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EU ETS Compliance Management

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Introduction

Our customer is one of the largest North Sea oil and gas operators and have presence in more than 70 countries, producing around 3.3 million barrels per day of oil equivalent. In 2011, KELTON were engaged to carry out a review of all the environmental measurement systems on their North Sea assets.

Summary

As part of the European Union Emissions Trading Scheme (EUETS), operators are required to submit a monitoring plan to the regulatory authorities containing details of how certain sources of CO2 emissions will be determined. This needs to include an uncertainty analysis of the measurement system for each such source stream.

The objective was to bring all the environmental measurement systems within tier under the EUETS monitoring and reporting system and the Oil Pollution Prevention and Control (OPPC) regulations, with a long-term goal of achieving the highest tier.

Action(s) Taken

KELTON completed a gap analysis on the environmental measurement systems across all of the customers North Sea assets to identify any measurement deficiencies in their fuel, flare and produced water measurement systems.

The gap analysis considered the following areas; the physical configuration of the system, the maintenance and calibration frequency, inspection activities, flow computer configuration and computation checks and any laboratory analysis requirements.

From the initial assessment, uncertainty calculations were developed using the KELTON UNCERTAINTYPLUS modules based on the findings from the gas analysis.

With this information available, a prioritised action plan was then created for each system to address the largest sources of uncertainty and to bring each system within tier.

Outcome

All the systems which demonstrated high uncertainty are now within a tier, and where possible, within the top tier. Where it was not feasible to bring a measurement system into the top tier, due to unreasonable costs, KELTON assisted the customer by developing Cost Based Analysis reports for those systems which were submitted to the regulator.

 

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EU ETS Compliance Management Case Study