Joe Etheridge – 25 September 2016 – Environmental Projects and Operations Update
Once again, time has flown by in a flurry of activity. Over the past couple of months, the Encino team has been hard at work completing a wide variety of projects from routine NSPS JJJJ and NESHAPs ZZZZ performance tests to hot-oil heaters and regenerative thermal oxidizers stack testing – to help comply with complex permitting requirements and tight deadlines.
The beginning of the summer also marked expansion into the State of New Mexico – where Encino has now taken over semi-annual monitoring of combustion emissions (turbines) at a major gas plant. Additionally, Encino has responded to the new fugitive monitoring requirements under NSPS OOOOa incorporation of our successful leak detection and repair (LDAR) program under the Texas Commission on Environmental Quality’s (TCEQ) Non-Rule Oil & Gas Permitting program.
A Stepwise Approach
As the regulatory belt tightens...and commodity prices remain stagnant around the $45/BBL mark, Encino staff recognizes the need for a more thoughtful approach to environmental regulatory compliance and operational management. Many of the sources subject to OOOOa are generally accounted for in various asset accounting systems and are managed to some degree by internal maintenance and reliability staff and contractors. By tapping these resources, owners/operators of affected sources can find opportunities for production optimization (and efficiency) from both an operational and environmental regulatory standpoint while, best of all – realizing real cost savings.
Encino has found success in developing LDAR programs by utilizing owner/operator in-house systems and resources in order to save time (and cost) during inspection and repair. For example – the asset inventory and accounting software program Systems Applications & Products (SAP) system can be tailored to track critical equipment at affected facilities/sources. Generally, the system will allow asset tracking from the “parent” (piping circuit/system) to the “subordinate” (separator, cooler, etc.), however, not all alpha-numeric characters are used. Therefore, LDAR nomenclature and naming schema can be extended under SAP for up to twenty (20) characters allowing specific components beyond each subordinate to be included in the critical equipment inventory.
What does that mean?
Very simply…this approach empowers the customer by providing them with total control over their LDAR program…and can be customized/tailored to include ANY equipment requiring inspection and/or periodic monitoring under a specific permit authorization or rule. In addition, it provides a seamless approach to managing inspections and repairs – as each piece of regulated equipment will have its own SAP Identification (ID) – providing a leak management “failsafe” in addition to flags, pictures, and geo-locations. By referencing each SAP ID and correlating the location on a process-flow diagram (piping and instrumentation diagram/drawing (P&ID)), the owner/operator can more effectively determine the location of leaking equipment while adhering to regulatory timelines.
This practice/methodology can be applied to other asset and accounting platforms as long as equipment inventories are relatively complete.
Other Benefits…
Each upstream company (exploration & production) have their own personality. These personalities generally express themselves in the process in which their assets are developed. In the early days of the Eagle Ford boom, many operators where drilling wells in order to secure leases. This “wildcat” approach created challenges from a facility engineering standpoint…as central gathering facilities needed to be designed to adjust to future production rates and operational demand. In addition, transportation infrastructure was basically non-existent…therefore many operators were limited in terms of getting their product to market. In the years that followed, the infrastructure was “fleshed out” by midstream operations and bulk terminals. However, not all owners/operators could keep up with the drilling schedule/pace – and initial P&ID drawings and resources rapidly became obsolete.
With the onset of a decline in commodity pricing – resulting from over supply – created an environment of budget cuts, corporate restructuring, and staff reductions. Without critical operational resources, many initiatives – such as frequent P&ID updates and interdisciplinary communication have become limited. Meanwhile, the EPA continues to monitor E&P operations…to capture sources previously unregulated. Programs such as LDAR (whether required under permit authorization or NSPS OOOOa) can be leveraged to help bridge the gaps between environmental compliance obligations, maintenance and reliability, and general production operations.
“Out of clutter, find simplicity. From discord, find harmony. In the middle of difficulty lies opportunity.”
Once again, time has flown by in a flurry of activity. Over the past couple of months, the Encino team has been hard at work completing a wide variety of projects from routine NSPS JJJJ and NESHAPs ZZZZ performance tests to hot-oil heaters and regenerative thermal oxidizers stack testing – to help comply with complex permitting requirements and tight deadlines.
The beginning of the summer also marked expansion into the State of New Mexico – where Encino has now taken over semi-annual monitoring of combustion emissions (turbines) at a major gas plant. Additionally, Encino has responded to the new fugitive monitoring requirements under NSPS OOOOa incorporation of our successful leak detection and repair (LDAR) program under the Texas Commission on Environmental Quality’s (TCEQ) Non-Rule Oil & Gas Permitting program.
A Stepwise Approach
As the regulatory belt tightens...and commodity prices remain stagnant around the $45/BBL mark, Encino staff recognizes the need for a more thoughtful approach to environmental regulatory compliance and operational management. Many of the sources subject to OOOOa are generally accounted for in various asset accounting systems and are managed to some degree by internal maintenance and reliability staff and contractors. By tapping these resources, owners/operators of affected sources can find opportunities for production optimization (and efficiency) from both an operational and environmental regulatory standpoint while, best of all – realizing real cost savings.
Encino has found success in developing LDAR programs by utilizing owner/operator in-house systems and resources in order to save time (and cost) during inspection and repair. For example – the asset inventory and accounting software program Systems Applications & Products (SAP) system can be tailored to track critical equipment at affected facilities/sources. Generally, the system will allow asset tracking from the “parent” (piping circuit/system) to the “subordinate” (separator, cooler, etc.), however, not all alpha-numeric characters are used. Therefore, LDAR nomenclature and naming schema can be extended under SAP for up to twenty (20) characters allowing specific components beyond each subordinate to be included in the critical equipment inventory.
What does that mean?
Very simply…this approach empowers the customer by providing them with total control over their LDAR program…and can be customized/tailored to include ANY equipment requiring inspection and/or periodic monitoring under a specific permit authorization or rule. In addition, it provides a seamless approach to managing inspections and repairs – as each piece of regulated equipment will have its own SAP Identification (ID) – providing a leak management “failsafe” in addition to flags, pictures, and geo-locations. By referencing each SAP ID and correlating the location on a process-flow diagram (piping and instrumentation diagram/drawing (P&ID)), the owner/operator can more effectively determine the location of leaking equipment while adhering to regulatory timelines.
This practice/methodology can be applied to other asset and accounting platforms as long as equipment inventories are relatively complete.
Other Benefits…
Each upstream company (exploration & production) have their own personality. These personalities generally express themselves in the process in which their assets are developed. In the early days of the Eagle Ford boom, many operators where drilling wells in order to secure leases. This “wildcat” approach created challenges from a facility engineering standpoint…as central gathering facilities needed to be designed to adjust to future production rates and operational demand. In addition, transportation infrastructure was basically non-existent…therefore many operators were limited in terms of getting their product to market. In the years that followed, the infrastructure was “fleshed out” by midstream operations and bulk terminals. However, not all owners/operators could keep up with the drilling schedule/pace – and initial P&ID drawings and resources rapidly became obsolete.
With the onset of a decline in commodity pricing – resulting from over supply – created an environment of budget cuts, corporate restructuring, and staff reductions. Without critical operational resources, many initiatives – such as frequent P&ID updates and interdisciplinary communication have become limited. Meanwhile, the EPA continues to monitor E&P operations…to capture sources previously unregulated. Programs such as LDAR (whether required under permit authorization or NSPS OOOOa) can be leveraged to help bridge the gaps between environmental compliance obligations, maintenance and reliability, and general production operations.
“Out of clutter, find simplicity. From discord, find harmony. In the middle of difficulty lies opportunity.”
- Albert Einstein
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