What's new in production

June 2002 Vol. 223 No. 6  What's New in Production

Perry A. Fischer,  Editor

New U.S. law affects automation & control systems. Here’s an example of how a small, somewhat quirky change in the law governing plants and producing facilities can have an unusual consequence. The following was contributed by Stan DeVries, director of industry marketing for Invensys Production Management, a company that furnishes software to industrial plants.

Recent U.S. laws encourage private companies and federal agencies to submit reports electronically. The first law (Code of Federal Regulations) to have a major impact on automation and control systems is 21 CFR Part 11, which is normally used for records and reports for the food and drug industries. Companies affected by this law must establish compliance by June 2002. Several software companies have developed functionality to help users comply by then, as well as improve security and change management and reliability of electronic records / signatures. This law includes distributed control systems, SCADA systems, human / machine-interface software, data historians and other software that supervises operator procedures. Later in 2002, another part of the federal code, 40 CFR Part 3, will affect all industries that deal with environmental records and reports. It contains many references to 21 CFR Part 11.

Many industrial facilities – especially oil and gas production and processing – use the main control or SCADA system, along with software such as data historians to process and archive data that is used for environmental reports. Government rules for maximizing the availability, accuracy and completeness of information for these reports have been in place for many years. A landmark case involving a Texas refinery, defending charges from the EPA, revealed issues surrounding the refinery’s ability to prove that its records and data were sufficiently controlled.

The basic requirement is that companies submitting electronic records for EPA compliance must maintain control over the accuracy, completeness, availability and security of such records. As a minimum, this only affects electronic files that are submitted to the EPA. Arguably, this data can be gathered and processed manually, but a production facility has to deal with too many sources of data to process this manually. This is where the law affects automation and control systems: If these systems are automatically gathering and processing the supporting data, then whoever is responsible for these reports and records becomes responsible for the other systems that help generate them – automation and control systems.

There are three key questions that oil & gas producers must consider. First, availability: Will key information regarding an EPA report be collected, retained and made readily accessible despite changes to computer hardware or software? How long should the information be kept, given legal record-keeping needs?

Second, reliability: Will the electronic records be sufficiently reliable and persuasive to satisfy courts and others who must determine the facts underlying EPA actions? Will they satisfy admissibility requirements? Will sufficient context be preserved so that such records are usable?

Third, compliance with other laws: Will company use of electronic methods to obtain, send, disclose and store information comply with applicable laws, such as those governing privacy, confidentiality, record keeping and accessibility to persons with disabilities?

It seems that new functionality will be required for future compliance. The new laws will impact major automation suppliers’ business, including food and drug manufacturers, oil and gas production, transportation, terminaling, processing facilities and similar businesses – anyone who must provide records of configuration / maintenance changes, personnel actions, alarms and diagnostics, and show supporting evidence should data or calculations be questioned. Similar laws exist in countries such as Germany and Australia that basically require this type of functionality – whenever data that affects safety, health or environmental procedures, and other records and reports are required. Fortunately, as with other U.S. laws, there will be time allowed for compliance.

Sonic scale removal. A DOE-sponsored project has resulted in a new, low-cost sonic scale remover for use in natural gas wells. The tool was proven in wells in a gas-storage withdrawal setting. Cleaning improves flowrates by removing scale downhole – especially from perforations.

The prototype was developed through a cooperative agreement of a consortium led by Furness-Newburge Inc. of Versailles, Kentucky. It included Nicor Technologies and TechSavants Inc., both of Naperville, Illinois; Baker Atlas, division of Baker Hughes, Houston; and DOE’s National Energy Technology Laboratory.

The compact, 10-lb, 2-in.-dia. prototype is about 2 ft long and comprises an oscillator, power supply, wireline reel (for the power cable), acoustical transducer, portable generator and waterproof connections. The tool emits relatively low-frequency, high-intensity sound waves and removes scale in a relatively short time. Jim Furness, principal investigator and partner at Furness-Newburge, said, "Who would have thought that the Navy acoustical training I received in 1966 would be used to clean out gas wells!"

The technology is not ultra-sound, Furness points out; "People can hear the sound used for this process." The device is tunable within the range of subsonic to 3kHz. About two years of lab and bench-scale development yielded impressive results during testing at the Bashore-1 observation well, operated by Nicor Gas near Pontiac, Illinois. More extensive field tests need to be performed, plus additional lab work, before the tool is commercial, but results so far are good.

According to DOE, on average, more than 17,000 gas storage wells lose 5% of their ability to inject and withdraw gas from storage fields each year. A DOE-Gas Research Institute (now GTI)study determined the culprit was inorganic scale buildup.

The acoustic portion of the tool is expected to sell for less than $15,000 and is compatible with standard wireline equipment. A second research phase will begin this summer to further improve the tool, including field testing in different types of gas-storage reservoirs and pressure regimes, and "ruggedizing" the tool for field use. For technical information, contact James R. Ammer, DOE NETL, 304/285-4383, email: jammer@netl.doe.gov.  

Comments? Write: fischerp@gulfpub.com