First Name | Milan |
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Last Name | Steube |
Email Address | milans@cox.net |
Affiliation | |
Subject | GHG MRR Section 95153(v) - Produced Water Dissolved CO2 |
Comment | Regarding Section 95153(v) – Produced Water Dissolved CO2: 1. The first line says: “Produced Water Dissolved CO2. The operator must calculate dissolved CO2 and CH4 in produced water as follows:” The remainder of the section does not mention CH4. Are CH4 emissions required to be reported or not? 2. Item (3) provides an exemption for “EOR operations that route produced water from separation directly to re-injection into the hydrocarbon reservoir in a closed loop system without any leakage to atmosphere”. a. Section 95102(a)(128) appears to define “EOR” to include water flooding. Is this a correct interpretation? b. Since no system is 100% leak free 100% of the time, what is the definition of “a closed loop system without any leakage to the atmosphere”? Can such a system include a water storage or surge tank that is connected to a typical oilfield vapor recovery system upstream of the re-injection pumps (and which may vent to atmosphere via a pressure relief valve when process conditions are abnormal)? Does a system ((even if it does not include any tanks) qualify if it has an occasional leak (e.g., water with dissolved gases dripping from a valve stem or flange)? |
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Date and Time Comment Was Submitted | 2011-08-11 16:24:24 |
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