, D. Ep-
person, ivl. Hall, M.Harrison, K. Hummel, D, Myers,
T. Shires, B. Stapper, C. Stapper, J. Wessels,  and *
                                                      6. PERFORMING ORGANIZATION REPORT WO.
             DCN 96-263-081-17
                                                      10 PROGRAM ELEMENT NO,
9. PERFORMING ORGANIZATION NAME AND ADDRESS
Radian International LLC
P. O. Box 201088
Austin, Texas 78720-1088
            11. CONTRACT/GRANT NO.
             5091-251-2171 (GRI)
             68-01=0031 (EPA)
12. SPONSORING AGENCY NAME AND ADDRESS
 EPA, Office of Research and Development
 Air Pollution Prevention and Control Division
 Research Triangle Park, NC 27711
                                                       13. TYPE OF REPORT AND PERIOD COVERED
                                                       Final;  3/91-4/96
            14. SPONSORING AGENCY CODE
              EPA/600/13
ie.SUPPLEMENTARY NOTES EPA project officer is D. A. Kirnhgessner,MD-63,919/541-4021.
Cosponsor GRI project officer is R. A. Lott, Gas Research Institute, 8600 West Bryn
Mawr Ave., Chicago,  IL 60631. (*)H. Williamson (Block 7).
              15-volume report summarizes the results of a comprehensive program
to quantify methane (CK4)  emissions from the IJ. S. natural gas industry for the base
year. The objective was to determine CH4 emissions from the wellhead and ending
downstream at the  customer's meter. The accuracy goal was to determine these
emissions within -i-/-0. 5%  of natural gas production for a 90% confidence interval. For
the  1992 base year, total CB4 emissions for the U. S, natural gas industry was 314
+ /- 105 Bscf (6.04  +/- 2.01 Tg).  This is equivalent to 1.4 +/- 0.5% of gross natural
gas production, and reflects neither emissions reductions (per the voluntary Ameri-
Gas Association/EPA Star Program) nor incremental increases (due to increased
gas usage) since 1992. Results from this program were used to compare greenhouse
    emissions from the fuel cycle for natural gas, oil,  and coal using the global war-
ming potentials (GWPs)  recently  published by the  Intergovernmental Panel on Climate
Change (IPCC). The analysis showed that natural  gas contributes less to potential
global warming than coal or oil,  which  supports the fuel switching strategy suggested
by the IPCC and others. In addition, study results are  being used by  the natural gas
industry to reduce  operating costs while reducing emissions.
                             KEY WORDS AND DOCUMENT ANALYSIS
                 DESCRIPTORS
                                          b.lDENTIFIFRS/OPCN ENDED TERMS
                                                                      cos AT I Field/Group
Pollution
Emission
Greenhouse Effect
Natural Gas
Gas Pipelines
Methane
Pollution Prevention
 Stationary Sources
 Global Warming
13 B
14G
04A
21D
15E
07C
18. DISTRIBUTION STATEMENT

 Release to Public
19. SECURITY CLASS (Tliis Report)
 Unclassified
                                                                    21, NO OF PAGES
20. SECURITY CLASS (1 his page)
EPA Form 222O-1 (9-?:;)

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                            FOREWORD
The U. S. Environmental Protection Agency is charged by Congress with pro-
tecting  the Nation's land, air, and water resources.  Under a mandate of national
environmental laws, the Agency strives to formulate and implement actions lead-
ing to a compatible balance between human activities and the ability of natural
systems to support and nurture life.  To meet this mandate, EPA's research
program is providing data and technical support for solving  environmental pro-
blems today and building a science  knowledge base necessary to manage our eco-
logical  resources wisely, understand how pollutants affect our health, and pre-
vent or reduce environmental risks in the future.

The National Risk Management Research Laboratory is the Agency's center for
investigation of technological and management approaches for reducing risks
from threats to human health and the environment. The focus of the  Laboratory's
research program is on methods for the prevention and control of pollution to air,
land, water, and subsurface resources; protection of water  quality in public water
systems; remediation of contaminated sites and groundwater; and prevention  and
control of indoor air pollution.  The goal of this research effort is to  catalyze
development and implementation of innovative, cost-effective environmental
technologies; develop scientific and engineering information needed by EPA to
support regulatory and policy decisions; and provide technical support and infor-
mation  transfer to ensure effective implementation of environmental  regulations
and strategies.

This publication has been produced as part of the  Laboratory's strategic long-
term research plan. It is published and made available by EPA's Office of Re-
search  and Development to assist the user community  and to link researchers
with their clients.


                           E. Timothy Oppelt, Director
                           National Risk Management Research Laboratory
                           EPA REVIEW NOTICE

     This report has been peer and administratively reviewed by ihe U.S. Environmental
     Protection Agency, and approved for publication.  Mention of trade names  or
     commercial products does not constitute endorsement or recommendation for use.

     This document is available to the public through the National Technical Information
     Service, Springfield, Virginia 22161.

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                                          EPA-600/R-96-080f
                                          June 1996
              METHANE EMISSIONS FROM
             THE NATURAL GAS INDUSTRY*
VOLUME 6: VENTED AND COMBUSTION SOURCE SUMMARY
                    FINAL REPORT
                      Prepared by:,

                   - Theresa M. Shires
                   Matthew R. Harrison

                 .Radian International LLC
                   8501 N. Mopac Blvd.
                 \   P.O. Box 201088
                  Austin, TX  78720-1088
                   DCN:  95-263-081-01
              «     ~      For  ~    ~ _  -

             GRI Project Manager:, Robert A. Lott
                GAS RESEARCH INSTITUTE
                 Conttact No. 5091-251-2171 - .
                 8600 West Bryn Mawr Ave.
                  __  Chicago, IL 60631

                     -     and -   r

          EPA Project Managers David A. Kirchgessner
       U.S. ENVIRONMENTAL PROTECTION AGENCY
                  Contract No. jS8-Dl-003i
         National Risk Management Research Laboratory
              Research Triangle Park, NC 27711

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LEGAL NOTICE:  This report was prepared by Radian International  LLC as an account
of work sponsored by Gas Research Institute  (GUI) and the U.S. Environmental  Protection
Agency (EPA).  Neither EPA, GRI, members of GRI, nor any person acting on behalf of
either:

a.     Makes any warranty or representation, express or implied, with  respect  to the
       accuracy, completeness, or usefulness of the information contained  in this rsport. or
       that the use of any apparatus, method, or process discio,=ed in this report may not
       infringe privately owned rights;  or

b.     Assumes any liability with respect to the use of, or for damages resulting from the
       use of, any information, apparatus, method, or process disclosed in this report.

NOTE:  EPA's Office  of Research and Development quality  assurance/quality control
(QA/QC)  requirements  are applicable to some of the cotmt data generated  by this project.
Emission  data and additional count data are from  industry or  literature  sources,  and  are not
subject  to EPA/ORD's  QA/QC policies. In all cases, data and results were reviewed by the
panel of experts listed in  Appendix D of Volume  2.

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                             RESEARCH SUMMARY
Title



Contractor




Principal
Investigators

Report Period


Objective
Technical
Perspective
Results
Methane Emissions From Vented and Combusted
Sources
Final Report

Radian International LLC

GRI Contract Number  5091-251-2171
EPA Contract Number 68-D1-0031

Theresa M.  Shires
Matthew R. Harrison

March 1991 - June 1996
Final Report

This report summarizes methane emissions from vented and combusted
sources.  Significant sources of vented and combusted emissions are
discussed, as well as miscellaneous minor sources of emissions.  In
addition, documentation for the methane compositions used for each
industry segment is provided.  This report also discusses inconsistencies
hi reported vented and flared emissions reported by other sources.

The increased use of natural gas has been suggested as a strategy for
reducing the potential for global warming. During combustion, natural
gas generates less carbon dioxide (CO2) per unit of energy produced than
either coal or oil.  On the basis of the amount of CO2 emitted, the
potential for global warming could be reduced by substituting natural gas
for coal or oil.  However, since natural gas is primarily methane,  a potent
greenhouse gas,  losses  of natural gas during production, processing,
transmission, and distribution could reduce the inherent advantage of its
lower CO2 emissions.

To investigate this, Gas Research Institute (GRI) and the U.S.
Environmental Protection Agency's Office of Research and  Development
(EPA/ORD) cofunded a major study to quantify  methane  emissions from
U.S. natural gas  operations for the 1992 base year. The results of this
study can be used to construct global methane budgets and  to determine
the relative impact on global warming of natural gas versus coal and oil.

Vented emissions account for approximately  94 Bscf of methane
emissions annually.  Compressor exhaust is the  primary source  of
                                          111

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                  combustion  emissions, contributing approximately  25 Bscf of methane
                  emissions annually.

                  Based on data from the entire program, methane ^missions from natural
                  gas operations are estimated to be 314 ± 105 Bscf for the 1992 base
                  year.   This is about 1.4 ± 0.5% of gross natural gas prodactioii.  The
                  overall program also showed that the percentage of methane  emitted for
                  an incremental  increase in natural  gas sales would be significantly lower
                  than the baseline case.

                  The project  reached its accuracy goal and provides an accurate  estimate
                  of methane  emissions that can be used to conduct methane inventories
                  and analyze fuel switching strategies.

Technical         Vented emissions primarily result  from three categories:  1) pneumatic
Approach         devices, 2) blow and purge emissions,  and 3) dehydrator emissions.
                  Combusted emissions result from the incomplete combustion of methane
                  in burners,  flares, and engines.

                  Vented and  combusted emissions are typically considered unsteady
                  emission sources, that is, sources with highly variable emissions.   These
                  emission sources vary from company to company and site to site,
                  because of different maintenance practices and operating conditions.
                  Therefore, it is impractical to measure every source continuously  for  a
                  year.  Each  unsteady emission source requires a unique  set of equations
                  and gathered data based on the equipment type, various components,  and
                  operating modes to produce an emissions  factor.  Data on unsteady
                  emissions were gathered at multiple  sites in each  segment of the
                  industry: production, gas processing, transmission,  storage, and
                  distribution.

                  This report summarizes  methane emissions from significant, as well as
                  minor miscellaneous  sources of vented and combusted emissions.  In
                  addition, this report serves to document the data sources used to
                  determine methane compositions for the various industry segments.
                  Finally, a discussion  of inconsistencies in reported vented and flared
                  emissions is provided to support the decision for using a bottom-up
                  approach in this project to more accurately account for emissions from
                  these sources.

Project            For the  1992 base year the annual methane emissions estimate for the
Implications       U.S. natural gas industry is 314 Bscf ± 105 Bscf (± 33%).  This is
                  equivalent to 1.4% ± 0.5% of gross natural gas production.  Results from
                  this program were used to compare greenhouse gas emissions from the
                  fuel cycle for natural gas. oil,  and coal using the globJ warming

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potentials (GWPs) recently published by the Intergovernmental Panel on
Climate Change (IPCC).  The analysis showed that natural pt-.s
contributes Jess to potential  global warming than coal or oil, which
supports the fuel  switching strategy suggested by IPCC and others.
                                                                                                            10    Si.
In addition, results from this study are being used by die natural gas
industry to reduce operating costs while reducing emissions.  Some                                              .0    IN
companies are also participating in the Natural Gas- Star program, a
voluntary program sponsored by EPA's Office of Air and Radiation  in                                        3.0    D/'
cooperation with  the American Gas Association to implement cost-
effective emission reductions and to  report reductions to the EPA. Since                                        4.0    RI
this program was begun after the 1992 baseline year, any reductions in
methane emissions from this program are not reflected in this study's                                                  4. 1
total emissions.                                                                                                     4.'
Robert A. Lott
Senior Project Manager,  Environment and Safety                                                              5.0    Mi
                                                                                                            6.0
                                                                                                                   A:

                                                                                                                   A

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                           TABLE OF CONTENTS

                                                                        Psgi*

1.0   SUMMARY  	1

2.0   INTRODUCTION 	2

3.0   DATA COLLECTION	,	4

4.0   RESULTS   	8

      4.1    Compressor Exhaust  	8
      4.2    Pneumatic Devices	10
      4.3    Chemical Injection Pumps  	  12
      4.4    Dehydrator Vents  	  13
      4.5    Dehydrator Glycol Pumps	  14
      4.6    Blow and Purge	  15

5.0   MISCELLANEOUS MINOR CATEGORIES  	  18

      5.1    Burners  	18
      5.2    Flares	20
            5.2.1  Combustion Efficiency  	21
            5.2.2  Total Natural Gas Flow to Gas Industry Flares  	  24
      5.3    Acid  Gas Recovery Vents	,	27
      5.4    Salt Water Tanks	28
      5.5    Drilling  	29
      5.6    Drips  	30
      5.7    Sampling  	31

6.0   REFERENCES  	32


      APPENDIX  A - Methane Composition   	,	A-l

      APPENDIX  B -  Reported "Vented and Flared" Data	 B-l
                                     VI

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                                 LIST OF TABLES

                                                                              Page

3-1    Emission  Sources	6

3-2    Emission  Source Groups by Type  	7

4-1    Summary of Unsteady Emissions	  9

4-2    Blow and Purge Emission Results	 17

5-1    Burner Fuel Gas Activity Factor  	 19

5-2    Summary of Previous Flare Combustion Efficiency Studies   	 22

5-3    Non-Combusted Emissions from Production and Gas Processing
       (GRI/EPA Estimate Basis)   	25

5-4    Maximum Flaring Emissions	27

5-5    Salt Water Tank Emissions	2^

A-?.    Methane Composition by Industry Segment  	  A-2

A-2    Average State Methane Content and Production Rate	  A-4

A-3    Methane Composition of Production Gas  	A-5

A-4    Methane Composition hi Gas Processing  	  A-5

B-l    Comparison  of 45-1 Reports  	  B-9

B-2    1991 Flaring Permits for Oklahoma	  B-10

B-3    Supply and Disposition of Gas hi the United States—1989	  B-l3
                                        VII

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1.0          SUMMARY

             This report is one of several volumes that provides background information
supporting the Gas Research Institute and U.S. Environmental Protection Agency, Office of
Research and Development (GRI-EPA/ORD) methane emissions project. The objective of
this comprehensive program is to  quantify tne methane emissions from the gas industry for
the 1992 base year to within ± 0.5% of natural gas production starting at. the wellhead  and
ending immediately downstream of the customer's meter.

             This report summarizes methane emissions from vented and combustion
sources.  Vented emissions primarily result from three categories:  1) pneumatic  devices, 2)
blow and purge emissions,  and 3) dehydrator emissions, which combined account for
approximately 94 Bscf of methane emissions annually.  Combustion  emissions result from
the incomplete combustion of methane  in burners, flares, and engines.  Compressor  engine
exhaust is the only significant source of methane in this category, accounting for
approximately 25 Bscf of methane emissions annually.

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2.0           INTRODUCTION


              For this project, sources of methane emissions from the natural gas industry
were classified as follows:
                     Vented - Vented emissions are Intentional releases from equipment
                     blowdown lor maintenance, releases from emergency depressuring
                     (from safety valves and station emergency blowdown)-  direct venting
                     of gas used to power equipment (such as pneumatic devices), or
                     accidental  releases due to mishaps (such as pipeline dig-ins).

                     Combustion - Combustion  emissions refer  to methane  that enters the
                     atmosphere due to the incomplete combustion of natural gas.
                     Examples are methane in compressor engine exhaust and methane
                     from flare stacks and burners.

                     Fugitive  - Tugitive emissions are unintentional leaks from sealed
                     surfaces (such as valve stem packing, flange gaskets, compressor shaft
                     seals, and pipelines).
              This report summarizes emissions from vented and combustion sources.

Vented and combustion emissions are typically considered "unsteady." Unsteady emitters

are defined  as sources with highly variable emissions,  such as a pneumatic device on an

isolation valve or a maintenance activity that requires blowdown.  These emission sources

vary from company to company and site to site, because of different maintenance practices
and operating conditions.


              In contrast, emission sources with continuous bleed rates, or with reasonably

steady bleed rates  over a typical measurement tune,  are considered "steady"  sources.
Fugitive emissions are generally considered steady.  Extensive measurements of fugitive

emissions have been made in this  and other studies in all segments of the gas industry.1'2'3


              Section 3 of this report discusses daH collection techniques used  to estimate
unsteady emissions.  Results from vented and combustion sources considered significant are
presented in Section 4.  Details on emission estimates  for compressors, pneumatic devices,

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dehydrators, chemical  injection pumps, mishaps,  etc. are available in other volumes.'1'"'7'8-9
Section 5 discusses miscellaneous minor emission sources.  Documentation  supporting the
methane compositions  used for each industry  segment is provided in Appendix A.  This
report also discussed inconsistency in vented and flared emissions in Appendix B.

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3.0           DATA COLLECTION

              This GRI/EPA study calculated emission factors for unsteady emission
sources, rather than measuring  them.  Each unsteady source requires a unique set of
equations  and gathered data based on the equipment type, various components, and
operating  modes to produce the emission factor quantity.  However, all sources require the
following general  information:

              1)     A detailed technical description of the source, identifying the
                    important emission-affecting  parameters  (i.e., equipment components
                    and operating modes).  This  was  generally accomplished  through a
                    source characterization  report.
              2)     Data to estimate the volume  of natural gas released and the frequency
                    of releases from multiple site visits or existing reports.
              3)     Data on gas composition (percent methane) in various industry
                    segments  (production, gas processing, transmission, and distribution).
                    Details  on the methane  composition  results  are provided in Appendix
                    A.

              Step 1 was accomplished by researching  each particular source and gathering
manufacturer, operator, and site data so that  a full technical description of the  important
emission characteristics  of the source category could be written.  Using this description,
data on the emission-affecting characteristics  of each source were gathered through  site
visits or existing resources.

              For many  emission sources, the frequency of release events was measured
(such as strokes/minute  for pneumatic actuators); but for extremely infrequent  releases (such
as equipment maintenance blowdowns), the frequency  was estimated by gas  industry field
personnel.  The emission volume per event was not measured for most sources (as in the
case of compressor exhaust methane) but was often calculated using gathered site data,
existing reports, and first principles.

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              During this study, data on unsteady emissions were gathered at multiple sites
in each segment of the industry: production, gas processing, transmission, storage, and
distribution.  Details on the industry  segments and boundaries are provided in Volume 5 on
the activity factors.10  The site visits  and literature searches allowed construction of a matrix
that shows all the emission sources within the gas industry grouped by process segment and
operation mode.  Table 3-1 shows this grouping.  The industry characterization also  allowed
a grouping of sources  by emission type, as shown in Table 3-2.

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TABLE 3-1. EMISSION SOURCES
Industry Segment
Production
Gas Processing Plants
Transmission and Storage
Distribution
Operating Mode
Start Up
Normal Operations
Maintenance
Upsets/Mishaps
Start Up
Normal Operations
Maintenance
Upsets/Mishaps
Start Up
Normal Operations
Maintenance
Upsets/Mishaps
Start Up
Normal Operations
Maintenance
Upsets/Mishaps
Emission Sources
(Equipment or Activities)
Drilling (mud emissions)
Well completion testing
Fugitives
Pneumatic devices
-control valves
Chemical injection pumps
Glycoi dehydrators
Compressor exhaust
Compressor starts
Well bore maintenance
Blow and purge
Emergency blowdowns
Dig-ins
Not applicable or negligible activity
Fugitives
Pneumatic devices
- isolation valves
Glycoi dehydrators
Acid Gas Recovery vent,
Engine exhaust
Compressor starts
Blow and purge
Emergency blowdowns
NO MISHAPS
Not applicable or negligible activity
Fugitives
Pneumatic devices
- control valves
- isolation valves
Glycoi dehydrators
Engine exhaust
Compressor starts
Blow and purge
Emergency blowdown
Dig-ins

Fugitives
Pneumatic devices
- control valves
- isolation valves
Glycoi dehydrators
Engine exhaust
Compressor starts
Blow and purge
Emergency blow-down
Dig-ins

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                 TABLE 3-2.  EMISSION SOURCE GROUPS BY TYPE
    Source
  Type
Emission Soi trees
Combustion      Unsteady   Engine exhaust (compressors and other gas-driven engines)
Sources                     Flares
                            B'irners
Vented Sources   Unsteady
           Pneumatic devices
           Chemical injection pumps
           Glycol circulation pumps
           Glycol dehydrator vent
           Acid Gas recovery (AGR) vent
           Blow and purge
                        (for start up, maintenance, and
                        upsets/emergency conditions)
           Mishaps
Fugitive
Sources
Steady     Leaks from sealed surfaces
                        (flange gaskets, valve stem packing, valve seats
                        open to the atmosphere, pressure relief valve
                        seats, compressor seals, etc.)
           Leaks from small holes in pipelines

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4.0           RESULTS

              This section reviews the characterization results on the major unsteady
categories.  (Major categories were defined as any source over 1 Bscf.) Minor categories
are discussed in Section 5. Table 4-1 summarizes the results determined for each category of
unsteady emissions in ec"-.h industry segment.  Details on the techniques used and the data
gathered for each of the unsteady emission categories are provided in other documents of this
multi-volume set on methane emissions.4'6'8'9'11-12

4.1           Compressor Exhaust

              Methane emitted to the atmosphere in compressor engine exhaust is a
significant source of unsteady emissions and accounts for approximately 25 Bscf of methane
emissions.4  Methane emissions result from the incomplete combustion of the natural gas
fuel, which  allows some of the methane hi the fuel to exit in the exhaust stream. There are
two primary types of compressor drivers:  1) reciprocating gas engines, and 2) gas turbines.
A few compressors in the industry  are driven by other means such as electrical motors, but
the majority are natural gas-fueled  drivers.  In addition to compressors, there  are some
natural gas drivers that operate site electrical generators for gas plants and compressor
stations.

             Reciprocating  engines emit more methane per horsepower or per unit of fuel
consumed than turbine drivers: 0.24 scf/HP«hr for reciprocating versus 0.0057 scf/HP«hr for
turbines.  Reciprocating engines account for over two-thirds of all installed horsepower in the
gas industry (100,500 MMhp»hr compared to 44,300 MMhp»hr for gas turbines).  Therefore,
reciprocating engines account for 98% of the methane emissions for this category.

             Emissions were determined by analyzing and combining several databases. A
GRI database,  the GRI TPANSDAT compressor module,13 contains data from American Gas
Association  (A.G.A.) on types and models of compressors in use, as well as data on

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	TABLE 4-1.  SUMMARY OF UNSTEADY EMISSIONS	

                           Annual Methane                    :
         Source            ;Emissaons, Bscf       90% Confidence Interval

 Oppressor Exhaust
   Production                          6.6                     ± 200%
   Gas Processing                       6.9                     ± 130%
   Transmission                       11.4                     ±15%

 Pneumatic Device?
   Production                         31.4                     ±65%
   Gas Processing                       0.1                     ± 64%
   Transmission                       14.1                     ± 60%

 Chemical Injection Pumps                1.5                     ±203%

 Dehydrator Vents
   Production                          3.4                     ± 193%
   Gas Processing                       1.05                    ± 208%
   Transmission                        0.10                    ± 392%
   Storage                             0.23                    ± 166%

 Dehydrator Glycol Pumps
   Production                         11.0                     ±110%
   Gas Processing                       0.17                    ±228%
   Transmission
   Storage

 Acid Gas Recovery Vents                0.82                    ± 109%
Blow and Purge
Production
Gas Processing
Transmission
Distribution

6.6
3.0
18.5
2.2

± 329%
±262%
± 177%
± 1,783%
 TOTAL                             119                        ± 54%

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compressor driver exhaust from the Southwest Research Institute (SwRI).  A.G.A. gathers ii.s
data from government agencies, such as DOE and FERC, and from surveys of its member
companies hi transmission and distribution. SwRI data were generated through actual field
testing. The data were combined to  generate emission factors for this project by correlating
compressor driver type, methane emissions, fuel use rate, and annual operating hours for 775
reciprocating engines and 86 gas turbines.

              Horsepower°hour activity factors were developed  for each industry segment
using TRANSDAT, FERC, A.G.A., company databases, and site-visit data.  TRANSDAT
includes horsepower data for 7,489 reciprocating engines and 793 gas turbines in
transmission.  Transmission operating hours were based on FERC data for 1992 and one
company's data for 524 reciprocating engines and 89 gas turbines.  Storage horsepower was
based on A.G.A. data aid operating  hours are based  on data from 11 storage stations. Since
national totals for transmission and storage horsepower are available, no industry
extrapolation was necessary for these activity factors.  Production horsepower°hours were
based on one company's data for 516 reciprocating engines.  Horsepower  and operating
hours for the gas processing segment were based on 10 site  visits and company data for 18
gas processing plants.  Horsepowereho
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              There are two primary types of these devices:  1) control valves thai regulate
flow, and 2) isolation valves that block or isolate equipment and pipelines.  Of the two main
types,  isolation valves typically have lower annual emissions, although the emission rate per
actuation can be large.  This is because isolation valves are moved infrequently,  for
emergency or maintenance activities that require isolating a piece of equipment or section of
pipeline.  Alternatively, control valves typically move frequently to make adjustments for
changes in process conditions, and some types of control valves bleed gas continuously.

              Each segment of the industry has very different practices regarding the
pneumatic devices, as described below:

              Production

              The production segment accounts for the majority of pneumatic emissions:
31.4 Bscf,  or 69% of all pneumatic emissions.  Compressed air is rarely used as a pneumatic
operating medium in the production segment, since compressed air requires electricity at the
often remote well sites,  and since gas is readily available and less expensive.   A  typical
production pneumatic device releases  126 Mscf methane annually and there are an estimated
249,000 pneumatic devices associated with natural gas production.

              Gas Processing

              Pneumatic emissions from the gas processing segment are very small: 0.12
Bscf annually, or approximately 1% of all pneumatic emissions.  Only one-half (56%) of the
gas processing plants participating in this project use natural gas to operate pneumatic
controllers  and isolation valv^- other sites use compressed air or electric motors.  The
natural gas-powered isolacion valves in this industry segment are operated infrequently
(once/month or once/year), so the annual emissions per site are relatively small
(approximately 165 Mscf of methane per gas  processing plant).
                                           11

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              Transmission/Storage

              Pneumatic emissions from the transmission compression stations and storage
stations account for 14.1 Bscf annually, or 31% of pneumatic emissiors.  Ir this industry
segment, most of the pneumatics are gas-actuated isolation valves.  There are  a few
pneumatic control valves used to reduce pressure or to control liquid flow from a separator
or scrubber.  The annual methane emissions from a transmission pneumatic device are 162
Mscf, and there are apj.' xirnately 87,000 of these devices nationally.

              Distribution

              Pneumatic emissions for the distribution segment are included in the meter and
regulation station "fugitive" emission factor.2

4.3           Chemical Injection Pumps

              Chemical injection pumps .^e a source of unsteady emissions and account for
1,5 Bscf of annual methane emissions.8 Gas-driven chemical injection pumps use gas
pressure to move  a piston which pumps the chemical on the opposite end  of the piston shaft;
the power gas is then vented to the atmosphere at the end of the stroke. The power gas may
be natural gas or compressed  air.  Two types of chemical injection pumps were observed:  1)
piston pumps, and 2) diaphragm pumps. The  larger diaphragm pumps emit more gas per
stroke, and they are used to pump a higher flow rate of chemical or to pump the chemical.
into high pressure equipment.

              Chemical injection pumps are used to add chemicals such as corrosion
inhibitor, scale inhibitor, biocidc,  demulsifier, clarifier, and hydrate inhibitor to operating
equipment. These additives protect the equipment or help maintain the flow of gas.  The
vast majority of these pumps exist hi the production segment, located at the well sites, so
that the chemical can protect all of the downstream and downhole equipment.  As with
                                          12

-------
pneumatic control valves, the chemical injection pumps in production are primarily powered
by natural gas.

              In the production segment, significant regional differences exist.  Depending
on the gas composition and conditions, some regions use very few pumps, while other
regions use the pumps frequently.  Many pumps also iiave seasonal operation since they
protect against hydrate formation, which whiter temperatures exacerbate. Approximately
17,000 chemical injection pumps are associated with natural gas production.  A typical
methane emission rate is 248 scfd per  pump, based on site and manufacturer data.

              Only a few pumps exist hi the gas processing and transmission segments. The
pumps that do exist are powered by compressed air at these stations, and as a result, have no
methane emissions.

4.4           Dehydrator Vents

              Glycol dehydrator vents are a     ^oant source of methane emissions and
account for 4.8 Bscf of methane emissions annually.11  The majority of the glycol
dehydrators are located in production,  but dehydrators  are also present in the gas processing,
transmission, and storage segments of  the natural gas industry. Methane emissions are
higher in the production segment (71% of the total emissions are attributed to glycol
dehydrator vents) due to  the high activity factor for this segment and the lack of flash tanks
hi most production dehydrators.

              Glycol dehydrators remove water from the natural gas through continuous
glycol absorption.  The water-rich glycol is then regenerated, or heated, which drives the
water back out of the glycol. The glycol also absorbs  some other compounds from the gas,
including a small amount of methane.  The methane is driven off with the water in the
regenerator and vented to the atmosphere.
                                          13

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              The important ^mission-affecting variables for dehydrators are:  gas
throughput, use of a flash tank, use of stripping gas, and use of vent controls routed to a
burner.  An emission factor was established for glycol dehydrator regenerator vents using
three sources of riata:  1) computer simulations of dehydrator operations using first
principles; 2) data from actual on-line analyzer samples taken from regenerator vents: and 3)
multiple site visits.  The resulting annual methane emission factors are:  276 scf/MMscf
throughput for production, 122 scf/MMscf for gas processing, 94 scf/MMscf for
transmission, and 117 scf/MMscf for storage.  For each industry segment, the emission
factor v/as combined with an activity factor to generate the national emission rats, where the
activity factors are based on the annual volume of gas dehydrated (12.4 Tscf for production,
8.6 Tscf for gas processing. 1.1 Tscf for transmission, and 2.0 Tscf for gas storage).

4.5           Dehydrator Giycol Pomps

              Glycol dehydrator circulation pumps are a significant source of unsteady
emissions and account for approximately 11 Bscf of annual methane emissions.12  These
pumps use the high pressure of the rich glycol from the absorber to power pistons that pump
the low-pressure, lean glycol from the regenerator.  The pump configuration pulls additional
gas from the absorber along with  the rich glycol (more gas than would flow with the rich
glycol if conventional electrical pumps  and level control were used). This gas is emitted
along with other absorbed methane through uie dehydrator vent stack.

              Gas-powered glycol circulation pumps are common throughout the industry,
even in sites where electrical pumps  are the standard for other equipment.  The dehydrator
equipment is often specified as a separate bid package, and the vendors most often use the
Kimray gas pump as their standard pumping unit.  The pumps are an integral part of the
glycol dehydrator unit and  their emissions occur through the same point. However,  the
pumps are the cause for most of the  methane emissions from dehydrators, so they are
considered separately.
                                           14

-------
              Unlike chemical injection pumps which vent the driving gas directly to the
atmosphere, dehydrator pumps pass the driving gas along with the wet glycol to the reboiler.
Therefore, methane emissions from the pump depend on the design of the dehydrator, since
gas recovery on the dehydrator will also recover gas from the pump. The demographics
generated for the glycol dehydrator control system (flash drum recovery and vent vapor
recovery) were also used to determine the net emission rate for glycol pumps.

              Based on a gas iliroughput basis, emission factors for glycol pumps were
estimated to be 992 scf msthane/MMscf for production and 178 scf/MMscf for gas
processing.  The corresponding annual activity factors are  1.1 Tscf and 0.96 Tscf,
respectively.

4.6           Blow and Purge

              Blow and purge is a large source of unsteady emissions and accounts for
approximately 30 Bscf of methane emissions annually.9 Blow (or blowdown) gas refers  to
gas that is vented due to maintenance, routine operations, or emergency conditions.  A piece
of process equipment or an entire site is isolated from other gas-containing equipment and
depressured to the atmosphere. The gas is discharged to the atmosphere for one of the
following reasons:
             1)     Maintenance Blowdown - the gas is vented from equipment to eliminate
                    the flammable material inside the equipment, thus providing a safer
                    working environment for workers that service the equipment or enter
                    the equipment.
             2)     Emergency Blowdown - the gas is vented from a site to eliminate a
                    potential fuel source.  For example, if an equipment fire begins at a
                    compressor station, the station emergency shutdown and emergency
                    blowdown system blocks the station away from the pipelines ?nd
                    discharges the gas inside the station, thus reducing the fuel that could
                    feed the fire.
                                          15

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The factors that affect the volume of methane blowdown released to the atmosphere are:
frequency, volume of gas blowdown per event, and the disposition of the blowdown gas.

             Blowdown from maintenance releases was determined for each equipment
category:  compressor blowdown, compressor  starts, pipeline blowdown, vessel blowdown,
gas wellbore blowdown, and miscellaneous equipment blowdown.  Emergency  blowdown
refers to the unexpected release of gas by a safety device, such as a pressure-relief valve
(PRV) on a vessel or the automatic shutdown/emergency blowdown of a transmission
compressor station.  Dig-ins, which are  pipeline ruptures caused by unintentional damage,
were also classified as an emergency release of gas. Table 4-2 summarized the emission
factors and activity factors for the various blow and purge sources.

             Emission estimates for each industry segment were based on data from one or
more of the following sources: 1) site-visit data; 2) company-tracked data; 3) company
studies; and 4) equipment characteristics. Data quality in the transmission segment was
considered superior since it was based upon rigorous company-tracked data.  Gas-processing
data were extrapolated from transmission data based upon the similarities between gas plant
compression and transmission compressor stations.  Distribution segment data were
considered good since they were based upon company studies.  Production data were
considered poor (and may be underestimated) since they are based upon operator
recollections of blowdow- frequency gathered  during site visits.
                                          16

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                      TABLE 4-2. BLOW AND PURGE EMISSION RESULTS
   Industry Segment
 Annual Emission Factor
       Activity Factor
 National Annual
Methane Emission
   Rate, Bscf
Production:
 Gas Wells Unloading
 Compressor Slowdowns
 Compressor Starts
 Pipeline Miles
 Production Vessels
 Completion Flaring
 Well Workovers
 PRV Releases
 BSD Releases
 Dig-ins
     49,570 ± 344% scf/wdl
    3,774 ± 147% scf/comp.
    8,443 ± 157% scf/comp.
        309 ± 32% scf/mile
       78 ± 266% scf/vessel
  733 ± 200% scf/completion
 2,454 ± 459% scf/workover
       34 ± 252% scfy/PRV
256,888 ± 200% scf/platform
      669 ± 1,925% scf/mile
     114,139 ±45% wells
17,112 ± 52% compressors
17,112 ± 52% compressors
     340,000 ± 10% miles
   255,996 ± 26% vessels
   844 ± 10%  completions
 9,329 ± 258% workovers
    529,440 ±53% PRVs
   1,115 ± 10% platforms
     340,000 ± 10% miles
     5.66 ± 380%
    0.065 ± 173%
    0.144 ± 184%
     0.105  ± 34%
    0.020 ± 276%
   0.0006 ± 201%
  0.023 ± 1,296%
    0.018 ± 289%
    0.286 ± 201%
   0.23 ± 1,934%
Gas Processing
   4,060 ± 322% Mscf/plant
         726 ±2% plants
     2.95 ± 262%
Transmission and Storage:
  Stations
  Pipeline Miles
  4,359 ± 322% Mscf/station
     31.6 ± 343% Mscf/mile
      2,175 ±8% stations
      284,500 ±5% miles
     9.48 ± 263%
     9.00 ± 236%
Distribution:
 PRV Releases
 Dig-ins
 Blowdowns
  0.050 ± 3,914% Mscf/main
                      mile
   1.59 ± 1,922% Mscf/mile
    0.102 ± 2.521 Mscf/mile
 836,760 ±5% miles main
    1,297,569 ±5% miles
    1,297,569 ±5% miles
   0.04 ± 3,919%
   2.06 ± 1,925%
   0.13 ± 2,524%

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5.0          MISCELLANEOUS MINOR CATEGORIES

             There were many emission categories that contributed negligible amounts of
methane (less than 1 Bscf). Although small, these categories are discussed in order to
provide a complete picture of the industry, but these emission sources are not itemized hi the
summary of annual emissions reported by this study.  Emissions from a few other minor
categories are quantified in Volume 7 on blow and purge activities.9

5.1          Burners

             Burner combustion refers to the controlled burning of natural gas in order to
add heat to a process stream.  Burners combine ah"  and gas in a controlled manner to
maximize combustion efficiency. In the natural gas industry, burners are used in all industry
segments.  In the production segment, a high-pressure gas well requires a choke and an in-
line heater to avoid  freezing water hi the line  from the pressure drop flash.  Glycol
dehydrators, which are present in all industry segments, require a reboiler burner to heat and
regenerate the glycol.  Above-ground liquefied natural gas (LNG) facilities may have boilers
or hot oil furnaces for methane vaporization.  Some gas plants may have additional burners
hi boilers and other sources.

             Non-combusted methane may be emitted by burners hi two ways:  1) since
combustion is not 100% efficient, there is a Finall amount of methane that escapes from the
burner uncombusted, and 2) if the burner has  a flameout, all of the methane sent to the
burner can be emitted uncombusted.  This report has assumed that flameout emissions are
negligible, based upon interviews with gas industry  personnel.  Therefore only incomplete
combustion emissions are calculated hi this section.

             The combustion efficiency cf natural  gas hi burners was determined from
Section 1.4 of the U.S. EPA's AP-42 document.14  The burners hi the natural gas industry
fall under the industrial furnace category (between 10 and 100 MMBtu/hr of fuel fired).  AP-

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42 shows that uncontrolled methane emissions from natural gas burners in industrial boilers
are three pounds of methane per million cubic feet of fuel.  The accuracy of these numbers is
low, since AP-42 gives the data a rating of "C."

              In general, annual averages of combustion emissions are generated by
estimates of the total gas flow to the burners, combustion efficiency, and flameout frequency
and duration.  The activity factor for this category is the total amount of burner fuel used hi
the industry.  Nationally published numbers are available that show the total annual "lease
and plant fuel use" and "pipeline fuel use," as shown in Table 5-1.1S>16 However,
compressor engine fuel must be subtracted from these totals to determine burner fuel use.
Since there are no nationally available numbers for compressor engine fuel, compressor fuel
use was estimated.

	TABLE 5-1. BURNER FUEL GAS ACTIVITY FACTOR	
                    National Fuel Use                              Ift6 sdt
 "Lease and Plant Fuel" (Gas Facts, Table 3-3)14                               1,070,452
              - Production Compressor Fuel3                                  -219,700
              - Gas Plant Compressor Fuel3                                   -469.500
              - Estimated Burner Fuel (Production)                             381,252
 "Pipeline Fuel Use" (Gas Facts, Table 3-4)15                                  630,083
              - Transmission Compressor Fuel"                                -400,100
              - Storage Compressor Fuel3                                      -53.210
              - Estimated Burner Fuel (T&S)                                   176,773

a Estimated based on HP-hr from Volume 11 on compressor driver exhaust, the AP-42 "CO2
 per HP'hr"  emission factor, and the combustion  equation.4-14
             In addition, gas lift compressors also centime natural gas as fuel. Emissions
from these compressors are considered to be attributed to the petroleum industry, based on
the industry boundaries defined by this project.10 Methane emissions from this source have
not been quantified and subtracted from the natural gas industry emissions.
                                          19

-------
              The burner combustion efficiency was determined by using the AP-42 emission
factors.  The AP-42 emission factor (3 lb/106 ft3) can be converted to a combustion efficiency
as follows:
                 3 Ib CH4     Ibmol CH4    379 ^f             scf CH4
                         4  x  	S x  J/v ^ = 0.000071	            (1)
                106 cf fuel    16 Ib CH4     Ibmol              scf fuel
Multiplying the emission factor by the activity factor yields the emission rate for burners:
                                                         scf CH-                   //Vv
          (381,252 MMscf + 176,773 MMscf) x 0.000071	 =  0.039 Bscf      (2)
                                                         scf fuel
This value is insignificant, and therefore is not listed as an emission source in the total
emissions estimate for this project.

5.2           Flares

              Flares are devices used to provide a safe and economical means of gas disposal
from routine operations, upsets, or emergencies via combustion of the gas. Flares prevent a
controlled release of methane from building up into a large cloud of gas that could explode.
There is a wide variety of flares used in the natural gas industry ranging from small open-
ended pipes at wellheads to iarge, horizontal,  or vertical flares with pilots, such as those at
gas plants.

              Methane emissions from flares result from the  incomplete combustion of gas in
the flare's flame or from time periods where there is no  flame at the flare tip (flame-out) due
to flare  operational problems. Either of these cases results in emissions of non-combusted
methane to the atmosphere.  To determine the total emissions from flares in the gas industry,
two factors must be known:  1) the average methane combustion efficiency of flares
(including flame-out periods) and 2) the total annual amount of natural gas flowing to flares
in the United States.
                                          20

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5.2.1         Combustion Efficiency

              The combustion efficiency of flares is primarily dependent upon the flame
stability which, in turn, depends on the gas velocity, heat content, and wind conditions.
There are many problems in testing industrial flares for combustion efficiency; some of these
include flare (and therefore flame) size,  radiant heat, wind conditions, and proper probe
placement within the flare flame. Therefore, most of the studies have been conducted on
pilot flares, with the results  extrapolated to the larger industrial-size flares. Table 5-2
provides a summary of flare combustion efficiency studies compiled by Pohl and Soelberg.17

              Only two of these studies used natural gas as the flare gas.  The study bj
Straitz has a wide-efficiency range, but instrument problems are also noted. The only oLter
study to use natural gas (Howes) shows an excellent combustion efficiency (>99%).
However, the composition of the natural gas is unknown in Howes' combustion  efficiency.
Although methane is a clean-burning  gas, the composition of the natural gas hi the
production segment can vary substantially.  As shown in Table 5-2, gas streams with
heavier hydrocarbons or with a substantial sulfur content, such as sour gas, result in lower
combustion efficiencies.

              Table 5-2 shows two studies for  open-ended pipes with combustion efficiency
ranges of 90 to 99.9% and 92 to 99.7%.   The lower efficiencies for these studies are due in
part to the lack of features and controls, which are used to ensure flame stability in the
larger,  more  efficient commercial flares.   Another reason for the lower efficiency was that
these two studies were conducted on  heavier gas mixtures that did not include methane  or
natural gas.  In the article by Straitz,  "Flare Technology Safety," the author claims that
typical flare combustion efficiencies are 99+%  for natural gas.18 The author also points out
that the combustion efficiency will be lower for gases with low-Btu heat content (due to
nitrogen, water vapor, or H2S).  Other sources give typical flare efficiencies  as  98 to 99%
as long as the flare is operated within the stability limits of the flame.19'20
                                          21

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                TABLE 5-2.  SUMMARY OF PREVIOUS FLARE COMBUSTION EFFICIENCY STUDIES
                                                                                     16
Study
Palmer
Merget
Straitz
Siegel
Lee&
Whipple
Howes, et al.
McDaniel
Year
1972
1977
1978
1980
1981
1981
1982
1983
1983
Marc
Size
(in)
0.5
47
2-6
17
2
6"
Sat
4C
8
6"
Design
Steam assisted
experimental
nozzle
Full size
Steam and pilot
Commercial flare
gas
Holes in 2" cap
(1.1 in2 open
area)
Commercial air
assist. Zink
STF-LH
Commercial H.P.
Commercial Zink
STF-S-8
Commercial air
assist. Zink
STF-LH-457-5
Gas Fxft
Velocity
(f/s)
50-250
NA

0.7-16
1.8
40-60
Near Sonic
(estimate)
0.03-62
1.4-218
Gas Heating
Value
(Eta^t5)
1448
NA
1000-2350
1500
2190-2385
2385
1000
209-2183
83-2183
Gas Flared
Ethylene
Carbon black
vinyl monomer
Natural gas,
propane
Refinery gasa
Propane
Propane
Natural gas
Propylene/N2
Propylene/N2
Measured
Combustion
Eff. (%)
<97.8
2500:1
reduction
in CO
75-99
97-99
96-100
92-100
>99
67-100
55-100
Comments
Helium tracer for
full-size flare
evaluation
EPA ROSE remote
sensing system
Results of limited
validity due to
instrument range
sensitivity
Multiposition plume
extractive sampling

Both extractive and
EPA RCSE plume
sampling

Extractive and EPA
ROSE plume
sampling

to
                                                                                            Continued

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                                                     TABLE 5-2. (Continued)
Study
Pohl, et al.
Pohl and
Soe'berg
Year
1984
1985
1985
1985
1985
Flare
Size
(in)
3-12
0.042
1.5-
12
0.042
-2.5
3
Design
Open pipe and
commercial
Nozzle
Commercial
coanda steam
injection, pres-
sure assisted, air
assisted, open
pipe, pilot
assisted
Nozzle
Open pipe
Gas Exit
Velocity
(f/s)
0.2-420
31-854
0.2-591
5.6-891
0.15-139
Gas Heading
Yaiwe
(Bta/ft3)
291-2350
923-3320
122-2350
588-2350
145-877
Gas Flared
Propane/N2
25 different gas
mixtures
Propane/N2
Propane/N2
H2S/propane/N2
NHj/propane/N,
1,3 butadiene/N2
Ethylene
Oxide/N2
Measured ..
Ccmbustfofi .
Eff . (%}
90-99.9
>98
( <50-99 99
destruction
efficiency)
36-99.9
NM
92-99.7
(92-99.9
destruction
efficiency)
Comments
Multiprobe plume
extractive sampling
Comparative
screening tests
Comparative com-
mercial flare type
evaluation
Flame aerodynaiu:''
tests
Gas mixture testing
NA~= Not Available
NM = Not Measured
1 50% hydrogen plus light hydrocarbons.
b Supplied through spiders; high Btu gas through area is 5.30 in2 and low Btu gas through 11.24 in2.
0 Three spiders, each with an open area of 1.3 in2.

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              Additional problems exist in the case of open-ended pipes used for flaring in
the production segment of the gas industry.  These flares typically do not have a pilot and
must oe lit manually.  Therefore, the potential exists for the gas to be vented rather than
flared when operating personnel are  not available to light Che fare (i.e., gas vented through a
pressure relief valve to a flare). Much of the flaring done in the production segment occurs
at well completion.  Since operating personnel are always present during this activity, the
volume of gas vented during well completion is small.   In addition, most state agencies
require that any ongoing (post-completion) vent of wellhead gas be burned; the agencies have
field auditors to ensure  that  this requirement is followed.

              On th2 basis that natural gas is predominantly methane (as presented in
Appendix A), a combustion efficiency of 98% was used for the production  segment of the
natural gas industry and 99% for the other industry segments.  A lower efficiency was used
for the production segment to provide a more  conservative estimate of emissions due to  the
variability of the composition of the natural gas as it is extracted from the well.  Both
efficiencies assume the flare to  be operating under optimum  flame ".lability.

              Flame-out in the natural gas industry was assumed to be negligible.  Most gas
processing plants are manned, so that flame-out at the flare would be observed and corrected
quickly. In addition, many of these sites have pilots and/or  igniters that ensure that the
flame remains lit.  For transmission, flare stacks at compressor stations are uncommon,
where they do exist,  they have  pilots and/or igniters that ensure that the flame remains lit.
In the production segment, most flaring from natural gas industry wells is performed either
with operator  supervision or occasionally with piloted flares, so that flame-out is minimal.

5.2.2         lotal Natural Gas Flow to Gas Industry Flares

              There  are no published sources  for the total volume of gas flared in the natural
gas industry.  While the American Gas Association (A.G.A.) does publish natural gas
production and distribution volumes that include a number called "Vented and Flared,"15 this
                                           24

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number does not split the amount vented from the amount flared.  For 1992, A.G.A. report?
167.5 Bscf of natural gas "vented and flared" from production and gas processing.  The
A.G.A. number is derived by a pseudo material balance and includes all gas that is not
marketed, reinjected, or used in the production field.  Therefore, the A.G.A. estimate
includes fugitive gas losses and vented losses, as well as flared volumes. If the A.G.A.
estimate were reduced by the actual amount "vented" to the atmosphere (fugitive + vented
volumes), the result would be the amount of natural gas that A.G.A. assumes is flared.  This
GRI/EPA Study estimates 48.4 Bscf of methane from production and processing fugitive
emissions and 58.9 Bscf ot mciliane from production and processing vented emissions.
Converting the GRI/EPA numbers to natural gas, based on the methane composition for each
industry segment, results in 132.3 Bscf of natural gas as shown  in Table 5-3.
        TABLE 5-3.  NON-COMBUSTED EMISSIONS FROM PRODUCTION
               AND GAS PROCESSING (GRI/EPA ESTIMATE BASIS)
.- . *•
Fugitive Emissions
Production
Processing
Vented Emissions
Production
Processuig
TOTAL
Bsefy Methane

24.0
24.4

53.8
5.1
107.3
Bsefy Natural Gas

30.4
28.1

67.9
5.9
132.3
             If  the difference between the A.G.A. "Vented and Flared" volume (167.5
Bscf natural gas)  and the non-combusted emission volume from this study (132.3 Bscf natural
gas) is assumed to result hi the flared volume, then 35.2 Bscf of natural gas would be flared.
Using a flaring efficiency of approximately 99% (as discussed in Section 5.2.1) and at
average  methane  composition for production and processing of 82.9%, a flared emission rate
can be estimated:
                                        25

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                         0.829 scf CH,    0.01 scf CH. non-combusted                „,,
           35.2e9 scf gas x	  x	 •-= 0.29 Bscf CH,  (3)
                            scf gas            scf CH4 flared                   4

              There are concerns with the accuracy of this approach, in that the "Vented and
Flared" volume report by A.G.A.  is fraught with inconsistencies: it includes items not truly
vented or flared, it does not include all vented and flared volumes (some sources from
production and processing are overlooked, and transmission and distribution sources are not
included), and each state may have different reporting requirements for the number.
Appendix B discusses why this number is  an inaccurate representation of the total vented and
flared volume.

              Selected Method

              Without reasonable nationally-tracked numbers for flaring, site data were
sought.  Most sites, however, did not measure nor track flared volumes.  This was especially
true hi the production segment.  Therefore, an alternate approach was used based on an
assumption that the total amount of gas flared would be equal to half of the total amount
directly vented to the atmosphere by the industry.  Table  5-4 shows the methane volumes
vented hi each industry segment, as presented in Volume 7 (Methane Emissions from Blow
and Purge Activities).9 Using the flaring efficiencies for each industry segment discussed
earlier,  a flare emission rate can be calculated by  multiplying the assumed flow by the
combustion inefficiency term.

              As shown hi Table 5-4, this alternate approach produces an estimatt  of 15.2
Bscf of natural gas  flared, which is significantly smaller than the A.G A. approach.  Since
the A.G.A. approach is believed to overstate the flared amount, this alternate approach was
selected.
                                           26

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                   TABLE 5-4. MAXIMUM FLARING EMISSIONS
Industry Segment
Production
Gas Processing
Transmission and
Storage
Distribution
TOTAL
Assumed
Mow to Flare/
Bsef FSaring Efficiency
0.5 (6.6 ± 329%)
0.5 (3.0 ± 262%)
0.5 (18.5 + 177%)
0.5 (2.2 ± 1,783%
15.2 + 185%
98%
99%
99%
99%

Maximum Annual
Methane Emissions
from Flaring,, Bscf
0.066 i 329%
0.015 ± 262%
0.093 + 177%
0.011 + 1,783%
0.185 ± 183%
The methane volume is assumed to be equivalent to half the vented quantity, where tne vented volumes are
reported in the Blow and Purge Report.9
              With either calculation approach, the estimated annual emissions from flares
are negligible (less than 0.3 Bscf), and may be conservatively high, given the problems built
into the A.G.A. number and that the flow to natural gas industry flares flare may be
overestimated in the second approach.  Therefore, this small category does not show up as an
itemized contribution to total emissions in this report.
5.3
Af 'd Gas Recovery Vents
             Acid Gas Recovery (AGR) vents are a very minor som-ce of methane
emissions and account for only 0.82 Bscf of methane emissions.  AGR systems are used to
remove acid gases (H2S and CO2) by contacting the stream with a solvent (usually amines)
and then driving the absorbed components from the solvent.  Tne amines can also absorb
methane and, therefore, methane can be released to the atmosphere through the reboiler
vent.
                                          27

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             Methane emissions were calculated using an ASPEN PLUS™ process
simulation.  The disposition of AGR vent gas and the number of AGR units were taken
from an API survey of U.S. Natural Gas Reserve Demographics.21  The following
assumptions were used in determining the emission rate:  1) AGR units do not use flash
drums  or stripping gas; 2) AGRs have an absorption of methane similar to water;  3) the
total number of AGR units in the United States are in the gas processing segment; and 4)
82% of AGR emissions are controlled (18% of the emissions are vented).

5.4          Salt Water Tanks

             Methane emissions from production salt water tanks were estimated using  an
ASPEN PLUS* process simulation. The flash calculations were based on the following
assumptions:

             1)     The natural gas industry produces 497 million barrels of salt water
                    annually, of which approximately  100 million barrels are from coal
                    bed methane wells.22
             2)     70% of the water from gas  wells is reinjected, leaving 30% of the
                    water stored in atmospheric tanks.22
             3)     The hydrocarbon composition is  100% methane.

             The flash calculation results are summarized in Table 5-5 for cases with the
salt content  varied from 2 to  20%, and the pressure varied from 50 psi to 1000 psi.  The
simulation results indicate that methane emissions from salt water tanks are negligible.
* ASPEN PLUS™ is a registered trademark of Aspen Technology, Inc.
                                          28

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                   TABLE 5-5.  SALT WATER  TANK EMISSIONS
Salt Content, Wt %
20% Salt


10% Salt

2% Salt

Pressure, psi
50
250
1000
250
1000
250
1000
Methane Emissions,
106 Ib/yr
1.6
10.8
38.8
16.4
58.7
19.4
69.5
Methane
Emissions,
Bscf
0.0
0.0
0.0
0.0
0.0
0.0
0.0
5.5
              Drilling operations typically use hydraulic pressure from the drilling mud to
keep the oil and gas in the formation while drilling.  The  intent is to prevent the
uncontrolled flow of oil and gas up the \vcll bore (a potential blowout) until the surface
equipment is ready  to receive the material.  Drilling  mud  does absorb some gas and releases
it in the degasser at the surface.  The quantity is typically small and has been excluded  for
this project.

              Blowouts during drilling or completion can  be a large individual  source of
emissions, since the formation flows uncontrolled to the surface.  The drilling industry has
developed procedures and devices throughout the evolution of oil and gas production to
prevent such an event. As a result, blowouts today are very infrequent and have not been
considered.

              Once the desired formation or depth is hit, the well must be "completed"
before it can be produced.  Less expensive  tubing replaces the strong  drill string and an
outer annular casing is cemented in place.  The casing has many uses. It prevents the
formation from caving in around the tubing, allows easier well maintenance, and allows
                                          29
offer data supporting the decision not to use the reported V&F numbers in this GRI/EPA

-------
onshore, dead (no surface pressure) oil wells to produce o^l up the tubing string "aid gas up
the outer casing.  If the oil ind gas were produced in the labing, the pumps would become
vapor locked.

              Once the casing is in place, it is perforated and the formation begins to flow
into the well. A clear completion fluid is used (heavy salt water) instead of mud, and the
completion fluid  will flow or be pumped to surface tanks or pits.  Again, some small
amount of gas may evolve from the completion fluid, but it is typically insignificant.

              After the completion fluid is out of the well, oil and/or gas flow begins.
Depending on the type of we!!, the gas may be vented, flared, or immediately produced.  If
the well was drilled  in a known field v ith other existing wells, it is called a Developmental,
or an Infill well.  In that circumstance, the reservoir  pressure  and size are already defined,
and the operator  can have production meters  and equipment sized and hi place for
completion.   Very little venting and flaring would occur at completion, if any.

              If the well was an exploratory  "discovery" well (i.e., one drilled hi a new
area of unknown reservoir potential),  facilities may not be ready for the well's production.
The well is flared for the time that it takes to measure the flow rates so that equipment can
be sized.  This period is referred to as completion, completion flaring, or well testing.
Emissions from completion flaring are minimal but are included hi the blow and purge
emissions.9

5.6           Drips

              Some  longer sections of gas-gathering  and transmission pipelines may have
small liquid collection pots L. cated along the line. These pots are periodically blown down
to clear collected hydrocarbon condensate, and the blowdown vents methane directly to the
atmosphere.   An  unaccounted-for (UAF) gas study by Pacific Gas and Electric (PG&E)
                                          30
Finally, given weaker enforcement, more unrerorted quantities will exist.  Some of the state-

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defined drip blowdown emissions under unmetered company gas usage,23  They found the
category to be insignificant, at 0.00035% of their total throughput.

5.7          Sampling

             Gas is consumed in sampling and analyzing  gas for composition and heating
value.  Much of this gas is then emitted to the atmosphere  from the on-line analyzers or
from the sample containers.  Most sampling efforts begin in the gas processing areas, and
field sampling represents  a small fraction of the total samples.  The PG&E UAF gas project
estimated this category as insignificant, at 0.00107% of their total throughput.23
                                          31
plant has orifice meter readings near zero, is not considered in the calculation of the reported

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6.0          REFERENCES
1.           Hummel, K.E., L.M. Campbell,  and M.R. Harrison. Methane Emissions from
             the Natural Gas Industry, Volume 8: Equipment Leaks, Final Report, GRI-
             94/0257.25 and EPA-600/R-96-080h, Gas Research Institute and U.S.
             Environmental Protection Agency, June 1996.

2.           Campbell, L.M. and B.E. Stapper. Methane Emissions from the Natural Gas
             Industry, Volume 10: Metering and Pressure Regulating Stations in Natural
             Gas Transmission and Distribution, Final Report,  GRI-94/0257.27 and EPA-
             600/R-96-080J, Gas Research Institute and U.S. Environmental  Protection
             Agency, June  1996.

3.           Campbell, L.M., M.V. Campbell, and D.L. Epperson.  Methane Emissions
             from the Natural Gas Industry, Volume  9: Underground Pipelines, Final
             Report,  GRI-94/0257.26  and EPA-600/R-96-080i,  Gas Research Institute and
             U.S. Environmental Protection Agency,  June 1996.

4.           Stapper, C.J.  Methane Emissions from the Natural Gas Industry, Volume 11:
             Compressor Driver Exhaust, Final Report, GRI-94/0257.28 and EPA-600/R-
             96-080k, Gas Research Institute and U.S. Environmental Protection Agency,
             June 1996.

5.           Picard, D.J., B.D. Ross,  and D.W.H. Koon. "A Detailed Inventory of CH4 and
             VOC Emissions From Upstream Oil and Gas Operations in Alberta."
             Canadian Petroleum Association, Calgary, Alberta, 1992.

6.           Shires, T.M. and M.R. Harrison.  Methane Emissions from the Natural Gas
             Industry, Volume 12: Pneumatic Devices,  Final Report, GRI-94/0257.29 and
             EPA-600/R-96-0801, Gas Research Institute and U.S.  Environmental
             Protection Agency, June  1996.

7.           Radian Corporr^on.  Glycol Dehydrator Emissions: Sampling  and Analytical
             Methods and L^.tmation  Techniques. GRI-94/0324, Gas Research Institute,
             Chicago, IL, March 1995.

8.           Shires, T.M.  Methane Emissions from  the Natural Gas Industry,  Volume  13:
             Chemical Injection Pumps, Final Report, GRI-94/0257.30 and EPA-600/R-96-
             080m, Gas Research Institute and U.S.  Environmental  Protection Agency,
             June 1996.
                                         32
               ratio  Nn actual measurements are used for P-l or P-2 reported values,

-------
9.           Shires, T.M. and M.R. Harrison.  Methane Emissions from the Natural Gas
             Industry, Volume  7: Blow and Purge Activities, Final Report, GRI-94/0257.24
             and EPA-60Q/R-96-080g, Gas Research Institute and U.S. Environmental
             Protection Agency, June  1996.

10.          Stapper. B.E. Methane Emissions from the Natural Gas Industry,  Volume 5:
             Activity. Factors, Final Report, GRI-94/0257.22 and EPA-600/R-96-080e, Gas
             Research Institute and U.S. Environmental Protection Agency, June 1996.

11.          Myers, D.  Methane Emissions from the Natural Gas Industry, Volume 14:
             Glycol Dehydrators, Final Report, GRI-94/0257.31 and EPA-600/R-96-080n,
             Gas Research Institute and U.S. Environmental Protection Agency, June
             1996.

12.          Myers, D.B. and M.R. Harrison. Methane Emissions from the Natural Gas
             Industry, Volume  15: Gas-Assisted Glycol Pumps, Final Report, GRI-
             94/0257.33 and EPA-600/R-96-080o,  Gas Research Institute and U.S.
             Environmental Protection Agency, June 1996.

13.          Biederman, N.  GRI TRANSDAT Database:  Compressor Module,  (prepared
             for Gas Research  Institute),  npb Associates with Tom Joyce and Associates,
             Chicago, IL, August 1991.

14.          U.S.  Environmental Protection Agency. Compilation of Air Pollutant
             Emission Factors, U.S. EPA Office of Air Quality, Planning, and Standards,
             AP-42, Fifth Edition, Research Iriangle Park, NC, January 1995.

15.          American Gas Association.  Gas Facts:  1990 Data,  (Table 3-3), Arlington,
             VA,  1991.

16.          American Gas Association.  Gas Facts:  1993 Data,  (Table 3-4), Arlington,
             VA,  1994.

17.          Pohl, J.H. and N.R.  Soelberg. "Evaluation of the Efficiency of Industrial
             Flares:  H2S Gas Mixtures and Pilot Assisted Flares," EPA-600/2-86-080
             (NTIS PB87-102372),  September 1986.

18.          Straitz, J.F., III.  "Flare Technology Safety," Chemical Engineering Progress,
             Volume 83, No. 7, July 1987, pp. 53-62.

19.          Romano, R.R. "Control Emissions with Flare Efficiency,"  Hydrocarbon
             Processing. Volume  62, No.  10. October  1983, pp. 78-80.
                                         33
wells.  For that reason, there is a significant quantity of casinghead gas produced.  In Texas,

-------
20.          Pohl, J.H., J. Lee, R. Payne, and B. Tichenor.  "Combustion Efficiency of
             Flares," 77th Annual Meeting and Exhibition of the Air Pollution Control
             Association, San Francisco, CA, June 24-29, 1984.

21.          American Petroleum Institute.  Survey of U.S. Natural Gas Reserve
             Demographics,  Washington,  DC, 1992.

22.          Energy Environmental Research Center, University of North Dakota, and
             ENSR Consulting and Engineering.  Atlas of Gas Related Produced Water
             for 1990.  Gas  Research Institute, 95/0016, May 1995.

23.          Pacific Gas & Electric Company.  "Unaccounted-For  Gas Project."  Volume
             1, 1989.
                                         34

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   APPENDIX A




Methane Composition
        A-l

-------
                                    APPENDIX A
                             METHANE COMPOSITION

       The composition of methane in natural gas is needed to calculate methane emissions
from natural  gas that is emitted to the atmosphere.  This section describes the characteristics
of natural gas streams in production, processing,  transmission, and distribution.  The
methane composition for each segment is presented in Table A-l.

        TABLE A-l. METHANE COMPOSITION  BY INDUSTRY SEGMENT
                    Segment                               Methane (volume %)
                   Production                                    78.8 ±  5%
                 Gas Processing                                  87.0 ± 5%
              Transmission/Storage                               93.4 ± 1.5%
                  Distribution                                   93.4 ± 1.5%
       Production Segment - The production segment of the gas industry includes natural
gas produced from gas wells (non-associated) and oil wells (associated).  Data from the
United States Bureau of Mines, Division of Helium Field Operations,  and A.G.A. Gas
Facts were used to calculate the production methane composition.1>2  The Bureau of Mines
(BOM) has been collecting analytical data from oil and gas wells and natural gas pipelines
since 1917 in an effort to locate sources of helium. Under another GRI project, all
published BOM data through 1987 were obtained on magnetic tape and loaded it into an
Empress® database.3  The focus of this earlier project was to  determine the  major
contaminants in sour natural gas, specifically, hydrogen sulfide and carbon dioxide. Over
14,000 records  were used to determine county and state averages for natural gas
composition, including methane content.

       The BOM data were corrected  since a few non-gas industry wells that have very
high helium or  carbon dioxide content with little or no methane were  included hi the data

                                         A-2

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set.  For the largest producing states,  the Empress data files were reviewed and the entries
with less than 40% methane were removed. Table A-2 shows the average methane content
and marketed  production by state. This information  was regionalized to estimate the
national average methane content of 78.8 mol %  ± 5% as shown  in Table A-3.

       Gas Processing Segment - The only source of methane data identified for the
processing segment is from the Gas Engineer's Handbook* These data are from November
1951 and consist of eight data points with only two states,  California and Texas,
represented (see Table A-4).  The data are  reported as "after processing plant" and were
assumed to represent  typical speciation data for natural gas leaving this industry  segment.
Due to the limited data set, an average methane content was calculated instead of a
weighted average based on the state's fraction of U.S. production.  The average methane
content for the processing segment is  87 mol ->ercent.  A 90% confidence  interval  of 5%
was calculated based  on the spread of the available data.

       Transmission  and  Storage Segments - The methane composition  for transmission
and storage was based on the GRI TRANSDAT database,5  which has analyses of fifty fuel
gas samples from various transmission compressor stations.  Since the  fuel gas is from the
pipeline, these  should represent transmission gas quality. The  resulting average methane
composition for transmission  is 93.4 mol%  ± 1.5% (90% confidence interval is based on
the spread  of data).

       Distribution Segment - The Gas Engineer's  Handbook provided methane
composition data for the distribution segment.4  This data set 'acludes distribution  ir: 48
cities, representing 29 states and the District of Columbia. i:;-~  the f;xT. of 1062.  A weJghK ."
average was not used for this industry segment sinu; 1'rc 
-------
       The composition of gas leaving the processing  segment should agree with the
methane composition in the transmission and distribution segments, since the gas is only
transported or stored.  However, the distribution value is less than the methane composition
determined for the transmission segment.  Because the transmission data are based  on the
more recent and more extensive data source, the same composition is used for distribution.
Therefore, the distribution  methane composition used in determining emission factors is
93.4 vol % ± 1.5%.
   TABLE A-2.  AVERAGE  STATE METHANE  CONTENT AND PRODUCTION
                                       RATE
Region
Gulf Coast




Central Plains










Pacific and Mountain




Atlantic & Great
Lakes







States"
AL
FL
LA
MS
TX
AR
CO
KS
MO
MT
ND
NE
NM
OK
SD
WY
AK
AZ
CA
OR
UT
IL
KY
MI
NY
OH
PA
TN
VA
WV
Methane Composition,
Volnme %
86.4
60.2
87.8
79.8
75.1
87.7
65.4
69.4
69.4
69.4
62.5
53.4
64.4
79.8
—
69.9
76.5
—
75.3
._
-
86.2
76.2
74.4
90.0
82.0
91.0
85.2
88.0
86.9
1989 Marketed Gas
Production, Bscf
151
• 8
5,087
165
6,401
174
227
601
4
51
56
1
856
2,237
4
756
394
1
364
3
120
2
72
156
20
160
192
2
18
177
  States not shown had insignificant 1989 marKeted gas production rates.
                                        A-4

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        TABLE A-3. METHANE COMPOSITION OF PRODUCTION GAS
     Region
Volume Percent Methane (from
state vol %'s weighted by state
         production)
          Comments
Gulf Coast

Central Plains
Pacific and
Mountain

Atlantic and Great
Lakes
            80.76

            73.68



            75.92


            83.59
All states but GA represented

Some states with insignificant
production were excluded (IA,
MN)

Alaska and California only
Some states with insignificant
production were excluded (CT,
DE, IN, MA, MD, ME, NC, NH,
NJ, RI, SC, VT, WI)
Total U.S.
            78.8
Weighted average by regional
production
        TABLE A-4. METHANE COMPOSITION IN GAS PROCESSING
                 Location
                              Methane Composition, Vol %
CA, Kettleman North Dome
CA, Ventura
TX, Agua Dulce
TX, Carthage
TX, Hugoton
TX, Keystone
TX, Panhandle
TX, Wasson

Average
                                         93.0
                                         92.7
                                         93.0
                                         91.7
                                         79.0
                                         86.2
                                         81.5
                                         76.9

                                         86.8
                                     A-5

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REFERENCES:

1.     U.S. Bureau of Mines. Analyses of Natural Gases, 1917-1987.  6 vols. Helium Field
       Operations, Amarillo TX.  February 1988 (magnetic tape and hard copy).

2.     American Gas Association.  Gas Facts:  1990 Data, (Table 3-3), Arlington, VA,
       1991.

3.     Radian Corporation.  Investigation of U.S. Natural Gas Reserve Demographics and
       Gas Treatment Processes, Topical Report. Gas Research Institute, January 1991.

4.     "Natural Gas from Various Gas Fields (As of November 1951)," Table 2-12,  Gas
       Engineers Handbook, Industrial Press Inc., New York, NY, 1977.

5.     Biederman, N. GRI TRANSDAT Database:  Compressor Module,  (prepared for
       Gas Research Institute) npb Associates with Tom Joyce and Associates, Chicago, IL,
       August 1991.
                                        A-6

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         APPENDIX B




Reported "Vented and Flared" Data
             B-l

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                                    APPENDIX B
                    REPORTED "VENTED AND FLARED" DATA

       National numbers for "vented and flared" volumes are reported by production and
processing companies to state agencies, which then report to the Department of Energy
(DOE) Energy Information Administration (ElA).  Gas Facts publishes this EIA national
number for "venting  and flaring" (V&F) at approximately 0.71% of the total natural gas
production.1 Initially, it was assumed that the reported V&F number was valid, and the
approach for this project focused on simply splitting this number into a vented  volume and a
flared volume, so that vented emissions could be accurately quantified. However, this study
discovered that the reported V&F number has many problems, and it is not a useful measure
of actual venting or flaring.

       The reported numbers do not represent actual "vented and flared"  quantities of gas,
since companies do not use a standard practice or protocol for determining their V&F
amount.  In fact, many sites use a protocol  that results in an erroneous value for V&F.
Many gas plants simply report all material balance  discrepancies as "vented and flared," even
though most material balance losses are due to other factors, such as metering inaccuracies.
Other companies have operators simply guess the amount of gas vented or flared in order to
fill out a state form.  Very few sites actually measure or accurately calculate V&F volumes.
Even if the reported V&F volumes were accurate, there is not a reliable method of splitting
the number into the amounts flared (burned) and  the amounts vented.  Furthermore, there is
no method for separating the amount of vented, unmarketed natural gas attributable to oil
production.

       The GRI/EPA project abandoned use of the reported V&F number, and turned to a
technique that identified each source of vented emissions, and estimated emissions from each
source type. This technique  is described in more detail hi Volume 3  on general
methodology.2 This appendix discusses the problems with the  V&F numbers reported by
operators to various state and federal government agencies.  This section  is only intended to

                                        B-2

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offer data supporting the decision not to use the reported V&F numbers in this GRI/EPA
project.  Sources of data for the United States and for individual states, as well as the quality
of the data are covered in detail in the  following subsections.

B.I    Specific States

       Specific state data were analyzed for Texas, Oklahoma, and Louisiana. These thres
states comprise 68% of all the gas produced in the U.S. in 1989 and are representative of gas
production facilities.  States that are major producers of oil and gas generally have state
governmental  agencies that regulate and maintain data on the oil and gas industry.  The
regulating agencies for Texas, Louisiana, and Oklahoma are the Texas Railroad Commission
(RRC),  the Louisiana Department of Natural Resources (DNR), and the Oklahoma
Corporation Commission, respectively.

       The primary goal of these agencies is to control the industry (provide "fair play" for
all operators), collect fees, and protect  the community and the environment.   Methane
emissions have not been a concern for these agencies except where the emitted methane
represents 1) an unnecessary waste of natural resources that should come out of a company's
"allowable" production quota; 2) a toxic gas hazard (H2S); or 3) a fire or explosive hazard.
To the extent that methane emissions represent a measurable loss of natural resources, the
agencies track data on "venting and flaring." For many agencies,  the V&F numbers are
grouped together.  No differentiation is made between amounts actually burned versus
amounts vented; however, there is one  exception.  Permits filed under Rule 32 in the Texas
RRC code do  differentiate between venting  and flaring.

       The accuracy and extent of the reported V&F numbers are  a iqunction of the V&F
definition the state uses in the reporting regulations, the state's  enforcement of report' g
regulation, and the exclusions that the  state allows.   Given a broader definition, more
emissions are  included; however, given more exclusions, fewer events will be reported.
                                          B-3

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Finally, given weaker enforcement, more unrepor~d quantities will exist.  Some of the state-
specific data are discussed below.

B.I.I  Texas

       For Texas, most of the V&F numbers are reported as one number to the RRC on a
monthly basis.  Gas plant operators send in R-3 forms, and oil and gas producers send in P-l
and P-2 forms, respectively.  Oil wells are tracked by the lease, and gas wells are tracked by
the individual well. The data from these forms are summed into tables in the RRC's
published Oil and Gas Annual Report.3  The RRC also requires a permit for flares or vents
lasting more than 24 hours in the R-32 form.  The specific  forms are discussed in more
detail below.

       Among the states, Texas probably has the strongest regulations, the strongest enfor-
cement, and the most comprehensive published data.  Nevertheless, the reported vented and
flared numbers in Texas are difficult to assess; there are areas over-reported and under-
reported due to definition. Amounts vented from compressor engine exhausts, pneumatic
actuators, glycol vents, and acid gas recovery vents have never been considered as part of
the V&F definition for reporting.  In addition, the definition of V&F is different even among
the various RRC forms.

       R-3 Gas Plants - For  gas plants,  the V&F number on the R-3 is simply the result of
a material balance closure around the gas plant.  The rule is:

                 GAS IN - PRODUCTS OUT - CONSUMPTION = V&F

Measured outlet dispositions (pipeline gas,  fuel, extraction loss, etc.) are subtracted from the
inlet, plant meter,  and the difference is reported as V&F.  The difference is really just an
"unaccounted-for" (UAF) number arrived at by an accounting procedure; it is usually
positive and hi the range of 0.3% of the total gas processeu. The flare, which in the gas
                                         B-4

-------
plant has orifice meter readings near zero, is not considered in the calculation of the reported
V&F number.

       If the gas plant material balances are absolutely accurate (all quantities included are
on the same basis) and have a zero meter bias (doubtful, but possible), then the reported
V&F number, even though a calculated value, is a true "emitted, vented, or flared" amount.
From the V&F number, the flare meter reading could be subtracted, the fugitive emissions
subtracted, and the remarking value would be material actually vented.  This is the "top-
down" yardstick that the "bottom-up" emissions rates for gas plants can be compared to.

       R-3 Cycling  Plants (Pressure Maintenance) - Cycling plants process gas to reduce
the dew point of condensibles in the formation and thus extend the life of a field. In most
cases, not all of the  gas is returned to the formation in a cycling plant.  Again, data from the
Texas Railroad Commission indicate that for the 15 pressure maintenance facilities in Texas,
51.6% of the residue gas is used for repressurizing or cycling, while 26.6% is sent to
transmission pipelines.3  It should be noted also  that the V&F  estimate for cycling plants is
0.3% of the total gas processed, which is the same as for gas  plants.

       P-l, P-2 Production -  A P-l report is generated for each oil lease and a P-2 report
for each gas well. For production facilities, V&F on the P-l and P-2 reports is meant to
represent a real vented and flared quantity at the wellhead.   Nevertheless, many releases are
exceptions to the reporting requirements, including: well completion flaring for up to 10
days, events less than 24 hours in duration, well cleanups,  and venting and flaring from
certain field equipment (glycol separators and pneumatic devices). This excludes many of
the true release events from the numbers recorded by the RRC.

       Even the accuracy of the categories that are included in reporting is questionable.
Production flares have no pilot and no meter, so reported values are operator estimates.  The
operators generally base their estimates upon the most recent well test data or upon the
                                          B-5

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field's gas-to-oil ratio.  No actual measurements are used for P-l or P-2 reported values,  and
the RRC admittedly has no way to verify the reported values.

       There are so many exceptions and estimations in the reported production numbers  that
it is impossible to intuitively tell whether the number is over- or under-reported.  As with
gas plants, a method that does not use the reported V&F numbers must be used to estimate
real production emissions.  The reported numbers can then be adjusted to use only as a check
value for the bottom-up calculations.

       Rule R-32 - The Texas RRC Rule 32 does have some impact on the V&F amounts.
The rule allows 10 days of venting following completion of a well, and then requires all gas
to be  flared.  In addition, permits are required for flares  or vents beyond initial completion
(exceptions are well cleanups or repairing/modifying a gas-gathering system).  The permit
fcrm  has one very useful piece of data:  a designation of venting that is different from
flaring. The form is the only place hi the reported V&F category where the operator must
designate whether he intends to vent or to flare for the specific release permit.

       The RRC  tracks Rule 32 permits to make sure that sour gas is burned and that large
vented releases are not near major roadways nor populated areas. Releases of unburned sour
gas can be toxic,  and large vented releases can be explosion or fire hazards.   The R-32 d'tfa
were used for  this project to establish a percentage split between vented versus flared for  all
the  production V&F totals that are reported.  The data were reviewed for 1991 permits and
showed that the amount vented was  7.7% and the amount flared was 92.3%  of the total
V&F. However, the assumption that the non-permitted quantities have the same split may be
incorrect,  since events less than 24 hours and well cleanups are exceptions.  Therefore, many
venting events may not be part of these data.

       Oil and Gas Annual Report - With all of the above limitations in mind, the data
from  annual reported values were analyzed. Most of the reported venting and flaring
volumes were  for casinghead gas (oil well gas).  There are many more oil wells than gas
                                         B-6

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wells.  For that reason, there is a significant quantity of casinghead gas produced. In Texas,
23% of all gas produced is casinghead gas.

       Of the total reported V&F amounts,  V&F from casinghead gas at the well accounts
for 47.5%, while V&F from gas at the well accounts for only 5%. Gas well gas V&F is
likely under-reported, since well cleanups are not reported.  The data show that a dispro-
portionate amount of the reported V&F is due to casinghead gas.  The remainder of the
reported V&F amounts is due to V&F reported at gas plants. This accounts  for 47.5% of
the reported total V&F amount.

       These data show that gas wells typically vent or flare infrequently.  This makes sense
from an economic point of view, since vented gas represents a direct loss of  the well's only
revenue. Casinghead gas (oil well gas) is vented or flared more frequently.  Gas lost
through V&F at oil wells is also a loss of revenue but on a much less significant scale.  The
oil revenue is typically much larger than the gas revenue.

       Casinghead gas that is V&F may be  from wells that never produce gas to a pipeline
and, therefore, should not be considered part of the gas industry emissions.   Those wells
would either consume all of the produced gas as lease fuel, reinject all of the gas, or
vent/flare all of the gas.  Summing those three disposition categories for the  RRC's
casinghead gas annual table shows that 4.3% of the total casinghead gas is used for those
purposes.  If all  oil wells had identical gas production, this would mean that  the maximum
amount of oil wells that should be excluded is 4.3%.  For a more exact answer, the number
of oil wells that do not market gas must be known.

       The reported V&F numbers for Texas imply that 0.53% of all gas produced is vented
or flared.  However, the following problems are associated with the Texas statistics [pluses
(+) are shown for comments that would raise the reported numbers when corrected, and
minus (-) symbols are shown for items that would reduce the reported numbers]:
                                         B-7

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       (-)     Approximately one-half of the V&F amount is due to gas plant V&F, which is
              an accounting closure number and not really venting and flaring.  Even if a
              gas plant material balance is assumed to have  a zero bias, fugitives should be
              subtracted from the V&F numbers reported.

       (-)     Nearly half of the reported venting and flaring gas is from casinghead gas.
              Some of this casinghead gas is associated with oil wells that do not produce to
              a gas pipeline, and that fraction is,  therefore,  not part of the natural gas
              industry  as defined by this project.  This amount could be excluded if a
              defensible basis were derived to separate those wells.

       (-)     Venting and flaring permit rates are usually overestimated (in the RRC's
              opinion)  because many of the producers do not want to apply for permit
              exceptions if the rate increases.

       (+)    Many events are exempted from the reporting rules (such as well cleanup, well
              completion, and events less than 24 hours).

       (+)    Some oil wells that produce associated or dissolved gases do not report V&F.

       (+)    Emissions from tank batteries, glycol dehydrators,  AGRs, and other
              miscellaneous sources are not reported.
Therefore, even though Texas' reported V&F numbers appear to give an overall emission

estimate for V&F emissions, they cannot be used as a quantitative measurement.


B.1.2  Louisiana


       The Louisiana Department of Natural Resources (DNR) tracks V&F in a mariner

similar to the Texas RRC.  Operators report the monthly production (wellhead) disposition

data on the R-5D form and the gas plant data on the R-6 form.  The DNR,  like the Texas

RRC, compiles all of the monthly data on computer files.  The DNR, however, only makes

the data available through specific, standardized computer runs which must be pre-paid by

the requestor.
                                         B-8

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       Radian has not requested Louisiana runs; however, Louisiana provided the 1988
Parish Report during a visit to the DNR.  The report showed a total onshore V&F number
similar to Texas,  at 0.47% of total gas production (Texas was 0.51%).

       Louisiana's definitions of venting and flaring for reported numbers appear to be
similar to Texas;  and, therefore, Louisiana data will have the same problems that were
described for the Texas data.  Louisiana also has no method of separating the split between
vented and flared quantities from the single V&.F numbers reported on the R-5D and R-6
forms. In fact, the term "venting," such as the "vented" column on the R-6 form, refers to
venting or flaring.

       Although Louisiana does not have a Rule 32 flare permit requirement as Texas does,
it has a Statewide Order 45-1 that require? a semiannual status report, which lists casinghead
and natural gas "vented" by lease and explains why the gas is not being recovered.
Unfortunately, the DNR does not aggregate these data; the data are received in nonstandard
letter format and stored as received. It would be very difficult and time-consuming to
assemble all of "hese data into a meaningful form.  For example, Radian's examination of
three 45-1 status reports indicated very different results as shown in Table B-l.

                   TABLE B-l.  COMPARISON OF 45-1 REPORTS
      Company
Type of Gas
Reason for Venting
 Mid-size company     Casinghead gas
                Uneconomical to recover.  Most vent points were low-
                pressure heater treaters.  Some fields used intermittent
                gas lift, thus, consuming all of the produced gas
                intermittently.
Large company
Small company
Unknown
Unknown
Majority of emissions were from compressor
downtimes.
Compressor downtimes.
                                         B-9

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B.I.3  Oklahoma

       The Oklahoma Corporation Commission's Oil and Gas Conservation Division issues
venting and flaring permits.  However, only rates above 50 Mcfd require a permit, and few
wells fall into that category.  The permit file for 1991 had only nine permits issued as  shown
in Table B-2.

             TABLE B-2.  1991 FLARING PERMITS FOR OKLAHOMA
Number of
Permits
6
1
2
Percent of Total
Permits
67
11
22
Season for Request
Recover load water from gas well (well

clean-up).
H2S found, pulled from gathering system and flared.
Other (unknown)

       Oklahoma appears to have significantly fewer reporting requirements than Texas or
Louisiana and had no other data on V&F available. Interestingly, Oklahoma does not appear
to exclude well cleanups from the permit requirements as Texas does. As shown above, well
cleanups constitute a large percentage of the permits issued in Oklahoma.

B.2    United States

       There are several sources of information gathered on the natural gas industry for the
entire United States.  These sources include federal agencies, such as the Federal Energy
Regulatory Commission (FERC) and the Department of Energy (DOE), and gas industry
representatives, such as the American Gas Association (A.G.A.).  Numerous publications are
compiled by these agencies and include information on gas industry financials, gas
production and disposition, and gas storage and reserves.  Data are also collected from
regulatory agencies and other private agencies, such as the American Petroleum Institute
(API).
                                        B-10

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       There are five FERC forms that deal specifically with the natural gas industry.  The
main form completed by gas companies regulated by FERC is the FERC Form No. 2,
"Annual Report for Major Natural Gas Companies." This form is an annual requirement for
major gas companies, which are defined by the FERC as "having combined gas sold for
resale and gas transported or stored for a fee exceeding 50 Bcf (at 14.73 psia 60°F) in each
01 the three previous calendar years."  Most of the information collected on this form is
financial and, therefore, does not contribute to the data gathering effort for V&F.  The other
FERC forms collect information on underground storage (FERC-8), gas pipelines (FERC-
11,-15), and gas supply (FERC-16),

       The Energy Information Administration (EIA) of the DOE, publishes many reports on
the natural gas industry. One of the most useful publications  is the Natural Gas Annual*
Two EIA forms provide most of the information used in this report; EIA-176, "Annual
Report of Natural and Supplemental Gas Supply and Disposition," and EIA-627, "Annual
Quantity and Value of Natural Gas Report." The EIA-176 is  a mandatory form to be
completed by all companies that deliver natural gas to consumers or transport interstate gas.
The EIA-627 is a voluntary form completed by energy or conservation agencies in gas-
producing states.  Other sources of information used by EIA for the Natural Gas Annual
include  the FERC, the United States Geological Survey (USGS),  and the Interstate Oil
Compact Commission (IOCC). Information directly from the USGS and the IOCC has not
been gathered for this venting and flaring task.

       The Natural Gas Annual provides information on gas production, transmission, and
consumption for the United States as a whole and for each gas-producing state individually.
Included in this report are numbers for gas V&F.  Both the EIA-176 and the EIA-627 collect
gas V&F information.  Since these data are taken directly from the responsible state
agencies, any differences in reporting requirements and/or the definition of vented and flared
are not accounted for in this publication. Some of these differences were identified in the
previous sections on individual state reporting.  The EIA is aware of this inherent problem,
but it is not known if the agency adjusts the data to reflect these differences.
                                        B-ll

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       The A.G.A.'s Gas Facts is an annual publication containing data on the gas utility
industry.  The data concentrate  on gas distribution and transmission but also include some
information from the gas-producing segment of the industry.  Most of the information is
gathered by the A.G.A. in its survey entitled "Uniform Statistical Report.  The only
information on venting and flaring provided in the Gas Facts was taken from the EIA
Natural Gas Annual.  Again, this  information is just a reiteration of the numbers reported by
the responsible state agencies with the  inherent problems already discussed.  A summary  of
the national statistics in Gas  Facts is shown in Table B-3.1

       It appears that any data which are derived from an overall United States approach are
just a summation of the data reported by the individual gas-producing stales.  Due to the
variability in  these data, the  task of characterizing V&F in the natural gas industry should
follow a bottom-up approach and begin with the identification of the individual sources.
Then, respective methane emission estimates could be calculated and added to determine the
overall emission number  for  the entire  United States.

REFERENCES
1.     American Gas Association: Gas Facts:  1990  Data, (Table 3-3), Arlington, VA,
       1991.
2.     Harrison,  M.R.. H.J. Williamson, and L.M. Campbell.  Methane Emissions from the
       Natural Gas Industry, Volume 3: General Methodology, Final Report, GRI-
       94/0257.20 and EPA-600/R-96-080c, Gas Research Institute and U.S. Environmental
       Protection Agency, June 1996.
3.     Texas Railroad Commission.  Oil and Gas Annual Report, Volume 1  "Cycling Plant
       Operations hi Texas," Data Source: RRC Form R-3,  1991.
4.     U.S. Department of Energy.  "Quantity  of Natural Gas Used as  Lease Plant Fuel  by
       State," Natural Gas Annual 1992, Volume 1.  Energy Information Administration,
       Office of Oil and  Gas, U.S. Dept. of Energy,  Washington, DC,  November 1993, p.
       240.
                                         B-12

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             TABLE B-3. SUPPLY AND DISPOSITION OF GAS IN
                       THE UNITED STATES - 1989"

Production
Gas Wells
Oil Wells
Total
Disposition
Extraction Loss
Fuel and Lease Use
Pipeline Fuel
Gas Lift
Repressure and Pressure Maintenance
Cycled
Underground Storage (Net Charge)
To Transmission Lines
To Carbon Black Plants
Vented or Flared
Acid Gas (H2S, CO2, H2O)
Plant Meter Difference (UAF)
MMcf

15,735,849
5,262,981
20,998,030

784,502
1,070,452
630,083
Unreporied
2,451,342
Unreported
(310,802)
15,688,047
Unreported
140,532
362,457
182,217
Percent of Total

74.9
25.1
100.0

3.7
5.1
3.0

11.7
-
(1.5)
73.3
-
0.7
1.7
0.9
a Data reported includes gas processing.
                                  B-13

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