Upload
william-paul
View
213
Download
0
Embed Size (px)
Citation preview
Partner Reported Opportunities forPartner Reported Opportunities forSmall and Medium Sized ProducersSmall and Medium Sized Producers
Lessons LearnedLessons Learnedfrom Natural Gas STARfrom Natural Gas STAR
Small and Medium Sized Producer Technology Transfer WorkshopSmall and Medium Sized Producer Technology Transfer Workshop
Bill Barrett Corporation, Evergreen Resources Inc,Bill Barrett Corporation, Evergreen Resources Inc,Southern Gas Association andSouthern Gas Association and
EPA’s Natural Gas STAR ProgramEPA’s Natural Gas STAR Program
June 29, 2004June 29, 2004
Page 2Reducing Emissions, Increasing Efficiency, Maximizing Profits
Producer PROs: AgendaProducer PROs: Agenda
Introduction to Partner Reported Introduction to Partner Reported Opportunities (PROs) and Lessons LearnedOpportunities (PROs) and Lessons Learned
Selected PRO OverviewsSelected PRO Overviews
DI&MDI&M
DI&M Industry ExperienceDI&M Industry Experience
Discussion QuestionsDiscussion Questions
Page 3Reducing Emissions, Increasing Efficiency, Maximizing Profits
Why Are Partner ReportedWhy Are Partner ReportedOpportunities Important?Opportunities Important?
Partner Annual Reports document Program Partner Annual Reports document Program accomplishmentsaccomplishments Best Management Practices (BMPs): the Best Management Practices (BMPs): the
consensus best practicesconsensus best practices PROs: Partner Reported OpportunitiesPROs: Partner Reported Opportunities
Simple vehicles for sharing successes and Simple vehicles for sharing successes and continuing Program’s future continuing Program’s future Lessons Learned: expansion on the most Lessons Learned: expansion on the most
advantageous BMPs and PROsadvantageous BMPs and PROs PRO Fact SheetsPRO Fact Sheets Technology Transfer WorkshopsTechnology Transfer Workshops Posted on www.epa.gov/gasstarPosted on www.epa.gov/gasstar
Page 4Reducing Emissions, Increasing Efficiency, Maximizing Profits
Why Are Partner ReportedWhy Are Partner ReportedOpportunities Important?Opportunities Important?
Many production facilities have identified Many production facilities have identified practical, cost effective reduction practicespractical, cost effective reduction practices
Production partners report saving 187 Bcf Production partners report saving 187 Bcf since 1990, 80% from PROssince 1990, 80% from PROs Vapor recover units (VRUs) account for 30% Vapor recover units (VRUs) account for 30%
of PRO emissions reductionsof PRO emissions reductions Plunger lift installations account for 16%Plunger lift installations account for 16% Flare installations account for 13%Flare installations account for 13%
Page 5Reducing Emissions, Increasing Efficiency, Maximizing Profits
Production Best Management PracticesProduction Best Management Practices
BMP 1: Install and replace high-bleed BMP 1: Install and replace high-bleed pneumaticspneumatics
BMP 2: Install flash tank separators (FTS) on BMP 2: Install flash tank separators (FTS) on glycol dehydratorsglycol dehydrators
BMP 3: Partner Reported OpportunitiesBMP 3: Partner Reported Opportunities
Page 6Reducing Emissions, Increasing Efficiency, Maximizing Profits
Lessons LearnedLessons Learned
11 applicable to small and medium sized 11 applicable to small and medium sized producersproducers 2 focused on operating practices2 focused on operating practices 9 focused on technology9 focused on technology
All 16 Lessons Learned studies on the EPA All 16 Lessons Learned studies on the EPA web siteweb site www.epa.gov/gasstar/lessons.htmwww.epa.gov/gasstar/lessons.htm
Page 7Reducing Emissions, Increasing Efficiency, Maximizing Profits
Technology Focused Lessons LearnedTechnology Focused Lessons Learnedfor Small and Medium Producersfor Small and Medium Producers
Installing Vapor Recovery Units on Crude Oil Storage Installing Vapor Recovery Units on Crude Oil Storage Tanks Tanks
Optimize Glycol Circulation and Installation of Flash Tank Optimize Glycol Circulation and Installation of Flash Tank Separators in DehydratorsSeparators in Dehydrators
Options for Reducing Methane Emissions from Pneumatic Options for Reducing Methane Emissions from Pneumatic Devices in the Natural Gas IndustryDevices in the Natural Gas Industry
Convert Gas Pneumatic Controls to Instrument Air Convert Gas Pneumatic Controls to Instrument Air Reducing Methane Emissions from Compressor Rod Reducing Methane Emissions from Compressor Rod
Packing Systems Packing Systems Replacing Gas-Assisted Glycol Pumps with Electric PumpsReplacing Gas-Assisted Glycol Pumps with Electric Pumps Installing Plunger Lift Systems in Gas WellsInstalling Plunger Lift Systems in Gas Wells Composite Wrap for Non-Leaking Pipeline DefectsComposite Wrap for Non-Leaking Pipeline Defects Replace Glycol Dehydrators with Desiccant DehydratorsReplace Glycol Dehydrators with Desiccant Dehydrators
Page 8Reducing Emissions, Increasing Efficiency, Maximizing Profits
Gas STAR PRO Fact SheetsGas STAR PRO Fact Sheets
16 applicable to small and medium sized 16 applicable to small and medium sized producersproducers 38 PROs applicable to production38 PROs applicable to production
12 focused on operating practices12 focused on operating practices 26 focused on technology26 focused on technology
PRO Fact Sheets from Annual Reports PRO Fact Sheets from Annual Reports 1994-20021994-2002 Total 56 posted PROs at Total 56 posted PROs at
epa.gov/gasstar/pro/index.htmepa.gov/gasstar/pro/index.htm
Page 9Reducing Emissions, Increasing Efficiency, Maximizing Profits
PROsPROs
Replace Gas Starters with AirReplace Gas Starters with Air
Replace Ignition – Reduce False StartsReplace Ignition – Reduce False Starts
Install Electric StartersInstall Electric Starters
Rerouting of Glycol Skimmer GasRerouting of Glycol Skimmer Gas
Convert Gas-Driven Chemical Pumps to Instrument AirConvert Gas-Driven Chemical Pumps to Instrument Air
Pipe Glycol Dehydrator to Vapor Recovery UnitPipe Glycol Dehydrator to Vapor Recovery Unit
Convert Pneumatics to Mechanical ControlsConvert Pneumatics to Mechanical Controls
Install Electronic Flare Ignition DevicesInstall Electronic Flare Ignition Devices Use ClockSpringUse ClockSpring®® Repair Repair
Page 10Reducing Emissions, Increasing Efficiency, Maximizing Profits
More PROsMore PROs
Inspect Flowlines AnnuallyInspect Flowlines Annually Install BASOInstall BASO®® Valves Valves Use Ultrasound to Identify LeaksUse Ultrasound to Identify Leaks Connect casing to VRUConnect casing to VRU Lower Heater-Treater TemperatureLower Heater-Treater Temperature Begin DI&M at Remote FacilitiesBegin DI&M at Remote Facilities Install Compressors to Capture Casinghead GasInstall Compressors to Capture Casinghead Gas Install Pumpjacks on Low Water Production Gas Wells Install Pumpjacks on Low Water Production Gas Wells Replace Glycol Dehydration Units with Methanol Replace Glycol Dehydration Units with Methanol
InjectionInjection
Page 11Reducing Emissions, Increasing Efficiency, Maximizing Profits
Examples of PROs Applicable to Examples of PROs Applicable to Small/Medium ProducersSmall/Medium Producers
PROs enabled by instrument airPROs enabled by instrument air Replace Gas Starters with Instrument AirReplace Gas Starters with Instrument Air Convert Gas-Driven Chemical Pumps to Convert Gas-Driven Chemical Pumps to
Instrument AirInstrument Air PROs enabled by glycol dehydratorsPROs enabled by glycol dehydrators
Reroute Glycol Skimmer GasReroute Glycol Skimmer Gas Reroute Glycol Dehydrator to Vapor RecoveryReroute Glycol Dehydrator to Vapor Recovery
PROs enabled by electric powerPROs enabled by electric power Install Electric StartersInstall Electric Starters Install Compressors to Capture Casinghead GasInstall Compressors to Capture Casinghead Gas
Page 12Reducing Emissions, Increasing Efficiency, Maximizing Profits
Replace Gas Starters with AirReplace Gas Starters with Air
What is the Problem?What is the Problem? Pressurized gas used to start engines Pressurized gas used to start engines
is exhausted to atmosphereis exhausted to atmosphere Partner SolutionPartner Solution
Replace gas with compressed airReplace gas with compressed air Methane SavingsMethane Savings
Based on one 3,000 HP reciprocating Based on one 3,000 HP reciprocating compressor with 10 start-ups per yearcompressor with 10 start-ups per year
ApplicabilityApplicability Natural gas pneumatic starter motorsNatural gas pneumatic starter motors Needs electric power to run air Needs electric power to run air
compressorcompressor
Methane Methane SavingsSavings
1,356 Mcf/yr1,356 Mcf/yr
Project Project EconomicsEconomics
Project Project CostCost
< $1,000< $1,000
Annual Annual O&M O&M CostsCosts
$100 - $100 - $1,000$1,000
PaybackPayback < 1 yr< 1 yr
Page 13Reducing Emissions, Increasing Efficiency, Maximizing Profits
Convert Gas-Driven Chemical PumpsConvert Gas-Driven Chemical Pumpsto Instrument Airto Instrument Air
What is the Problem?What is the Problem? Chemical pumps powered by Chemical pumps powered by
pressurized natural gas vent pressurized natural gas vent methanemethane
Partner SolutionPartner Solution Replace natural gas with Replace natural gas with
instrument air to power pumps instrument air to power pumps Methane SavingsMethane Savings
Based on glycol unit pumpBased on glycol unit pump ApplicabilityApplicability
Use excess capacity of existing Use excess capacity of existing instrument airinstrument air
Needs electric power to run air Needs electric power to run air compressorcompressor
Methane Methane SavingsSavings
2,500 Mcf/yr2,500 Mcf/yr
Project Project EconomicsEconomics
Project Project CostCost
$1,000 - $1,000 - $10,000$10,000
Annual Annual O&M O&M CostsCosts
$100 - $100 - $1,000$1,000
PaybackPayback < 1 yr< 1 yr
Page 14Reducing Emissions, Increasing Efficiency, Maximizing Profits
PROs Enabled by Glycol DehydratorsPROs Enabled by Glycol Dehydrators
Dehydrators present an excellent place to Dehydrators present an excellent place to reduce emissionsreduce emissions How much methane is emitted?How much methane is emitted?
A 1 MMcf/d dehydrator with vent condenser, no A 1 MMcf/d dehydrator with vent condenser, no flash tank separator and gas pump can flash tank separator and gas pump can produce 460 Mcf/yr of lossesproduce 460 Mcf/yr of losses
How can these losses be reduced?How can these losses be reduced? BMP 2: install flash tank separatorBMP 2: install flash tank separator Many PROsMany PROs
Page 15Reducing Emissions, Increasing Efficiency, Maximizing Profits
Reroute Glycol Skimmer GasReroute Glycol Skimmer Gas
Methane Methane SavingsSavings
7,600 Mcf/yr7,600 Mcf/yr
Project Project EconomicsEconomics
Project Project CostCost
<$1,000<$1,000
Annual Annual O&M O&M CostsCosts
$100 - $100 - $1,000$1,000
PaybackPayback < 1 yr< 1 yr
What is the Problem?What is the Problem? Gas from condensate separator vented Gas from condensate separator vented
to atmosphereto atmosphere
Partner SolutionPartner Solution Reroute condensate separator gas for Reroute condensate separator gas for
fuel usefuel use
Methane SavingsMethane Savings Based on 20 MMcf/d dehydrator w/o Based on 20 MMcf/d dehydrator w/o
FTS, circulating 300 gph FTS, circulating 300 gph
ApplicabilityApplicability All dehydrators with vent condensersAll dehydrators with vent condensers Condensate separator must operate at Condensate separator must operate at
higher pressure than gas destinationhigher pressure than gas destination
Page 16Reducing Emissions, Increasing Efficiency, Maximizing Profits
Pipe Glycol Dehydrator to Vapor Pipe Glycol Dehydrator to Vapor RecoveryRecovery
Methane Methane SavingsSavings
3,300 Mcf/yr3,300 Mcf/yr
Project Project EconomicsEconomics
Project Project CostCost
$1,000 - $1,000 - $10,000$10,000
Annual Annual O&M O&M CostsCosts
> $1,000> $1,000
PaybackPayback < 1 yr< 1 yr
What is the Problem?What is the Problem? High pressure gas used to drive gas High pressure gas used to drive gas
pumps in dehydrators are ventedpumps in dehydrators are vented Partner SolutionPartner Solution
Reroute gas vent to VRUReroute gas vent to VRU Methane SavingsMethane Savings
Based on a 10 MMcf/d gas Based on a 10 MMcf/d gas dehydration unit with FTS and gas dehydration unit with FTS and gas assist pumpassist pump
ApplicabilityApplicability Sufficient spare capacity in existing Sufficient spare capacity in existing
VRUVRU Capacity of VRU outletCapacity of VRU outlet
Page 17Reducing Emissions, Increasing Efficiency, Maximizing Profits
Install Electric StartersInstall Electric Starters
What is the Problem?What is the Problem? Pressurized gas used to start Pressurized gas used to start
engines is exhausted to atmosphereengines is exhausted to atmosphere Partner SolutionPartner Solution
Replacing starter expansion turbine Replacing starter expansion turbine with electric motor starterwith electric motor starter
Methane SavingsMethane Savings Based on one engine starter, ten Based on one engine starter, ten
start-ups per year and methane start-ups per year and methane leakage through gas shut-off valveleakage through gas shut-off valve
ApplicabilityApplicability All sectors of the gas industryAll sectors of the gas industry Requires access to power supplyRequires access to power supply
Methane Methane SavingsSavings
1,350 Mcf/yr1,350 Mcf/yr
Project Project EconomicsEconomics
Project Project CostCost
$1,000 - $1,000 - $10,000$10,000
Annual Annual O&M O&M CostsCosts
< $100< $100
PaybackPayback 1- 3 yrs1- 3 yrs
Page 18Reducing Emissions, Increasing Efficiency, Maximizing Profits
Install Compressors toInstall Compressors to Capture Casinghead Gas Capture Casinghead Gas
What is the Problem?What is the Problem? Casinghead gas vented to atmosphereCasinghead gas vented to atmosphere
Partner SolutionPartner Solution Install compressor to capture Install compressor to capture
casinghead gas and pump to sales linecasinghead gas and pump to sales line Methane SavingsMethane Savings
Based on 180 Mcf/d associated gas Based on 180 Mcf/d associated gas containing 50% methane, 30 HP electric containing 50% methane, 30 HP electric rotary compressor, 100 psig sales linerotary compressor, 100 psig sales line
ApplicabilityApplicability Oil wells that produce significant Oil wells that produce significant
volume of casinghead gasvolume of casinghead gas Access to electricity for compressorAccess to electricity for compressor
Methane Methane SavingsSavings
32,850 Mcf/yr32,850 Mcf/yr
Project Project EconomicsEconomics
Project Project CostCost
> $10,000> $10,000
Annual Annual O&M O&M CostsCosts
> $1,000> $1,000
PaybackPayback <1 yrs<1 yrs
Page 19Reducing Emissions, Increasing Efficiency, Maximizing Profits
Directed Inspection & MaintenanceDirected Inspection & Maintenance
Page 20Reducing Emissions, Increasing Efficiency, Maximizing Profits
What is the Problem?What is the Problem?
Gas leaks are Gas leaks are invisibleinvisible, , unregulatedunregulated and and go unnoticedgo unnoticed STAR Partners find that valves, connectors, compressor STAR Partners find that valves, connectors, compressor
seals and open-ended lines (OELs) are major sourcesseals and open-ended lines (OELs) are major sources 27 Bcf methane emitted per year by reciprocating 27 Bcf methane emitted per year by reciprocating
compressor seals and OELscompressor seals and OELs OELs contribute half these emissionsOELs contribute half these emissions
Fugitive methane emissions depend on operating Fugitive methane emissions depend on operating practices, equipment age and maintenancepractices, equipment age and maintenance
Page 21Reducing Emissions, Increasing Efficiency, Maximizing Profits
How Can These Losses Be Reduced?How Can These Losses Be Reduced?
Implementing a Directed Inspection and Implementing a Directed Inspection and Maintenance (DI&M) ProgramMaintenance (DI&M) Program
Source: CLEARSTONE ENGINEERING LTD
Page 22Reducing Emissions, Increasing Efficiency, Maximizing Profits
What is a DI&M Program?What is a DI&M Program?
Implementing a Directed Inspection and Implementing a Directed Inspection and Maintenance ProgramMaintenance Program VoluntaryVoluntary program to identify and fix leaks program to identify and fix leaks
that are cost-effective to repairthat are cost-effective to repair Outside of mandatory Leak Detection and Outside of mandatory Leak Detection and
Repair (LDAR)Repair (LDAR) Survey cost will pay out in the first yearSurvey cost will pay out in the first year Provides valuable data on leakersProvides valuable data on leakers
Page 23Reducing Emissions, Increasing Efficiency, Maximizing Profits
How Do You Implement A DI&M Program?How Do You Implement A DI&M Program?
SCREEN and MEASURE leaks SCREEN and MEASURE leaks
ESTIMATE repair cost, fix to a payback criteriaESTIMATE repair cost, fix to a payback criteria
PLAN for future DI&MPLAN for future DI&M
Record savings/REPORT to Gas StarRecord savings/REPORT to Gas Star
CONDUCT Baseline survey CONDUCT Baseline survey
FIX on the spot leaksFIX on the spot leaks
Page 24Reducing Emissions, Increasing Efficiency, Maximizing Profits
One of the New PROsOne of the New PROs
Begin Directed Inspection and Begin Directed Inspection and Maintenance at Remote Maintenance at Remote FacilitiesFacilities SAVES: 362 Mcf/yrSAVES: 362 Mcf/yr PAYOUT: < 1 yrPAYOUT: < 1 yr
Enables several PROsEnables several PROs Inspect and Repair Compressor Inspect and Repair Compressor
Station Blowdown ValveStation Blowdown Valve Use Ultrasound to Identify LeaksUse Ultrasound to Identify Leaks Test and Repair Pressure Safety Test and Repair Pressure Safety
ValvesValves
Bubble test on leaking Bubble test on leaking valvevalve Source: CLEARSTONE ENGINEERING LTD
Page 25Reducing Emissions, Increasing Efficiency, Maximizing Profits
Combustion Equipment9.9%
Amine Vents0.5%
Flare Systems24.4%
Non-leaking Components0.1%
NRU Vents0.3%
Storage Tanks11.8%
Leaking Components53.1%
Source: Clearstone Engineering, 2002
Natural Gas Losses by SourceNatural Gas Losses by Source
Page 26Reducing Emissions, Increasing Efficiency, Maximizing Profits
Control Valves4.0%
Open-Ended Lines11.1%
Other Flow Meters0.2%
Orifice Meters0.1%
Pressure Relief Valves3.5%
Valves26.0%
Blowdowns0.8%
Connectors24.4%
Compressor Seals23.4%
Crankcase Vents4.2%
Pump Seals1.9%
Pressure Regulators0.4%
Source: Clearstone Engineering, 2002
Natural Gas Losses by Equipment TypeNatural Gas Losses by Equipment Type
Page 27Reducing Emissions, Increasing Efficiency, Maximizing Profits
How Much Methane is Emitted?How Much Methane is Emitted?
Component Type% of Total Methane
Emissions% Leaks
Estimated Average Methane Emissions per
Leaking Component (Mcf/Year)
Valves (Block & Control) 26.0% 7.4% 66Connectors 24.4% 1.2% 80Compressor Seals 23.4% 8.1% 372Open-Ended Lines 11.1% 10.0% 186Pressure Relief Valves 3.5% 2.9% 844
Methane Emissions from Leaking Components at Gas Plants
Source: Clearstone Engineering, 2002, Identification and Evaluation of Opportunities to Reduce Methane Losses at Four Gas Processing Plants. Report of results from field study of 4 gas processing plants in WY and TX to evaluate opportunities to economically reduce methane emissions.
Page 28Reducing Emissions, Increasing Efficiency, Maximizing Profits
How Much Methane is Emitted?How Much Methane is Emitted?
Summary of Natural Gas Losses from the Top Ten Leakers1.
Plant No. Gas Losses From Top 10
Leakers (Mcf/d)
Gas Losses From All Equipment
Leakers (Mcf/d)
Contribution By Top 10 Leakers
(%)
Contribution By Total Leakers
(%) 1 43.8 122.5 35.7 1.78
2 133.4 206.5 64.6 2.32 3 224.1 352.5 63.6 1.66
4 76.5 211.3 36.2 1.75 Combined 477.8 892.84 53.5 1.85
1Excluding leakage into flare system
Page 29Reducing Emissions, Increasing Efficiency, Maximizing Profits
Screening and MeasurementScreening and Measurement
Summary of Screening and Measurement Techniques
Instrument/
Technique Effectiveness
Approximate
Capital Cost
Soap Solution
$
Electronic Gas Detectors
$$
Acoustic Detection/ Ultrasound Detection
$$$
TVA (FID)
$$$
Bagging
$$$
High Volume Sampler
$$$
Rotameter
$$
Source: EPA’s Lessons Learned Study
Page 30Reducing Emissions, Increasing Efficiency, Maximizing Profits
Cost-Effective RepairsCost-Effective Repairs
Repair the Cost Effective Components
Component Value of
Lost gas1 ($)
Estimated Repair cost
($)
Payback (Months)
Plug Valve: Valve Body 12,641 200 0.2
Union: Fuel Gas Line 12,155 100 0.1
Threaded Connection 10,446 10 0.0
Distance Piece: Rod Packing 7,649 2,000 3.1
Open-Ended Line 6.959 60 0.1
Compressor Seals 5,783 2,000 4.2
Gate Valve 4,729 60 0.2
Source: Hydrocarbon Processing, May 2002 1Based on $3/Mcf gas price
Page 31Reducing Emissions, Increasing Efficiency, Maximizing Profits
DI&M - Partner ExperienceDI&M - Partner Experience
Partner APartner A: leaking cylinder head tightened, which : leaking cylinder head tightened, which reduced methane emissions from almost 64,000 reduced methane emissions from almost 64,000 Mcf/yr to 3,300 Mcf/yrMcf/yr to 3,300 Mcf/yr Repair required 9 man-hours labor and annualized gas Repair required 9 man-hours labor and annualized gas
savings were approximately 60,700 Mcf/yr. At $3/Mcf, savings were approximately 60,700 Mcf/yr. At $3/Mcf, the estimated value of gas saved was $182,100/yrthe estimated value of gas saved was $182,100/yr
Partner BPartner B: one-inch pressure relief valve emitted : one-inch pressure relief valve emitted almost 36,774 Mcf/yralmost 36,774 Mcf/yr Five man-hours labor and $125 materials eliminated Five man-hours labor and $125 materials eliminated
leak. The annualized value of gas saved was more leak. The annualized value of gas saved was more than $110,300 at $3/Mcfthan $110,300 at $3/Mcf
Page 32Reducing Emissions, Increasing Efficiency, Maximizing Profits
DI&M - Partner ExperienceDI&M - Partner Experience
Partner C: blowdown valve leaked almost 14,500 Mcf/yrPartner C: blowdown valve leaked almost 14,500 Mcf/yr Rather than replace expensive valve, the Partner spent just Rather than replace expensive valve, the Partner spent just
$720 on labor and materials to reduce emissions to ~100 $720 on labor and materials to reduce emissions to ~100 Mcf/yr Mcf/yr
Gas saved was approximately 14,400 Mcf/yr, worth $43,200 Gas saved was approximately 14,400 Mcf/yr, worth $43,200 at $3/Mcfat $3/Mcf
Partner D: tube fitting leaked 4,121 Mcf/yrPartner D: tube fitting leaked 4,121 Mcf/yr Very quick repair requiring only five minutes reduced leak Very quick repair requiring only five minutes reduced leak
rate to 10 Mcf/yrrate to 10 Mcf/yr Annualized value of gas saved was ~ $12,300 at $3/Mcf Annualized value of gas saved was ~ $12,300 at $3/Mcf
Page 33Reducing Emissions, Increasing Efficiency, Maximizing Profits
Discussion QuestionsDiscussion Questions
To what extent are you implementing these To what extent are you implementing these opportunities?opportunities?
Can you suggest other opportunities?Can you suggest other opportunities? How could these opportunities be improved How could these opportunities be improved
upon or altered for use in your operation?upon or altered for use in your operation? What are the barriers (technological, What are the barriers (technological,
economic, lack of information, regulatory, economic, lack of information, regulatory, etc.) that are preventing you from etc.) that are preventing you from implementing these practices?implementing these practices?