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.
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.
Learn more about the aspects of our air quality program:
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 flaring 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.
- 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 maximizes the marketing of natural gas; therefore, reducing potential emissions.
EPA has stated that emissions of carbon dioxide, methane, and other greenhouse gases (GHGs) present an endangerment to public health and the environment because emissions of such gases are contributing to the warming of the earth’s atmosphere and other climate changes. Whiting not only complies with the requirement to track and report GHG emissions, but we also work to reduce emissions of GHGs. For more information on how we reduce emissions, see Gas Gathering and Processing, Emissions Reductions, Leak Detection and Repair (LDAR) Program, Facility Environmental Inspections and Maintenance.
To track and report GHG emissions, Whiting estimates emissions in accordance with the requirements of EPA’s Mandatory Greenhouse Gas Reporting rule (40 CFR Part 98). These emissions are reported to EPA annually for each calendar year and reports are made publicly available on EPA’s webpage at www.epa.gov/ghgreporting.
At Whiting, we measure or estimate emissions of methane, carbon dioxide and nitrous oxide for multiple emission source types throughout the production, gathering, processing and transmission processes. We measure GHG emission rates for sources that use actual measured data in GHG emission calculations, such as reciprocating rod packing vents and gas plant equipment leaks. We estimate and report equipment leak emissions for production facilities we are required to report. The EPA’s emission factors assume constant leak rates per equipment type and do not account for the inspection and repair programs we have implemented. As a result, we believe this method likely overestimates our actual equipment leak emissions.
This table shows methane emissions from equipment leaks as a percentage of the total natural gas produced in 2015 for our Bakken and Denver-Julesburg shale play assets. For other GHG emissions sources, Whiting utilizes the EPA’s emission calculation methodology described above.
Estimated GHG Emissions from Equipment Leaks per Boe
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 and olfactory (AVO) and FLIR camera inspections are completed by our dedicated internal inspection teams and supported by our environmental staff as needed. These inspection teams 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. In nearly all instances, the first attempt and subsequent repairs are conducted within the underlying state or federal regulation regardless of the size or severity of the leak.
For example, in the DJ Basin, inspection teams currently conduct AVO inspections at least every week and FLIR camera inspections at least monthly. In the Bakken, inspection teams conduct AVO and FLIR inspections at least monthly. 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 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 Whiting identifies recurrent issues in its review, it implements 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 describes how Whiting’s LDAR program is part of an overall continuous improvement program that combines LDAR, Preventative Maintenance and Predictive Analysis to reduce equipment leaks.
These efforts have resulted in a reduction of the number of leaks and an improvement in our repair and maintenance practices. The predictive analysis program has helped us incorporate improved equipment and component designs and technologies that have resulted in an overall reduction in emissions. 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. For more information on our maintenance practices, see our Maintenance section.
Whiting has developed a robust routine maintenance program to track and trend all maintenance concerns through 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.