M-DEV0445: Deviation from methodology AM0009 (v.4) in order to cross check the volume of recovered gas processed by the project activity due to its interchangeability with an existing recovery facility.

AM0009 ver. 4: Recovery and utilization of gas from oil wells that would otherwise be flared or vented

PDD is confidential

The project is the installation of new compressors and an amine plant at an existing gas processing plant. The compressors and amine plant process gas recovered from new oil wells that were previously flared. On leaving the amine plant, the gas then feeds into the existing plant that produces LPG, condensate and lean gas. As a result of the project activity, an additional 5 MMSCFD of associated gas is processed into LPG, condensate and lean gas.

Prior to the implementation of the project activity, the project proponent was operating an existing compressor and amine plant, feeding the gas processing plant and utilizing 5 MMSCFD of associated gas from other oil wells. The gas processing plant was not running to its maximum capacity as the compressor and amine plant were a bottleneck. The project activity investments will allow for an additional 5 MMSCFD of associated gas to be processed from new project oil wells – this associated gas was previously flared. The baseline and the project activity are schematically illustrated in Figure A and Figure B attached to this request for deviation (Annex 1).

The methodology is applicable where the identified baseline is the continued operation of the existing oil and gas infrastructure without processing of any recovered associated gas and/or gas-lift gas and without any other significant changes (scenario P4). As explained above, some oil wells that are in the same oil field as the wells that supply the project activity are already recovering associated gas (and this gas is processed by the facility that the project activity expands). However, there are new oil wells that are currently flaring and will feed to the project activity. Therefore, the definition of “existing oil and gas infrastructure” is considered as those specific oil wells that are currently flaring associated gas and which will now feed the project activity compressors and amine plant.

One parameter to calculate baseline emissions as required by AM0009 (ver.4) is the volume of total recovered gas, (VF,y), measured at point F of Figure 2 of the methodology. This is after pre-processing and before recovered gas is used on-site. In the project activity, point F is after processing by the new amine plant (this pre-processed gas is called sweet gas).

In the case of the project activity, the existing compressor is interchangeable with the new compressors. There is a possibility to switch gas that would have been processed by the existing compressor and amine plant to the new compressors and amine plant and so claim CERs for processing of gas that would have been processed anyway. To avoid this, a QA/QC crosscheck is proposed by the project proponents.

As an element of conservativeness, this deviation proposes a daily crosscheck of the volume of total recovered gas processed by the new compressors and new amine plant (VF,y). This will ensure that only the incremental volume of gas recovered and processed over the theoretical maximum that could have been processed by the existing compressor and existing amine plant will qualify for emission reductions.

The throughput of gas processed by the existing amine plant is a direct function of the CO2 content of the feed gas.The higher the CO2 content, the lower the throughput and vice versa. The maximum design throughput of the existing amine plant is 5 MMSCFD (Million Metric Standard Cubic Feet per Day) at zero CO2 content feed gas.(For both new and existing compressors and amine plants, the amine plant has a lower maximum throughput than the compressor(s) therefore the maximum throughput of the existing compressor and amine plant is the maximum throughput of the existing amine plant).The CO2 content of feed gas will be monitored and included in the QA/QC procedure in the monitoring to crosscheck VF,y such that in each day where the monitored VF,y,day is greater than the cross check, the project proponents will use the crosscheck value to be conservative.

VF,y, day ≤ VSG, b, day – (5 MMSCFD x (1- CO2,feed,day))

Where:
VF,y, day = Crosscheck of measured volume of recovered gas in the project activity per day (MMSCFD)

VSG, b, day = Monitored output volume of gas processed by existing and new amine plants per day, measured at point b in Figure B of Annex 1 (MMSCFD)

5MMSCFD = The maximum output of gas processed by the existing amine plant (basis zero %CO2 feed gas)

CO2,feed,day = CO2 content of feed gas, daily measured at existing compressor (%)
d = All relevant days in the monitored period y

The proposed deviation changes the procedure for measuring the volume of total recovered gas (VF,y) by adding a QA/QC procedure as a crosscheck. This crosscheck will conservatively deal with the possibility of an increase in processing of recovered gas claiming CERs over that resulting from the project activity investment. This is because the project activity results in an expansion of an existing associated gas processing plant.

As per the terms described in EB49 Annex 4, the project participants deviated from AM0009 Ver. 4.0, when applying it to the proposed project activity and the DOE considers that the deviation is due to the proposed project specific situation, and not applicable for other projects applying AM0009 ver.4.0, implying a revision of the methodology would not be required to address the issue

The proposed deviation will give less or equal estimates of the emissions reductions than the use of approved methodology. The inclusion of a daily crosscheck of VF,y will ensure that only the incremental volume of gas processed over the theoretical maximum that could have been processed by the existing compressor and existing amine plant will qualify for emission reductions.

Where the monitored VF,y,day is greater than the cross check, the project proponents will use the crosscheck value to be conservative