April 2015 Inventory of U.S. Greenhouse Gas Emissions and Sinks: Potential Revisions to Liquids Unloading Emissions Estimate Overview of Methodology in 2013 and 2014 Inventories Data from a 2012 report published by the American Petroleum Institute (API) and America's Natural Gas Alliance (ANGA)1 were used beginning with EPA's 1990-2011 Inventory released in 2013 ("2013 Inventory") to develop regional activity data and regional emission factors for gas well liquids unloading activities in natural gas systems. For more information, see memo Overview of Updates to the Natural Gas Sector Emissions Calculations for the Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2011, available at http://epa.gov/climatechange/Downloads/ghgemissions/fact-sheet-oil-and-gas-estimates-in-2013- inventory.pdf. Potential Revisions to Liquids Unloading Estimates Several recent studies and upcoming data from GHGRP provide new information on liquids unloading. Below is a brief overview of the data and potential uses of the data to update the GHG Inventory estimates. Allen et al. 2014 Allen et al. 2014 presented results of a study focused on emissions from liquids unloading.2 The Allen et al. study measured unloading emissions from 107 natural gas wells owned by 10 study participant companies. The 107 wells were selected from 4 regions of the country, in proportion to the population of wells that were venting for liquids unloading in each region according to GHGRP data. The wells were selected to represent the three most common categories of unloading methods: automatic plunger-lift, manual plunger-lift and manual non-plunger. Using data from the emission measurements, Allen et al. developed five emission factors for various unloading methods and well types (termed "unloading categories" in this memorandum), in units of emissions per event. The 10 study participants were also surveyed to determine the frequency of events per year, for each of the five unloading categories, in each of four regions of interest. This information was combined with the 2012 GHGRP count of wells performing unloading operations (assumed to represent all national activity) to estimate national emissions from well unloading operations. The study estimated national methane emissions from unloading operations of 270 kilotons per year (kt/y) with a 95% confidence interval of 190 - 400 kt/y, for the year 2012. In contrast, the GHG Inventory estimated 2012 methane emissions of 267 kt/y from unloading activities. As shown in Table 1 below, the totals are in very close agreement, though the apportionment of emissions between non- plunger lift and plunger lift emissions differs between the two analyses. Table 1. Comparison of 2012 National Methane Emissions from Liquids Unloading as Reported in the 2015 GHG Inventory and the Allen et. al Study Lift Type 2015 GHG Inventory (kt) Allen et al. (kt) Non-plunger 126 80 Plunger 143 190 Total 269 270 1 "Characterizing Pivotal Sources of Methane Emissions from Natural Gas Production" (September 2012). Available online: http://www.api.Org/~/media/Files/News/2012/12-October/API-ANGA-Survey-Report.pdf 2 Allen, D.T., Sullivan, D., Zavala-Araiza, D., Pacsi, A., Harrison, M., Keen, K., Fraser, M., Hill, A.D., Lamb, B.K., Sawyer, R.F., and Seinfeld, J.H. Methane Emissions from Process Equipment at Natural Gas Production Sites in the United States: Liquid Unloadings, Environmental Science & Technology, 10.1021/es504016r. Available online: http://pubs.acs.org/doi/abs/10.1021/es504016r 1 ------- April 2015 Summary of Allen et al. Approach Allen et al. observed wide variability in measured emissions data from well unloading events. Allen et al. conducted statistical analyses to identify well and unloading event characteristics that could explain the variability observed and found that the variable that best explained the variability in the observed annual well emissions was unloading frequency. Allen et al. also found a positive correlation of event frequencies with well age (with older wells having more unloading events per year) and a negative correlation of annual emissions with well depth (with deeper wells having lower annual emissions). Allen et al. study results indicated consistency in per-event emissions for five unloading categories that vary by wells with or without plunger lift and by event frequency: • Wells without plunger lifts < 10 events per year; • Wells without plunger lifts > 10 < 50 events per year; • Wells without plunger lifts > 50 events per year; • Wells with plunger lifts < 100 events per year; and • Wells with plunger lifts > 100 events per year. To calculate national emissions, the Allen et al. study used national per-event emission factors for the five unloading categories above in conjunction with region-specific activity data comprising two components: 1. Regional total counts of wells in the five unloading categories. Allen et al. relied on 2012 GHGRP data for counts of wells on a regional level that perform liquids unloading with and without plunger lifts. The Allen et al. study then applied results from a survey of study participants to apportion the wells into the five unloading categories (e.g., 79% of non-plunger wells in the Appalachian region have < 10 unloading events per year). 2. Regional average annual number of events that are performed on wells in each of the five unloading categories. Allen et al. applied results from the survey of study participants to determine the region-specific average annual number of unloading events in each unloading category (e.g., non-plunger wells with < 10 unloading events per year in the Appalachian region perform 3.13 events/year on average). The study found that the distribution of high event frequency wells (> 100 events/year) is not uniform within the Rocky Mountain region. In particular, AAPG Basin 580 (San Juan Basin) had a much higher fraction of high frequency plunger lift unloading than the rest of the region. Therefore, the total number of events in the two plunger lift unloading categories was calculated for two sub-basins of the Rocky Mountain region to avoid skewing a regional estimate with the activity observed in Basin 580. Comparison of Allen et al. with EPA data Currently, EPA is considering ways to better reflect regional-level emissions for liquids unloading in the GHG Inventory. Although regional emissions were not the focus of the Allen et al. study, regional data from the study were used to compile regional emissions. Since the Allen et al. study combines the Southwest region with Mid-Continent and combines the West Coast region with Rocky Mountain, these same combinations were made in order to compare the Allen et al. study results to the GHG Inventory and the GHGRP emissions on a regional basis as shown in Table 2 below. 2 ------- April 2015 Table 2. Regional and National Comparison of 2012 Liquids Unloading Methane Emissions NEMS Region 2012 Liquids Unloading Emissions (MMT CO;e) Allen et al. 2015 GHG Inventory GHGRP Appalachian 1.13 2.10 0.51 Gulf Coast 0.27 0.35 0.49 Mid-Continent/Southwest 1.85 2.50 1.00 Rocky Mountain/West Coast 3.78 1.78 2.97 Total 7.03 6.73 4.97 The Allen et al. study and GHG Inventory compare very closely at the national level, but not at the regional level. At the regional level, the Allen et al. study results compare more closely with the GHGRP (which is expected to some degree because the Allen et al. study estimates are based on regional GHGRP well count activity data). Potential Applicability of Allen et al. to Revising the GHG Inventory Emission Factors The GHG Inventory applies region-specific annual emission factors to wells unloading with and without plunger lifts. For wells without plunger lifts, the GHG Inventory regional emission factors range from 100 thousand to 2.6 million scf CH4/well/year; for wells with plunger lifts, the regional emission factors range from 3.5 thousand to 1.4 million scf CH4/well/year. Table 3 below presents regional emission factors developed from the Allen et al. study. The basis for these factors is combining: (1) national average per-event emissions data (scf CH4/event) in each unloading category that were obtained from study measurements; with (2) event frequency data (events/well/year) in each unloading category that were obtained from the survey of study participants. The factors labeled "Regional Average" in Table 3 take into accout the relative prevalence of wells in each unloading category in each region based on the study participant survey. Table 3. Regional Methane Emission Factors (scf Cm/well/year) Developed from Allen et al. Study Unloading Category Appalachian Gulf Coast Mid-Continent/ Southwest Rocky Mountain/ West Coast Wells without plunger lifts < 10 events per year 67,237 62,778 63,483 60,659 10 < events < 50 per year 514,707 470,360 510,892 431,633 50 < events < 200 per year 2,352,151 3,177,691 2,611,834 2,657,585 Events > 200 per year3 - 12,105,491 14,478,647 - Regional Average 197,954 131,489 203,466 107,402 Wells with plunger lifts < 100 events per year 69,357 50,985 49,790 91,114 3 Allen et al. obtained activity data but not per-event emissions data for this category, and assumed the same per- event emissions as observed for the unloading category "50 < events < 200 per year." 3 ------- April 2015 > 100 events per year 326,206 162,000 2,139,423 1,447,558 Regional Average 75,336 51,726 430,730 472,937 Table 4 below compares regional emission factors developed from the Allen et al. study to the regional factors currently used in the GHG Inventory. Table 4. Regional Methane Emission Factors (scf CH4/well/year) Developed from Allen et al. Study Compared to Current GHG Inventory Factors3 Data Source Appalachian Gulf Coast Mid-Continent/ Southwest Rocky Mountain/ West Coast Wells without plunger lifts GHG Inventory 166,000 301,000 230,000/ 97,000 2,579,000/ 304,000 Allen et al. 198,000 131,000 203,000 107,000 Wells with plunger lifts GHG Inventory 315,000 70,000 1,380,000/ 4,000 154,000/ 345,000 Allen et al. 75,000 52,000 431,000 473,000 a - Rounded to the nearest thousand. In order to incorporate the Allen et al. factors into the GHG Inventory using the regional structure of the production segment calculations, the emission factors could be assigned to the Southwest region as the Mid-Continent region, and to the West Coast region as the Rocky Mountain region, since the Allen et al. study did not differentiate regions to the same granularity as the current Inventory methodology. Potential Applicability of Allen et al. to Revising the GHG Inventory Activity Data The Allen et al. study used GHGRP data to estimate national emissions. Note that the GHGRP data do not cover 100 percent of national activity due to the reporting threshold. Table 5 below shows activity data from the 2015 GHG Inventory compared to GHGRP data, for year 2012. Table 5. Regional Activity Data from Current GHG Inventory Compared to GHGRP for Year 2012 Well Type/ Data Source NEMS Region North East Gulf Coast Mid- Continent Southwest Rocky Mountain West Coast National Total Wells without plunger lifts GHG Inventory 18,181 2,627 5,383 10,527 1,199 179 38,096 GHGRP 7,562 4,649 3,569 3,980 6,720 33 26,513 Wells with plunger lifts GHG Inventory 7,030 860 3,031 1,797 10,162 200 23,080 GHGRP 11,118 1,613 1,903 2,596 15,412 0 32,642 Total wells with liquids unloading GHG Inventory 25,211 3,487 8,414 12,324 11,361 379 61,176 GHGRP 18,680 6,262 5,472 6,576 22,132 33 59,155 The results of a revision to the activity data methodology to use GHGRP data would better align the GHG Inventory with both the Allen et al. and the GHGRP results—both on a regional level and also regarding the overall apportionment between non-plunger lifts and plunger lifts. Potential Impacts of Allen et al. on GHG Inventory Estimates 4 ------- April 2015 Table 6 below shows 2012 methane emissions from liquids unloading for five calculation approaches: 1. Allen et al. study estimates, which apply regional emission estimates based on unloading volumes and frequencies observed during the study to available GHGRP activity data (note that since Allen et al. publication, updated 2012 GHGRP data have been published); 2. Current GHG Inventory estimates, which are based on emissions estimates and event counts from a 2012 API-ANGA study4; 3. Current GHGRP emissions data; 4. Emission factors developed from Allen et al. study data as shown in 5. Table 4 applied to current GHG Inventory activity data; and 6. Emission factors developed from Allen et al. study data as shown in 7. Table 4 applied to most up-to-date GHGRP activity data (i.e., updated activity data compared to approach 1). Table 6. Regional and National Comparison of 2012 Liquids Unloading Methane Emissions NEMS Region 2012 Liquids Unloading Methane Emissions (MMT CChe) Allen et al. Study Current GHG Inventory GHGRP EFs from Allen et al. Study & Inventory Activity Data EFs from Allen et al. Study & GHGRP Activity Data Appalachian 1.13 2.12 0.51 1.95 1.10 Gulf Coast 0.27 0.75 0.49 0.24 0.33 Mid- Continent/Southwest 1.85 2.09 1.00 2.51 1.64 Rocky Mountain/West Coast 3.78 1.88 2.97 2.39 3.79 Total 7.03 6.84 4.97 7.09 6.86 API/ANGA 2012 - Analysis of National versus Regional Factors EPA compared liquids unloading emissions data for 2011 and 2012 from the 2014 Inventory to data reported to GHGRP as of August 18, 2014. As shown in Table 7, there were significant regional differences between the Inventory emissions estimates and the data reported to the GHGRP for the same year. For example, liquids unloading emissions reported to GHGRP in the Rocky Mountain and South West NEMS regions are over twice as high as emissions for these regions in the Inventory. In contrast, Inventory emissions for the North East and Mid-Continent regions are more than five times as high as GHGRP emissions for these regions. EPA is considering options to address the differences between the Inventory and GHGRP. As discussed in the "Planned Improvements" section of the 2014 Inventory, EPA investigated the impact of using national-average data from the API/ANGA report as opposed to the regional data. Table 8 compares four sets of data on liquids unloading. The first column presents the data from year 2012 in the 2014 Inventory and is based on regional activity and emission factors developed from the API/ANGA study. The second column of data is the information reported under the GHGRP for year 2012 (as of August 18, 2014). The third column is the result of replacing regional emission factors for year 2012 in the Inventory with 4American Petroleum Institute and America's Natural Gas Alliance (API/ANGA) Characterizing Pivotal Sources of Methane Emissions from Natural Gas Production: Summary and Analyses of API and ANGA Survey Responses, Final Report, updated September, 2012. Available online: http://www.api.org/news-and-media/news/newsitems/2012/oct- 2012/~/media/Files/News/2012/12-October/API-ANGA-Survey-Report.pdf 5 ------- April 2015 national-average emission factors for liquids unloading with and without plunger lifts that were developed from the API/ANGA study. The fourth column replaces the regional proportions of wells venting during liquids unloading with the national-average proportions that were reported in the API/ANGA study in addition to using national-average emission factors. For the national average proportions of wells venting during liquids unloading, the wells vented with plunger lifts were tracked separately from the wells vented without plunger lifts. Table 7. Com larison of 2014 Inventory and GHGRP Emissions from Liquids Unloading NEMS Region Methane Emissions (MT CO;e)* GHGRP 2011 Emissions Inventory 2011 Emissions GHGRP 2012 Emissions Inventory 2012 Emissions GHGRP 2013 Emissions North East 407,027 2,077,962 603,649 2,115,336 350,790 Mid-Continent 245,585 1,798,774 292,158 1,790,352 126,146 Rocky Mountain 4,558,417 1,857,979 3,510,830 1,837,101 2,585,559 South West 1,334,024 304,100 943,095 304,888 849,077 West Coast 153,111 44,541 26,846 43,392 92,619 Gulf Coast 634,323 747,532 539,133 748,132 431,051 TOTAL 7,332,489 6,830,887 5,915,710 6,839,201 4,435,241 *Methane GWP=25 Table 8. National Emissions Estimates for Liquids Unloading Region Methane Emissions (MT COze)* 2012 Emissions (In 2014 Inventory) GHGRP2012 Emissions Inventory 2012 Emissions Using National Average EFs Inventory 2012 Emissions Using National Average EFs and Activity Assumptions North East 2,115,336 603,649 2,967,625 2,669,870 Mid-Continent 1,790,352 292,158 843,800 1,814,631 Rocky Mountain 1,837,101 3,510,830 1,552,525 1,401,015 South West 304,888 943,095 1,110,200 696,792 West Coast 43,392 26,846 37,175 35,208 Gulf Coast 748,132 539,133 860,250 1,291,289 TOTAL 6,839,201 5,915,710 7,371,575 7,908,807 *Methane GWP=25 Moving from regional-level to national-level emission factors and activity factors did not improve regional consistency with the GHGRP emissions. Greenhouse Gas Reporting Program EPA's Greenhouse Gas Reporting Program (GHGRP) has collected 3 years of emissions data on liquids unloading. EPA anticipates that for future Inventories, it may be possible to calculate updated emission factors and/or activity data using GHGRP data that will be reported starting in 2015. Data currently available through GHGRP include total methane emissions from liquids unloading at the sub-basin level for each reporter. Data that would allow EPA to develop an updated approach for liquids unloading using GHGRP data include data on the number of wells venting for liquids unloading, each reporter's total number of wells, and the number of those wells with and without plunger lifts. 6 ------- April 2015 Table 9. Comparison of GHGRP and GHG Inventory Liquids Unloading CH4 (kt] Year GHGRP 2015 GHG Inventory 2011 495 268 2012 227 267 2013 177 256 Requests for Stakeholder Feedback • EPA seeks feedback on the utility and transparency of using event-based EFs (scf CH4/event/year) versus well-based EFs (scf CH4/well/year) to develop national estimates in the Inventory. • EPA seeks feedback on estimating emissions using emissions data from Allen et al. The Allen et al. study apportioned wells into five unloading categories (e.g., 79% of non-plunger wells in the Appalachian region have < 10 unloading events per year). To apply emissions data in this structure, annual data (or a method to approximate annual data) would be needed on the number of wells in each category. Reflecting changes to this distribution across the time series from 1990 through 2013 would require data on distribution of unloading events over time. EPA seeks comment on data availability on distribution of unloading events and approaches to ensure that the Inventory reflects changes in practices overtime. • EPA seeks feedback on an approach that uses the Allen et al. data to develop regional emission factors for plunger and non-plunger wells (similar to the current Inventory structure). Average emission factors that incorporate the Allen et al. study data have a built-in assumption regarding the distribution of unloading frequency. If these factors are applied across the time series, then the implied assumption is that distribution of unloading frequency categories has not changed over time. EPA seeks feedback on approaches that may be applied to ensure accuracy across the time series. • Allen et al. observed that older wells had more frequent unloading events than newer wells. EPA seeks stakeholder feedback on an approach to calculating annual national emissions that incorporates data on well age to reflect this variability. • EPA seeks feedback on options for activity data for wells performing liquids unloading with and without plunger lifts, across the time series. The two right-most columns of Table 6 above show the impacts of moving from the current Inventory activity data to GHGRP activity data (while applying the same regional EFs developed from the Allen et al. study). • EPA seeks feedback on the sampling and measurement methods used in the Allen et al. study and the appropriateness of the data set for calculating national emissions estimates. • EPA seeks feedback on approaches for developing updated uncertainty estimates for this source. The Allen et al. study utilized a bootstrapping method to calculate uncertainty because the distributions of event emissions were not normally distributed about a mean. In the bootstrapping procedure, the original data set of each type of well was recreated by making random event selections, with replacement, from the data set. • The API/ANGA study estimated nationally 1.1 million unloadings without plunger lifts and 11.6 million with plunger lifts per year. The Allen et al. study data estimated much lower national event counts—approximately 0.2 million unloadings without plunger lift and 6.8 with plunger lifts per year. According to the Allen et al. analysis, the API/ANGA data set also show a much higher fraction of wells that experience very frequent unloadings (> 50 events/year) compared to the Allen et al. study findings. EPA seeks comment on the different findings of these studies. 7 ------- April 2015 Preliminary comments EPA has received on this source category include support for the development of emission factors and activity data on a regional as opposed to a national basis and support for the use of measurement data for calculating emission factors. 8 ------- |