Introduction to NSPS OOOOb
The Environmental Protection Agency (EPA) announced the adoption of a comprehensive regulatory framework with its Final Rule for Methane Reduction (NSPS OOOOb, in addition to OOOOc and Appendix K), aimed at curbing methane emissions from the oil and gas industry. This is the first of several articles we are developing to help operators understand the implications of the 1,690-page rule for their existing and anticipated well sites and facilities and compliance solutions. This is a short overview, and we plan to issue more in-depth articles in the near future.
General Factors
Applicability Date Extension. Operators can breathe a small sigh of relief knowing that the applicability date for Subpart OOOOa has been extended to December 6, 2022, from November 15, 2021, as originally proposed. Pushing back the applicability date allows affected facilities that began operations between September 18, 2015, and December 6, 2022, to continue with the current OOOOa practices.
Alternative Technologies and Tiered Approach. The rule now permits the use of various alternative technologies or combinations thereof for leak detection for well sites, centralized production facilities, and compressor stations. This flexibility provides operators with opportunities to tailor their emissions monitoring and compliance strategies to the needs of specific locations and their strategic emissions reduction goals.
For example, the table below summarizes the screening frequency with minimum detection threshold of the technology used for the screening at well site, centralized production facilities, and compressor stations subject to AVO inspections with quarterly OGI or EPA Method 21 monitoring (this table is just one of several in the final rule).
Source: EPA Final Rule 40 CFR Part 60, RIN 2060-AV16 (Table 1 to Subpart OOOOb of Part 60—Alternative Technology Periodic Screening Frequency at Well Sites, Centralized Production Facilities, and Compressor Stations Subject to AVO Inspections with Quarterly OGI or EPA Method 21 Monitoring, p. 1295)
Importantly, the rule establishes detection performance standards, instead of mandating specific technologies.
Adopting an alternative monitoring technology will require owners and operators, rather than solely technology providers, to demonstrate the required emission reduction equivalence of the alternative monitoring program with respect to OGI or EPA Method 21 performance. The implication is that a specification sheet or marketing collateral from a vendor is not enough to evidence that a specific technology meets the minimum detection requirements. Modeling of emission reductions equivalence will be required.
Super-Emitter Program
The Super-Emitter Program will be in effect and includes some potentially controversial elements.
Definition of Super Emitter Event. EPA defined an event with an emission rate of 100 kg/hr or more as a super emitter event, the same way it was originally proposed in the December 2022 supplemental proposal.
Certified Third-Party Verifiers. EPA will accredit each third-party verifier individually. It was noted that third-party verifiers are restricted to using satellite or airborne technologies. Other non-remote sensing technologies are not approved (e.g., excluding OGI, since it will require close access to a facility).
Flow of Information. Notably, the Super Emitter Program has reshaped the flow of information. Third-party notifiers, previously certified or approved by the EPA, will notify the EPA of a super emitter event. As it was originally proposed, third-party verifiers would send notice directly to owners and operators along with EPA, but in a nod to rumblings of potential legal challenges to the Constitutionality of that proposal, EPA is now the official notifier of a super emitter event. Per the final rule, the EPA will evaluate the received data and subsequently send notifications to operators and owners.
The Super Emitter Program supplements the periodic monitoring and repair work practice standards in NSPS OOOOb (and OOOOc after implemented by States) by requiring repair of the source of the super-emitter event. However, if the event happens on a OOOOa affected facility (e.g., tank subject to OOOOa with an open thief hatch), the program will serve as a notice only, and does not impose a requirement to remediate the problem (e.g., close the thief hatch).
The final rule includes amendments to NSPS OOOO and OOOOa to incorporate the requirement to investigate and report whether the super emitter event was caused by OOOO/OOOOa affected facility or associated equipment.
New Focus on Tank Battery Emissions
Emissions Reduction. The final rule includes an important addition to what was originally proposed by requiring storage vessels (i.e., tank batteries) to demonstrate a substantial 95% reduction in methane and VOC (volatile organic compound) emissions.
This requirement raises several issues, such as:
- What is the baseline from which the 95% reduction will be measured?
- What technologies are approved for evidencing the reduction?
- How does this requirement dovetail with the Waste Emission Charge (WEC) mandated by the Inflation Reduction Act?
We will be delving into more detail on answering these questions in future articles.
We do know that significant sources of tank battery emissions include worn thief hatches and seals. The Enviromech™ Composite Thief Hatch ensures a complete seal of the tank over the long-term and in varying weather conditions, reducing emissions and improving well site safety.
Additionally, the Enviromech Composite Thief Hatch is made of extremely durable composite material that is highly resistant to changes in environmental conditions, reducing maintenance, repair and replacement costs.
Handhelds (OGI Cameras) for Comprehensive Compliance
Leak Detection and Repair (LDAR) inspections are required for an expanded list of equipment along with specific flow rate requirements.
Process Controller Monitoring. Process controllers must undergo optical gas imaging (OGI) monitoring to maintain a methane emission rate of zero.
Wet Seal Centrifugal Compressors. Wet seal centrifugal compressors necessitate a substantial 95% reduction in methane and VOC emissions. LDAR is required. In addition, volumetric flow rates for compressor seals must be maintained at or below 3 scfm (9 scfm for Alaska).
Dry Seal Centrifugal Compressors. Dry seal centrifugal compressors require LDAR to ensure volumetric flow rates of 2 scfm or less.
Natural Gas-Driven Pumps. Pumps driven by natural gas must maintain zero methane and VOC emissions.
Natural Gas Processing Plants. Natural gas processing plants can follow LDAR with OGI following Appendix K, or alternatively, use Method 21.
Fugitive Emissions Monitoring. The final rule mandates fugitive emissions monitoring requirements as follows:
Source: EPA Final Rule 40 CFR Part 60, RIN 2060-AV16 (Table 26—Summary of Final EG Subpart OOOOc Presumptive Non-Numerical Standards, p. 681)
Phasing Out Routine Flaring
The final rule mandates a phase-out of routine flaring of natural gas from new oil wells, with a 2-year transition period. Many States regulatory agencies have been resisting a comprehensive ban on routine flaring, but the EPA has now made it official that the practice of routine flaring will be phased out.
Table 16 from the rule text provides a summary of allowance to routinely route associated gas to a flare or control device for NSPS OOOOb.
Source: EPA Final Rule 40 CFR Part 60, RIN 2060-AV16 (Table 16—Summary of Allowance to Routinely Route Associated Gas to a Flare or Control Device for NSPS OOOOb, p. 256)
EPA noted that “…the final rule provides a pathway to allow for the use of VISR (Video Imaging Spectral Radiometry), Simplified VISR, or other similar technology. In this pathway, an owner or operator could request an alternative test method to use a technology such as VISR that continuously monitors combustion efficiency or a technology such as Simplified VISR that continuously monitors NHVcz and NHVdil. The approval of such a request may be site-specific or may instead become broadly applicable, approved for a class of combustion devices, and listed on the EPA’s website as an alternative test method” (Source: EPA Final Rule 40 CFR Part 60, RIN 2060-AV16, Standards of Performance for New, Reconstructed, and Modified Sources and Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review, p. 577).
Encino Environmental can help operators navigate this transition, potentially by incorporating Agni technology for flare monitoring and visual flame confirmation.
Net Heating Value (NHV) Trailer Sampling Adjustments
Sampling Frequency Reduction. Sampling frequency for NHV trailers has been reduced to twice daily, for 14 days (28 samples). Each individual sample must have a minimum time of collection of at least one hour, with consecutive samples separated by at least 6 hours. If gas is intermittent (absence of gas when sampling), sampling should continue beyond the 14-day period until a minimum of 28 samples are collected. This replaced the previous hourly requirement over 10 days. Additionally, ongoing demonstrations are necessary, with three sampling activities every 5 years.
It is important to note that the samples must be taken during the period with the lowest expected NHV. Also, operators can request an alternative test method that demonstrates that the flare or enclosed combustion device reduces methane and VOC by 95% by weight or greater.
Continuous Monitoring Systems
The rule includes provisions for the use of advanced methane detection technologies that allow for continuous monitoring for fugitive emissions and emissions from covers and closed vent systems (CVS). The EPA also acknowledged that this type of methane detection technology could be used to identify super-emitter emissions events sooner.
We will be analyzing the rule closely and publishing our evaluation in a future article.
Summary
EPA’s adoption of its Final Rule for Methane Reduction (colloquially know as NSPS 0000b rule) marks a pivotal moment for the Oil & Gas industry, requiring operators to adopt innovative approaches for emissions reduction and compliance. The rule is comprehensive and voluminous, consisting of 1,690 pages, and as a practical matter it will take time to fully analyze. This overview is just the first of several articles we plan to publish to help the industry and clients both meet compliance requirements and achieve their voluntary emissions reduction goals.
Encino Environmental, with its cutting-edge technologies and expertise, stands as a valuable ally for operators striving to meet these stringent regulations efficiently and sustainably.
Utilizing SENSIA‘s industry leading handheld and fixed OGI solutions or providing them to clients to do so internally, Encino is well positioned to support industry even more in the future. Our bundled emissions offerings from ongoing monitoring to testing and compliance to reduction allow clients to maximize efficiency and cost effectiveness of solutions. Bundling services can also generate efficiencies and cost savings.
Together, we can work towards a cleaner, more environmentally responsible future.
Got questions on OOOOb and the Final Rule for Methane Reduction? Contact us today at (281) 201-3544 or support@encinoenviron.com for a free consultation and evaluation of how Encino can help you achieve environmental performance and compliance that generate economic results.
About Encino Environmental Services
Formed in 2010 and headquartered in Houston, Texas, Encino Environmental Services, LLC is an emissions performance testing and monitoring firm that specializes in environmental consulting, combustion analysis, LDAR (leak detection and repair) services, and CEMS (continuous emissions monitoring systems) technology.
Equipment from Sensia Solutions, a subsidiary of Encino, allows the integration of thermography and AI analytics for the leak detection and quantification (LDAQ) needs. Also, through its joint venture with Satlantis LLC, Encino hosts remote sensing technologies leveraging satellites for the monitoring of methane emissions, as well as advanced environmental data platforms for the measurement and minimization of emissions.
Encino supports permitting, regulatory compliance and strategic ESG initiatives across the U.S. covering all major oil and gas basins and select international markets.
