The Federal Clean Air Act and companion state laws regulate emissions of various air pollutants from industrial sources through air emissions permitting programs, require emission controls and reductions and impose other monitoring and reporting requirements. For example, the Environmental Protection Agency (EPA) has issued New Source Performance Standards (NSPS) and National Emission Standards for Hazardous Air Pollutants (NESHAPs) to reduce the emissions of key pollutants such as volatile organic compounds (VOCs), nitrous oxide (NOx) and carbon monoxide (CO), as well as hazardous air pollutants (HAPs) such as benzene. Among other things, these standards require the application of reduced emission completion techniques (green completions) associated with the completion of newly drilled and fractured wells in addition to existing wells that are refractured. The rules also establish specific requirements regarding emissions from storage tanks, compressors, dehydrators and other production equipment.
Whiting estimates the actual air emissions from our operations. We use state and federal emission estimation methodologies relevant to the locations in which Whiting operates along with manufacturer-provided or EPA-required emissions factors. The table below summarizes Whiting’s estimated emissions of NOx, CO, VOC, and total HAPs per barrel of oil equivalent (BOE) produced in our North Dakota operations.
|Pollutant||2017 Emissions (POUNDS/BOE)|
In addition to complying with stringent federal and state air quality regulation, Whiting strives to reduce air pollutant and greenhouse gas emissions in many ways.
REDUCED EMISSIONS COMPLETIONS
Ahead of the recently promulgated Federal regulations, Whiting began implementing practices where drilling and workover operations would utilize techniques aimed at reducing greenhouse gases by eliminating or significantly reducing gas vented into the atmosphere. The use of these techniques has greatly reduced Whiting’s carbon footprint, pollutant and greenhouse gas emissions and natural gas vented or flared during completions and workovers.
GAS GATHERING AND PROCESSING
Whiting has made significant investments in natural gas gathering and processing infrastructure to maximize natural resource recovery and minimize natural resource waste. Whiting works to capture and market natural gas resources wherever feasible. In areas where Whiting has not established or contracted with a midstream company for gas gathering and processing, it is our practice to proactively create other opportunities to send produced natural gas to market.
Whiting has constructed multiple gas gathering systems and gas plants where this infrastructure did not exist to expedite the capture of natural gas. For example:
- Whiting constructed gas gathering pipeline infrastructure, gas compression, and the Robinson Lake Gas Plant to capture and process Whiting and other companies’ gas in Mountrail County, North Dakota.
- Whiting built a 20” pipeline in McKenzie County, North Dakota to a third-party compressor station in the region.
These investments increase Whiting’s gas capture rate and maximize the marketing of natural gas, therefore, reducing potential emissions.
Low-Emitting Pneumatic Controllers
Whiting has implemented a policy to require that any equipment either purchased, replaced or modified must be fitted with a low-bleed natural gas, no-bleed natural gas, compressed air, or equivalent pneumatic controller and to encourage the replacement of existing high-bleed natural gas pneumatic controllers, except where safety or operational conditions require a higher-emitting controller. Whiting believes such a policy greatly reduces its carbon footprint, pollutant, and greenhouse gas emissions and conserves valuable natural resources. At this time, Whiting believes it has eliminated high-bleed pneumatic controllers from it’s operations. Additionally, Whiting looks for opportunities to eliminate or control emissions from the remaining low-bleed pneumatic controllers by:
- Routing their emissions back into the process,
- Routing their emissions to a combustion device,
- Using electrically actuated controllers, or
- Using compressed air as the pneumatic source.
LEAK DETECTION AND REPAIR (LDAR) PROGRAM
Whiting is committed to minimizing methane and other hydrocarbon leaks across our operations. We conduct leak inspections that meet or exceed the scope and frequency of applicable federal or state regulatory standards. As part of these efforts, our staff utilizes optical gas imaging (i.e., forward-looking infrared (FLIR) camera technology) across all our operations. Since 2010, we have led the industry by utilizing FLIR camera technology well ahead of regulations requiring FLIR camera inspections.
Audio / visual / olfactory (AVO) and FLIR camera inspections are completed by dedicated internal inspection teams in the Williston and DJ Basins, and by our environmental staff in other operating areas. These inspectors are trained on the equipment, techniques and procedures associated with these inspections prior to completing inspections. Additionally, our inspection teams, environmental staff, and production staff are trained annually on our Standard Operating Procedures (SOPs) and best practices.
Leak inspections are performed on all equipment and associated piping and fittings at subject facilities. Whiting responds expeditiously to repair any leak discovered, regardless of size. In all cases, any leak repairs are re-inspected to ensure the repairs were successful.
For DJ Basin tank batteries, inspection teams currently conduct AVO inspections at least every week and FLIR camera inspections at least monthly. For Williston Basin tank batteries, inspection teams conduct AVO inspections monthly and FLIR inspections at least quarterly, and as often as monthly in some cases. For many facilities, this is more frequent than what is required by applicable state and federal leak detection requirements. In other operating areas where there are no state or federal leak detection requirements, we conduct FLIR inspections at least annually. In addition to our dedicated inspection staff, we also train field operators to spot and repair leaks during daily rounds.
Whiting collects information during these leak inspection and repair activities. This information is reviewed as part of our predictive analysis program in the Williston and DJ Basins. We consider inspection results, repair trends, preventative maintenance activities, operational conditions, environmental factors and facility and equipment attributes during cross-functional team reviews. Where we identify recurrent issues in this review, we implement corrective actions as necessary. Through our evaluation, we are continually working to identify areas of focus where our efforts can drive improvement.
The figure below illustrates how this predictive analysis program in the Williston and DJ Basins is part of an overall continuous improvement program that combines LDAR, Preventative Maintenance and Predictive Analysis to reduce equipment leaks.
Whiting’s peer-leading programs in LDAR, Preventative Maintenance and Predictive Analysis have resulted in a reduction of the number of leaks and in enhancements to our repair and maintenance practices. As an example, through these methods, we have been able to reduce tank thief hatch leaks by improved material and component sourcing and preventive maintenance procedures.
The predictive analysis program has helped us incorporate better equipment and component designs and technologies that have resulted in an overall reduction in emissions. Over the course of our inspection program, we have seen significant improvement in the performance of our locations, as demonstrated by several key metrics from our Williston basin operations:
- Over 90% decrease in the total number of issues discovered during inspections
- Nearly 200% increase in the number of inspections that did not find an issue
- Over 400% increase in the length of time between when a previous issue was repaired, and when a new issue is discovered on a respective battery
Whiting has developed a robust routine maintenance program to track and trend all maintenance concerns through to resolution. This allows Whiting to target recurring maintenance issues and enhance equipment reliability. Preventative Maintenance (PM) is one of the key aspects of Whiting’s maintenance program. We have implemented these programs to help ensure reliable operation of our equipment. We have leveraged manufacturer recommendations, industry best practices and input from other sources, including our inspection programs, to develop and influence our PM programs. Our PM plans target equipment critical to storage tanks emissions management in addition to other operational equipment. By properly maintaining equipment, Whiting realizes significant emissions reductions through proper equipment operation. Whiting continues to evaluate these PM plans for improvement opportunities.
Vehicle Fleet Management
Whiting’s Vehicle Fleet Management is an integral part of our commitment to safe operations, environmental stewardship, and operational excellence. In April 2017, Whiting implemented the Pedigree Technologies GPS Fleet Management System, and it was completed in January 2018 to include 495 fleet vehicles in North Dakota, Montana, Colorado, Texas. The Pedigree system allows for greater visibility and transparency into the driving habits of our employees, promoting safe behaviors, accountability and insight into how improvements and training can be tailored for each company driver. Creating a safer environment in the communities in which we operate and share the road is vital to our success and the safety of those around us.
Whiting’s Fleet Management, Operations and Environmental, Health and Safety Departments work closely together to identify cost saving and efficiency opportunities, driver training needs and road hazard awareness. Whiting’s Fleet Management Program has marked several successes since the implementation of Pedigree in April of 2017, including but not limited to:
- A 22% decrease in fuel (gallon) consumption
- A 10% increase in miles per gallon economy
- A 13% decrease in miles driven, reducing on-road exposure
- A 21% decrease in total tons of CO2 emissions by reducing fleet size, increasing efficiency
- Promoting improved driving habits – reducing hard acceleration and braking by 15% and speeding events by 40%
- Reducing at fault accidents, down 35% from previous year.