Meta-Protocol for Oil and Gas Emission Reduction Projects:

High-Bleed to Low-Bleed Conversion of Pneumatic Controllers

Developed by Blue Source Canada for the Pacific Carbon Trust March 2011 Version 1.1

Table of Contents 1. 2. Project Scope and Description.......................................................................... 1 Module Scope and Description ........................................................................ 1 2.1. Module Approach ............................................................................................. 2 2.2. Module Applicability ......................................................................................... 2 2.3. Module Flexibility ............................................................................................. 3 Project Reporting .............................................................................................. 5 Glossary of New Terms ..................................................................................... 7 Quantification Development and Justification ................................................. 8 5.1. Identification of Sinks and Sources in the Project Condition ........................... 8 5.2. Identification of the Baseline Condition ......................................................... 10 5.3. Selection of Relevant Project and Baseline SSRs ............................................ 11 5.4. Quantification of Reductions, Removals, and Reversals of SSRs ................... 13 5.4.1. Quantification Approach........................................................................... 13 5.4.2. Accuracy .................................................................................................... 17

3. 4. 5.

List of Appendices Appendix A: Flexibility Mechanism Appendix B: Bleed Rate Quantification Appendix C: Device Inventory Appendix D: Contingent Data Collection Appendix E: Reference Controller Bleed Rates List of Tables Table 3.1: Key Data Project Reporting Table ...................................................................... 6 Table 5.1: Project SSRs ........................................................................................................ 9 Table 5.2: Baseline SSRs .................................................................................................... 10 Table 5.3: Comparison of SSRs.......................................................................................... 12 Table 5.4: Quantification Procedures ............................................................................... 14

List of Figures Figure 2.1: Process Flow Diagram for Project Condition .................................................... 4 Figure 2.2: Process Flow Diagram for Baseline Condition .................................................. 4 Figure 5.1: Project Element Lifecycle Chart ........................................................................ 8 Figure 5.2: Baseline Element Lifecycle Chart .................................................................... 10

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This module is an adaptation of the American Carbon Registry Protocol for Emission Reduction Measurement and Monitoring Methodology for the Conversion of High-Bleed Pneumatic Controllers in Oil and Natural Gas Systems. It is meant to be used in conjunction with the Meta-Protocol Introduction and is not a standalone document.

1. Project Scope and Description

Pneumatic controllers use pressurized gas (typically natural gas) for applications in the oil and gas production industry to regulate process variables such as pressure, flow rate and liquid level. Most pneumatic instruments and controllers in the natural gas industry are powered by natural gas, and these controllers are designed to discharge methane to the atmosphere as a part of normal operations. Pneumatic controllers can be designed at both high- and low-bleed rates. In addition, controllers may be self-contained and release gas into the downstream pipeline instead of venting to the atmosphere. Before 1990, all controllers were designed with generally high-bleed rates. It has now become standard practice to use low-bleed pneumatic controls in new construction in the oil and gas industry. Despite the existence of low-bleed technology as well as retrofit solutions, conversions of existing high-bleed controllers are uncommon. The opportunity for generating carbon offsets with this module arises from the direct and indirect reduction of greenhouse gas emissions resulting from the conversion of high-bleed pneumatic controllers to low-bleed/self-contained pneumatic controllers.

2. Module Scope and Description

This module is applicable to the conversion of high-bleed pneumatic controllers to lowbleed/self-contained pneumatic controllers, where operating conditions and requirements permit such conversions. Both snap-acting and throttle acting high-bleed pneumatic controllers are addressed in this module. In some operational applications, such as the control of very large valves that require fast or precise process changes, high-bleed controllers should not be replaced with low-bleed/self-contained controllers. A process flow diagram for a typical project converting high-bleed controllers to lowbleed/self-contained controllers is shown in Figure 2.1. Note that self-contained controllers may be included under the low-bleed controller SSR. The dashed arrows show that pneumatic controllers may or may not be used at each stage of natural gas processing, extraction, and transportation as many different process control configurations are possible.

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2.1.Module Approach
The baseline scenario is the continued use of high-bleed pneumatic controllers. Baseline emissions are comprised of the natural gas vented to the atmosphere from these highbleed controllers. Manufacturers data for bleed rates of controllers are established under laboratory operating conditions and are not reflective of field operating conditions.1 Therefore, emissions in the baseline condition will be determined through site-specific monitoring of a representative sample of the population of high-bleed controllers to be retrofitted. Baseline emissions will be projected from project operating hours. Project bleed rates will also be extrapolated from a series of representative sample measurements of the population of low bleed devices. Further information on the measurement and calculation of emissions can be found in Appendix B. A typical baseline process flow diagram is shown in Figure 2.2. The dashed arrows show that pneumatic controllers may or may not be used at each stage of natural gas processing, extraction, and transmission, because many different process control configurations are possible.

2.2.Module Applicability
To demonstrate that a project meets the requirements under this module, the project developer must supply sufficient evidence to demonstrate that: 1. The project involves the conversion of existing high-bleed controllers to lowbleed controllers and does not involve end of life replacements or new installations. This may be demonstrated by facility process flow diagrams and/or accounting records, work orders, invoices or other vendor/third party documentation/evidence. See Appendix B of the Meta-Protocol Introduction for more details on establishing end of life. 2. In certain applications, controllers may reach the end of their useful lives during the crediting period for the project. To determine if any controller included in the project would normally have been replaced with a low-bleed alternative during the crediting period for a reason other than the project activity, the project proponent should provide the following information. More detail on establishing end of life can be found in Appendix B of the Meta-Protocol Introduction. a. The project proponent should describe current practice for routine refurbishment of controllers and should provide to the verifier the
1

CAPP Fuel Gas Best Management Practices: Efficient Use of Fuel Gas in Pneumatic Instruments. May 2008.

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standard operating procedure, if any, for routine refurbishment of pneumatic controllers, including replacement specifications published by the controllers manufacturer if available. b. Any controllers which would have been so replaced during the crediting period should be identified with the expected date of such replacement stated, and no emission reductions credited for that controller after that date. 3. To facilitate verification and allow for changes in the facility, the proponent will develop an inventory of devices to be maintained annually. Any changes to the inventory, i.e. low-bleed controllers added, will impact net offsets claimed. A sample inventory tracking sheet can be found in Appendix C.

2.3. Module Flexibility

Flexibility in applying the quantification protocol is provided to project developers in the following ways. If applicable, the proponent must indicate and justify why flexibility provisions have been used. 1. If necessary, proponents may use a sample size greater than 30 controllers to determine bleed rates for high-bleed and low-bleed controllers, for greater accuracy in estimating controller population bleed rates. 2. In facilities that have already converted from high bleed controllers, the project developer may claim carbon offsets if the project implementation was after November 29th, 2007. Quantification guidance for retroactive credits can be found in Appendix A. 3. If annual measurements of project pneumatic controllers are not performed, a discount factor may be applied to adjust the baseline and project emissions. Refer to Appendix A for details.

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Figure 2.1: Process Flow Diagram for Project Condition

P6 Raw Gas Production

P4 Low-Bleed Pneumatic Controllers

P7 Raw Gas Transportation

P5 Fuel Gas for Facility

P8 Raw Gas Processing

P9 Processed Gas Distribution and Sale

Figure 2.2: Process Flow Diagram for Baseline Condition

B6 Raw Gas Production

B4 High-Bleed Pneumatic Controllers

B7 Raw Gas Transportation

B5 Fuel Gas for Facility

B8 Raw Gas Processing

B9 Processed Gas Distribution and Sale

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3. Project Reporting
The project reporting table provided below is meant to assist validators and verifiers in identifying key project data monitoring requirements. These are the minimum monitoring requirements necessary to quantify emissions. In no way does Table 3.1 purport to provide a complete summary of monitoring requirements. It is the responsibility of project proponents to correctly quantify emissions reductions using the methods set out in this module. In addition, the following checklist serves as a summary of module applicability requirements that may be reviewed to ensure that each project meets the requirements of this module. It is the responsibility of project proponents to correctly assess applicability requirements as laid out in this module. Applicability Checklist Low-bleed controllers are installed as a retrofit and not installed on brand new instruments at a new facility. Offsets are not generated for end-of-life replacements of high-bleed controllers. An inventory is used to keep track of replaced controllers, equipment types, etc.

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Table 3.1: Key Data Project Reporting Table

High-Bleed to Low-Bleed Controller Conversion Reporting Table Installation ID: Yearly Monitoring Requirements
Date of Fuel Gas Analysis Basin/ Site Location of Fuel Gas Analysis CH4 Content of Gas CO2 Content of Gas % Project Hours of Operation hours Bleed Rate Project Bleed Rate Baseline Actuation Percent* Total Emission Reductions

m3/hour

m3/hour

% time

t CO2e

*Only necessary for snap acting controllers to calculate actuating time. For a more information, see Appendix B.

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4. Glossary of New Terms

Bleed Rate: Rate at which a device uses air or natural gas due to design requirements. Rates may be continuous or intermittent and may vary in the field due to changing conditions. A device used commonly in the oil and gas industry for process control, which has a bleed rate in excess of 0.17 m3/h (6 ft3/h). A device used commonly in the oil and gas industry for process control, which has a bleed rate less than 0.17 m3/h (6 ft3/h). These controllers only vent gas when a process change is required. This device either actuates fully or not at all - in other words, it is either on or off with no proportionality. Typically, Snap-Acting Controllers are used for level control or emergency shutdown procedures. A device used commonly in the oil and gas industry for process control, which does not bleed to the atmosphere but captures vent gases and reintroduces them into the downstream pipeline. These controllers are designed for steadystate operation. They require constant supply and venting of gas, and therefore bleed continuously. They are used to control flow, pressure, temperature, and liquid level.

High-Bleed Pneumatic Controllers:

Low-Bleed Pneumatic Controllers:

Snap-Acting Pneumatic Controllers:

Self-Contained Pneumatic Controllers:

Throttle-Acting Pneumatic Controllers:

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5. Quantification Development and Justification

5.1. Identification of Sinks and Sources in the Project Condition
SSRs were identified for the project by reviewing the seed documents and relevant process flow diagrams pertaining to the operation of natural gas processing facilities. This process confirmed that the SSRs in the process flow diagrams covered the full scope of eligible project activities under the methodology. Based on the process diagrams provided in Figure 2.1, the projects SSRs were organized into lifecycle categories in Figure 5.1. A description of each of the SSRs and their classification as controlled, related or affected is provided in Table 5.1. Note that SSRs previously defined in the Meta-Protocol Introduction are excluded from Figure 5.1 and Table 5.1 for brevity.
Figure 5.1: Project Element Lifecycle Chart

Upstream SSRs During Project

P5 Fuel Gas for Facility P6 Raw Gas Production P7 Raw Gas Transportation P8 Raw Gas Transportation

Upstream SSR SSRs During Project Before Project

P4 Low-Bleed Pneumatic Controllers

Downstream SSR After Project

Downstream SSRs During Project

P9 Processed Gas Distribution and Sale

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Table 5.1: Project SSRs

1. SSR 2. Description 3.Controlled, Related, or Affected

Upstream SSRs During Project Operation P6 Raw Gas The raw gas is collected from a group of adjacent wells where Production moisture content is reduced by removing water and condensate. Condensate is transported to oil refineries for further processing and wastewater is disposed. Leaks may be present in the production facility. P7 Raw Gas The raw gas is piped to a natural gas processing plant. Leaks may Transportation also be present in the pipeline. P8 Raw Gas Processing of raw gas is required to remove hydrogen sulphide, Processing carbon dioxide, water vapour, and heavier hydrocarbons. Clean gas is ready to be distributed and sold. Heavier hydrocarbons are also removed and transported to oil refineries. P5 Fuel Gas Many processes in the facility require clean gas to function. This For Facility clean gas, also referred to as fuel gas, is drawn from the processed Processes gas that will be sold. Equipment in the processes includes compressors, boilers, heaters, engines, glycol dehydrators, refrigerators, and chemical injection pumps (CIP). The methane and carbon dioxide content of the processed gas would need to be tracked. Leaks may also be present in the production facility. Onsite SSRs During Project Operation Process control for temperature, pressure, flow, emergency shutdown, etc., may be required for raw gas production, processing, and distribution. Emissions in the project are attributed P4 Low-Bleed to the venting associated with Low-Bleed Pneumatic Controller Pneumatic operation. Self-Contained Pneumatic Controllers are also included Controllers under in this SSR. Emissions from project controllers may be continuous, intermittent, or zero, depending on controller design. Only controller retrofits are included here. Operating hours of the controller should be tracked. Downstream SSRs During Project Operation P9 Processed Natural gas and other commercially viable NGL products may be Gas sent to a pipeline system or transported by rail or truck to Distribution customers at another point. Greenhouse gas emissions are avoided and Sale from the conservation of fuel gas that was supplied to the control instrumentation in the baseline. It is assumed that the most likely use of avoided fuel gas consumption would be controlled combustion to produce carbon dioxide. Other N/A

Related

Related

Related

Related

Controlled

Related

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5.2. Identification of the Baseline Condition

The selected baseline scenario was a projection based approach. In this method of quantification, the operating hours of low-bleed controllers in the project condition represent an equivalent amount of operating hours in the baseline condition, thus establishing functional equivalence between the baseline and the project condition. Baseline emissions are determined by using different bleed rates for each type of high-bleed technology. Bleed rates will be extrapolated from a series of representative sample measurements from the baseline population. Appendix B details quantification methods for this bleed rate. Figure 5.2: Baseline Element Lifecycle Chart Upstream SSRs During Baseline
B6 Raw Gas Production B7 Raw Gas Transportation B8 Raw Gas Transportation B5 Fuel Gas for Facility

Upstream SSR SSRs During Baseline Before Baseline

B4 Low-Bleed Pneumatic Controllers

Downstream SSR After Baseline

Downstream SSRs During Baseline

B9 Processed Gas Distribution and Sale

Table 5.2: Baseline SSRs

1. SSR 2. Description 3.Controlled, Related, or Affected Related

Upstream SSRs During Baseline Operation B6 Raw Gas The raw gas is collected from a group of adjacent wells where Production moisture content is reduced by removing water and condensate. Condensate is transported to oil refineries for further processing and wastewater is disposed. Leaks may be present in the production facility. B7 Raw Gas The raw gas is piped to a natural gas processing plant. Leaks may Transportation also be present in the pipeline. B8 Raw Gas Processing of raw gas is required to remove hydrogen sulphide, Processing carbon dioxide, water vapour, and heavier hydrocarbons. Clean gas

Related Related

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1. SSR

2. Description

3.Controlled, Related, or Affected

is ready to be distributed and sold. Heavier hydrocarbons are also removed and transported to oil refineries. B5 Fuel Gas Many processes in the facility require clean gas to function. This For Facility clean gas, also referred to as fuel gas, is drawn from the processed Processes gas that will be sold. Equipment in the processes includes compressors, boilers, heaters, engines, glycol dehydrators, refrigerators, and chemical injection pumps (CIP). The methane and carbon dioxide content of the processed gas would need to be tracked.Leaks may also be present in the production facility. Onsite SSRs During Baseline Operation Process control for temperature, pressure, flow, emergency shutdown, etc., may be required for raw gas production, processing, and distribution. Emissions in the baseline are B4 High-Bleed attributed to the venting associated with High-Bleed Pneumatic Pneumatic Controller operation. Emissions from high-bleed controllers may be Controllers continuous or intermittent, depending on controller design. Only high-bleed controllers which have been retrofitted are included here. Downstream SSRs During Baseline Operation B9 Processed Natural gas and other commercially viable NGL products may be Gas sent to a pipeline system or transported by rail or truck to Distribution customers at another point. Greenhouse gas emissions are avoided and Sale from the conservation of fuel gas that was supplied to the control instrumentation in the baseline. It is assumed that the most likely use of avoided fuel gas consumption would be controlled combustion to produce carbon dioxide. Other N/A

Related

Controlled

Related

5.3.Selection of Relevant Project and Baseline SSRs

Each of the SSRs from the project and baseline condition were compared and evaluated as to their relevancy in quantification of greenhouse gas emissions and reductions using ISO 140642:2006. SSRs were identified as controlled, related or affected and included or excluded for quantification. The justification for the exclusion or conditions upon which SSRs may be excluded is provided in Table 5.3 below.

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Table 5.3: Comparison of SSRs

1. Identified SSR Upstream SSRs P6 Raw Gas Production B6 Raw Gas Production P7 Raw Gas Transportation B7 Raw Gas Transportation P8 Raw Gas Processing B8 Raw Gas Processing P5 Fuel Gas For Facility B5 Fuel Gas for Facility Related Onsite SSRs P4 Low-Bleed Pnuematic Controllers B4 High-Bleed Pnuematic Controllers Downstream SSRs P6 Downstream Fluid Processing B6 Downstream Fluid Processing Other N/A Excluded 2. Baseline (C, R, A) 3. Project (C, R, A) 4. Include or Exclude from Quantification Excluded Excluded Excluded Excluded Excluded Excluded Excluded 5. Justification for Exclusion

N/A Related N/A Related N/A Related N/A

Related N/A Related N/A Related N/A Related

The production of raw gas is negligibly impacted by the implementation of the project. Conservation of fuel gas in the project condition reduces project emissions. Conservativeness is increased by the exclusion of this SSR. The transportation of raw gas is negligibly impacted by the implementation of the project. Conservation of fuel gas in the project condition reduces project emissions. Conservativeness is increased by the exclusion of this SSR. The processing of raw gas is negligibly impacted by the implementation of the project. Conservation of fuel gas in the project condition reduces project emissions. Conservativeness is increased by the exclusion of this SSR. Production, processing, and transportation operations are not impacted by the retrofit. Therefore, any incremental reduction in fuel gas use in the project condition can be directly attributed to reduced venting. Emissions from reduced venting are already accounted for in P4 Vented Emissions and B4 Vented Emissions. N/A N/A

N/A Controlled

Controlled N/A

Included Included

N/A Related

Related N/A

Excluded Excluded N/A

Excluded as downstream fluid processing is not impacted by the implementation of the project and as such the baseline and the project conditions will be functionally equivalent.

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5.4. Quantification of Reductions, Removals, and Reversals of SSRs

5.4.1. Quantification Approach Quantification of the reductions, removals and reversals of relevant SSRs for each of the greenhouse gases will be completed using the methodologies outlined in Table 5.4, below. These calculation methodologies serve to complete the following three equations for calculating the emission reductions from the comparison of the baseline and project conditions. The general approach is to calculate the offsets as follows: Emission Reduction = Emissions Baseline Emissions Project Emissions Project = Emissions Low Bleed Pneumatic Controllers Emissions Baseline = Emissions High Bleed Pneumatic Controllers

Where: Emissions Baseline = sum of the emissions under the baseline condition. Emissions Vented Emissions = emissions under SSR B4 High Bleed Pneumatic Controllers Emissions Project = sum of the emissions under the project condition. Emissions Vented Emissions = emissions under SSR P4 Low Bleed Pneumatic Controllers

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Table 5.4: Quantification Procedures 1. Project / 2. Parameter / 3. Unit Baseline SSR Variable

4. Measured 5. Method / Estimated Project SSRs

6. Frequency

7. Justify measurement or estimation and frequency

Emissions Low-Bleed = (Bleed Rate Low-Bleed,i Op.Hours i %CH4 CH4 GWPCH4); (Bleed Rate Low-Bleed,i Op.Hours i %CO2 CO2) Emissions Vented from Low-Bleed Controllers /Emissions High Bleed Bleed Rate of Low Bleed Controller i/Bleed Rate Low-Bleed i Operating Hours of Controller i /Op. Hours i P4 Low Bleed Pneumatic 2 Controllers Percentage of CH4 in vented gas by volume/%CH4 Percentage of CO2 in vented gas by volume/%CO2 Density of CH4 / CH4 kg of CO2e N/A N/A N/A Quantity being calculated in aggregate form. Annual sampling prior to verification will give a high degree of accuracy. Monthly reconciliation of operating records will provide a high degree of assurance. Fuel gas composition should remain relatively stable. Fuel gas composition should remain relatively stable.

m /h

Measured

Direct measurement; See Appendix B.

Annually

Estimated

Data taken from facility operating records

Monthly

% volume

Measured

Direct measurement

Annually

% volume

Measured

Direct measurement 0.678 kg/m at 15C and 101.3 kPa, the standard reference conditions used by the natural gas industry. 3 1.86 kg/m at 15C and 101.3 kPa, the standard reference conditions used by the natural gas industry.
3

Annually

kg/m

Constant

Reference Value

N/A

Density of CO2 / CO2 kg/m

3

Constant

Reference Value

N/A

Actuation time has been excluded to increase the conservativeness of the estimate.

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Global Warming Potential of CH4/ GWPCH4

kg CO2e/kg CH4

Estimated

IPCC

Annually

The GWP of CH4 is 21, as per Intergovernmental Panel on Climate Change (IPCC) and International Standards Organization (ISO).

Baseline SSRs Emissions High-Bleed = Emissions Snap-Acting + Emissions Throttle The following equation is used to determine vented emissions from snap-acting controllers. Emissions Snap-Acting = (Bleed Rate Snap-Acting,i Op.Hoursi %CH4 CH4 (1 - ATi) GWPCH4 ); (Bleed Rate Snap-Acting,i Op.Hoursi %CO2 CO2 (1 - ATi) ) The following equation is used to determine vented emissions from throttle controllers. Emissions Throttle = (Bleed Rate Throttle i Op.Hoursi %CH4 CH4 GWPCH4); (Bleed Rate Throttle i Op.Hoursi %CO2 CO2) Emissions Vented from High-Bleed Controllers /Emissions High Bleed Emissions Vented from Snap-Acting Controllers /Emissions Snap-Acting Emissions Vented from Throttle Controllers /Emissions Throttle Bleed Rate of Snap Acting Controller i/Bleed RateSnap-Acting i kg of CO2e N/A N/A N/A Quantity being calculated in aggregate form.

B4 High Pneumatic Controllers

Bleed

kg of CO2e

N/A

N/A

N/A

Quantity being calculated in aggregate form. Quantity being calculated in aggregate form.

kg of CO2e

N/A

N/A

N/A

m /h

Measured

Direct measurement; See Appendix B

Once

Bleed Rate of Throttle Controller I /Bleed Rate Throttle i

m /h

Measured

Direct measurement; See Appendix B

Once

Annual sampling of a representative sample of the population size with a 95% confidence interval gives a high level of assurance. Annual sampling of a representative sample of the population size with a 95% confidence interval gives a high level of assurance.

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Operating Hours of Controller i /Op. Hours Percentage of CH4 in vented gas by volume/%CH4 Percentage of CO2 in vented gas by volume/%CO2 Density of CH4 / CH4

Estimated

Equal to operating hours of low-bleed controller which replaced high-bleed controller Direct measurement

Monthly

% volume

Measured

Annually

% volume

Measured

Direct measurement 0.678 kg/m at 15C and 101.3 kPa, the standard reference conditions used by the natural gas industry. 3 1.86 kg/m at 15C and 101.3 kPa, the standard reference conditions used by the natural gas industry.
3

Annually

Monthly reconciliation of operating records will provide a high degree of assurance. Annual sampling prior to verification will give a high degree of accuracy. Annual sampling prior to verification will give a high degree of accuracy.

kg/m

Constant

Reference Value

N/A

Density of CO2 / CO2 kg/m

3

Constant

Reference Value

N/A

Global Warming Potential of CH4/ GWPCH4 Percentage of Actuation Time (No Vent Gas Flow) to Total Time for Controller i/ ATi

kg CO2e/kg CH4

Estimated

IPCC

Annually

% time

Measured

See Appendix B

Annually

The GWP of CH4 is 21, as per Intergovernmental Panel on Climate Change (IPCC) and International Standards Organization (ISO). Sampling a representative sample of the population size with a 95% confidence interval gives a high level of assurance.

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5.4.2. Accuracy The bleed rates of controllers are highly variable. This uncertainty is addressed by using a statistical analysis to determine the upper and lower bound within which the average controller operates with 95% certainty. By using the upper bound in the baseline condition and the lower bound in the project condition, a conservative estimate of bleed rates is established to reduce the uncertainty associated with controller bleed rates. Actuation time has a medium level of uncertainty. To ensure a conservative estimate of emissions reductions are given, actuation time has been excluded in the project condition (i.e. all snap acting controllers are assumed to be bleeding 100% of the time). Other parameters such as operating hours and concentration of methane and carbon dioxide in fuel gas can be determined with a high level of accuracy.

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APPENDIX A: FLEXIBILITY MECHANISM QUANTIFICATION

A.1 Retroactive Credits

Retroactive credits may be claimed where facilities have already converted high bleed controllers to low bleed/self contained controllers. To determine the bleed rate of high-bleed controllers, two options are available. The preferred method is to reinstall high bleed devices or to take measurements at other sites that have the same makes and models of high bleed devices as outlined in Appendix B. Where this is not possible, bleed rates may be estimated using manufacturers specifications. Bleed rates for low bleed controllers should be determined as outlined in Appendix B. Bleed rates can be used retroactively for a period of two years. For example, if the samples for the bleed rate were taken on April 2nd, 2011, they may be used in emission reductions calculations for retroactive credits up to April 1st, 2009. This flexibility mechanism does not apply in cases where annual measurements of project controllers were missed.

A.2 Discount Factor for Missed Annual Bleed Rate Monitoring

Where annual measurements of project controllers were missed, emission reductions may be calculated using bleed rates from the previous year of monitoring. A discount factor is applied to the total emissions reductions, based on the number of years since Bleed Rates have been monitored. A 5% discount factor is applied per year. Table A1 shows the discount factor used for the number of missed annual measurements.
Table A1: Discount Factor for Missed Annual Bleed Rate Monitoring3

Number of Years Since Last Bleed Rate Sampling 1 >1 2 3

Discount Factor

N/A 5% 10% 15%

According to the EPA, Leaks increase by 25% for equipment which has not been serviced in the past 5 to 10 years. Therefore, it is assumed that equipment may leak an additional 5% per year. The repair of this equipment would result in a 5% decrease in bleed rate, and therefore a 5% decrease in emission reductions. See EPA Gas Star Lessons Learned: Convert Gas Pneumatic Controllers to Instrument Air, available at http://www.epa.gov/gasstar/documents/ll_instrument_air.pdf A-I |

APPENDIX B: BLEED RATE QUANTIFICATION

B1 Bleed Rate of Controllers

Sampling Procedure For any make and model of device (High or Low Bleed), sample bleed rates will be taken from a minimum of 30 controllers of the population (unless there are less than 30), the estimated number samples required for statistical relevance. From these samples, bleed rates will be established for each model of controller. For example, the population of Model R100 Snap-Acting high-bleed controllers will use a different bleed rate than the population of Model X99 Snap-Acting high-bleed controllers. Flow rate or totalizing meters, or calibrated bags, may be used to monitor bleed rate. Project proponents should ensure that monitoring of snap-acting controllers captures at least one dump cycle. Confidence Intervals In order to quantify the average bleed rate of various controllers through sampling, a brief explanation of the confidence intervals follows. In statistics, a confidence interval estimates the likelihood of finding a sample within an upper and lower bound. For example, one could state there is a 90% probability that a Canadian adult is between 5 feet and 6 feet tall. In this case, the lower and upper bounds are 5 feet 6 feet respectively. The sample size is the adult population of Canada and the confidence level is 90%. Establishing Bleed Rate from Sample Data To determine the confidence interval the following equation is used. A confidence level of 95% should be used with n-1 degrees of freedom to determine the t statistic, which can be looked up in most student statistics textbooks.
Equation A1

= x t [/n Where

(1/2)

= confidence interval t = statistical constant based on confidence level and sample size n = is the sample size x = sample mean = sample standard deviation The standard deviation can be calculated using the following equation. = [ (FCi x)2 / (n-1)] (1/2)
Equation A2

B-I

Where FC = Fuel consumption rate x = Sample mean n = number of samples taken. For the purposes of estimating Bleed Rates, a confidence level of 95% is used with a sample size of 30 controllers or greater. A bleed rate will be needed for each different low-bleed and high-bleed make and model. When estimating the baseline bleed rate, the upper bound will be used. When estimating the project bleed rate, the lower bound will be used. This ensures the conservativeness of the estimate. A sample calculation for the baseline condition is shown using data from a project with Invalco. Project data is presented in Table B1. Table B1 High-Bleed Pneumatic Controllers from Invalco Manufacturer Model Bleed Rate (scfd) Invalco Throttling 518.1 Invalco Snap-Acting 274.3 Invalco CTS-215 655.0 Invalco CTU-215 1052.2 Invalco CTU-415 597.6 Invalco CTU-415 599.2 Invalco CTU-415 415.2 Invalco CTU-415 636.0 Invalco CTU-215 744.0 Invalco CTU 540.0 Invalco CTU 285.0 Invalco CTU 984.0 Invalco CTU 1034.0 Invalco CTU 712.0 Invalco CTU 657.0 Invalco CTU 703.0 Invalco CTU 324.0 From this sample data, using a 95% confidence level, t = 2.120 (constant available in most statistics textbooks) = 237.9 n = 17 x = 628.9 = x t [s/n(1/2)] = 628.9 2.120[237.9/17(1/2)] = 628.9 122.3 = (506.6, 751.2)

Data Source Producer 1 Producer 1 EPA Producer 2 Producer 3 Producer 3 Producer 3 Producer 3 Producer 3 Producer 3 Producer 3 Producer 3 Producer 3 Producer 3 Producer 3 Producer 3 Producer 3

B-II

Therefore, the bleed rates of this equipment falls between 506.6 scfd and 751.1 scfd 95% percent of the time. For the baseline condition, the lower bound, 506.6 scfd, will be used in calculations for conservativeness.

B2 Actuation Time of Snap Acting Controllers

When snap-acting controllers are operating and conducting their intended function, natural gas is run through the device and is thus not bled to the atmosphere. This period of functioning, when no bleeding occurs, is called actuation. On ly in their inactive state are snap-acting controllers whether high-bleed or low-bleed bleeding gas. Most snap-acting controllers are inactive, and thus bleeding, the vast majority of the time (greater than 95%). However, the project proponent should still take into account the time the device is active and not bleeding gas, so this time can be discounted from overall baseline emissions. For this methodology, the project proponent will develop a default actuation rate to apply to the snap-acting controllers in the project boundary. The default will be based on gathering data from all controllers to be retrofitted and should provide the most conservative result for each distinct facility included in the project boundary. For the production sector4 a basin-by-basin approach is necessary because the actuation rates are directly related to liquid production volumes and therefore tend not to vary much across a basin, but may differ significantly between different basins. For the transmission sector5 a facility by facility approach (e.g. each compressor station) is necessary because actuation rates could vary significantly between facilities depending on where in the transmission process the facility is positioned. The percentage of time the actuator is operating daily (AT) and the snap-acting controller is NOT bleeding can be expressed as:
Equation A2

ATs,j = (BPC / LC) where ATs,j = the default actuation rate in facility j for snap-acting s controllers (%) BPC = barrels of production per controller (barrels/day or m3/day) LC = liquid capacity (barrels/day or m3/day)
4

The equipment, operations, and processes involved in the production of natural gas. This involves the wells and processing systems before transmission. See process flow diagram at: http://www.gastool.methanetomarkets.org/m2mtool/gas.html 5 The equipment, operations, and processes involved in the transport (usually by cross-country pipelines) of natural gas at high pressure from producing areas to consuming areas. Source: ttp://www.gastool.methanetomarkets.org/m2mtool/glossary.aspx?diagramblock=Gas%20Transmission

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Barrels of Production per Controller (BPC): The project proponent will determine the 30-day average combined (oil or water) production per day for the well sites with controllers to be retrofitted. The 30-day averages will be added together to determine the total combined average volume per day per type of snap-acting controller, across all of the controllers to be retrofitted. Any controller for which 30 days worth of production data is not available should be excluded from the calculation of the actuation rate. Liquid Capacity: The project proponent will determine the liquid capacity (LC) from the valve manufacturer using the lowest differential pressure (DP) and smallest port size to increase the conservativeness of the estimate. The lowest differential pressure (DP) will be determined across the snap-acting control valves within the population to be retrofitted. A common example of this is the pressure drop across a dump valve dumping from separator pressure down to storage tank pressure. Port size can be determined by physical inspection and should conform to manufacturers standard port sizes. The manufacturer of the valve should provide the liquid capacity (sometimes in a chart called the Liquid Capacity Chart) in its literature, based on port size and differential pressure. LC should be expressed in barrels per day of water flow rate. By using barrels per day of water, and NOT correcting for oil gravity, the calculations will remain conservative since water is denser than oil and will result in slightly longer actuation times. As an example, a company may have a Kimray valve located in an area where the DP is 200 psi and the port size is 1/4 inch. According to Kimray, in this case, the liquid capacity would be 650 barrels per day.

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APPENDIX C: DEVICE INVENTORY

Table C1: Sample Device Inventory High Bleed Controller (Baseline) Facility
Controller I.D. # Controller Make/Model Expected Replacement Date Snap-Acting controllers only Port Differential Barrels of Size Pressure Production

Low-Bleed Controller (Project)

Controller I.D. # Make/Model Date of Retrofit

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APPENDIX D: CONTINGENT DATA COLLECTION

Contingent means for calculating or estimating the required data for the equations outlined in section 5 are summarized in Table D1, below.
Table D1: Contingent Data Collection Procedures
1. Project / Baseline SSR 2. Parameter Variable / 3. Unit 4. Measured 5. Method / Estimated Project SSRs From historical averages of facility operation records 6. Frequency 7. Justify measurement or estimation and frequency Estimating operational hours from historical records is accurate where operations are consistent, when a more reasonable method cannot be used. Provides reasonable estimate of the parameter, when the more accurate and precise method cannot be used. Provides reasonable estimate of the parameter, when the more accurate and precise method cannot be used. Estimating operational hours from historical records is accurate where operations are consistent, when a more reasonable method cannot be used.

Operating Hours of Controller i /Op. Hours i

hours

Estimated

Monthly

P4 Low Bleed Pneumatic Controllers

Percentage of CH4 in vented gas by volume/%CH4

% volume

Percentage of CO2 in vented gas by volume/%CO2

% volume

Interpolation of previous and following Measured/ measurements taken, or Estimated from fuel analysis of gas composition within the same basin. Interpolation of previous and following Measured/ measurements taken, or Estimated from fuel analysis of gas composition within the same basin. Baseline SSRs From historical averages of facility operation records

Annually

Annually

B4 High Bleed Pneumatic Controllers

Operating Hours of Controller i /Op. Hours

hours

Estimated

Monthly

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Percentage of CH4 in vented gas by volume/%CH4 Measured/ Estimated

% volume

Interpolation of previous and following measurements taken, or from fuel analysis of gas composition within the same basin.

Annual

Provides reasonable estimate of the parameter, when the more accurate and precise method cannot be used.

Percentage of CO2 in vented gas by volume/%CO2

% volume

Measured/ Estimated

Actuation Time/AT % time Estimated

Interpolation of previous and following measurements taken, or from fuel analysis of gas composition within the same basin. If it is not possible to determine the actuation time using manufacturers data and compiled data, the conservative estimate of 10% will be used.

Annual

Provides reasonable estimate of the parameter, when the more accurate and precise method cannot be used. Provides conservative estimate of the parameter when the more accurate and precise method cannot be used. Typically actuation time <5%.

N/A

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APPENDIX E: REFERENCE CONTROLLER BLEED RATES

The following table has been provided for validators and verifiers as a means of assessing the accuracy of bleed rate estimates. Table E1: Bleed rates of Controllers6
Signal Pressure (psi) PRESSURE CONTROLLERS Ametek Series 40 20 35 Bristol Babcock Series 20 5453-Model 10F 35 Bristol Babcock Series 20 5455 Model 624-III 35 Bristol Babcock Series 502 A/D (recording 20 controller) 35 Fisher 4100 Series 20 (large orifice) 35 Fisher 4150 and 4160 20 35 Fisher 4194 20 (differential pressure) 35 Fisher 4195 20 35 Foxboro 43AP 20 35 ITT Barton 338 20 35 ITT Barton 335P 20 35 Natco CT 20 35 Bristol Babcock Series 9110-00A Fisher 546
6

Controller Model

Manufacturer Data (scfh) 6 6 3 3 2 3 <6 <6 50 50 10-35 10-42 3.5 5 3.5 5 18 18 6 6 6 6 35 35 TRANSDUCERS 0.42 0.42

Field Data (scfh) N/A N/A 20 - 30 20 - 30 20 - 30 20 - 30 N/A N/A 47 54 11 - 35 24 - 65 12 - 14 13-18 13-18 12-115 N/A N/A 20 - 30 20 - 30 18 - 30 20 - 30 N/A N/A N/A N/A 15 - 40

Number in Field low low low low low low low low low low high high moderate moderate moderate moderate moderate moderate moderate moderate low low low low

Throttling or snap throttling throttling throttling throttling throttling throttling throttling

throttling throttling throttling throttling throttling throttling throttling throttling throttling throttling throttling throttling throttling throttling throttling throttling throttling

20 35 20

high

throttling

CAPP Fuel Gas Best Management Practices: Efficient Use of Fuel Gas in Pneumatic Instruments (Module 3). CETAC West. May 2008.

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Controller Model

Fisher 646 Fisher 846 LEVEL CONTROLLERS Fisher 2900 Fisher 2900 (Continued)

Signal Pressure (psi) 35 20 35 20 35 20 20 35 35 20 35 20 35 20 35 20 35 20 35 20 35 20 20 35 35 20 20 35 35

Manufacturer Data (scfh) 30 <1 <1 <1 <1 23 23 23 23 42 42 1 1 <1 <1 <1 <1 40 N/A N/A 0.007 0.2 0.007 0.2 0.007 0.2 0.007 0.2

Field Data (scfh) 35 - 60 N/A N/A N/A N/A 22-51 18-127 28-51 27-153 N/A 44-72 N/A N/A N/A N/A N/A N/A N/A 34-88 N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A

Number in Field high

Throttling or snap throttling

moderate moderate moderate moderate moderate moderate moderate moderate low low moderate moderate low low moderate moderate high high high high low low low low

throttling snap throttling snap throttling throttling

Fisher 2500 Series Fisher 2660 Series Fisher 2100 Series Fisher 2680 Invalco CT Series Norriseal 1001 Norriseal 1001 (A)

throttling throttling

Wellmark 2001

throttling snap throttling snap throttling snap throttling snap

POSITIONERS Fisher 3582 Fisher 3661 Fisher 3590 (electropneumatic) Fisher 3582i (electropneumatic)

20 35 20 35 20 35 20 35

14 18 8.8 12.1 24 36 17.2 24

22 24 N/A N/A N/A N/A N/A N/A

high high moderate moderate high high moderate moderate

throttling throttling throttling throttling throttling throttling throttling throttling

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Controller Model Fisher 3620J (electropneumatic) Fisher 3660 Fisher Fieldvue Digital Masoneilan 4600B Series Masoneilan 4700B Series Masoneilan SVI Digital Masoneilan 7400 Series Moore Products Model 750P Moore Products 73NB PtoP PMV D5 Digital Sampson 3780 Digital VRC Model VP700 PtoP

Signal Pressure (psi) 20 35 20 35 20 35 20 35 20 35 20 35 20 20 35 20 20 35 20 35 20 35

Manufacturer Data (scfh) 18.2 35 6 8 14 49

Field Data (scfh) N/A N/A N/A N/A N/A

Number in Field moderate moderate moderate moderate moderate moderate low

Throttling or snap throttling throttling throttling throttling throttling throttling throttling throttling throttling throttling throttling throttling throttling throttling throttling throttling throttling throttling throttling throttling

18-30

low low

18-30 <1 <1 24-50 N/A N/A 42 36 <1 <1 <1 <1 <1 <1 N/A N/A N/A N/A N/A N/A N/A N/A

low low low low low moderate low low low low low low low

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