In December 2023, the Environmental Protection Agency (EPA) introduced groundbreaking updates to its air emissions regulations with the unveiling of the New Source Performance Standards (NSPS) OOOOb and EG OOOOc, targeting emissions within the oil and gas industry. Notably, these revisions introduce stringent criteria for both flares and enclosed combustion devices, with a primary aim of mitigating methane emissions.
The finalized rule applies to all facilities falling under NSPS OOOOb within the Oil and Gas sector. It specifically addresses unlit and malfunctioning flares, which the agency recognized as significant contributors to fugitive methane emissions.
Although the final rule amalgamates flares and enclosed combustors under a single “combustion devices” umbrella, this discussion will concentrate solely on flares. In this article we delve into the potential implications of the final rule as well as its scope, applicability, and the necessary steps for compliance, with a focus on the requirements pertaining to flares.
Final Rule Requirements for Combustion Control Devices (Flares)
The final rule emphasizes the importance of combustion control devices, particularly flares, in mitigating emissions from Oil and Gas operations. New mandates under NSPS OOOOb include:
- All flares and all enclosed combustion devices must operate with a continuously burning pilot flame and with no visible emissions, except for periods not to exceed a total of one (1) minute during any 15-minute period.
- Flares must be viewed with an optical gas imaging (OGI) camera during fugitive emissions inspections conducted with OGI to ensure that the flare is lit and that there are no uncontrolled emissions coming from the flare.
- Ensure that the flare is operating properly during Audio, Visual, and Olfactory (AVO) inspections by visually confirming that the pilot flame is lit and operating properly.
- Maintain records and report the results of all performance tests conducted on combustion control devices.
Additionally, 40 CFR 60.5417b(c) was revised to clarify that monitoring systems that check for the presence of a pilot flame must record a reading at least once every five (5) minutes and clarified the method for averaging parameters.
Optional Technology for Flare Pilot Monitoring
Although the agency acknowledged the potential for using Video Imaging Spectro-Radiometry (VISR) technology for monitoring flare combustion efficiency, it did not formally approve VISR for this purpose. Instead, the new rule provides operators a pathway for requesting approval of VISR, Simplified VISR or other similar technologies, on a site-specific basis.
One potential advantage of using VISR or other approved alternatives for continuous combustion efficiency monitoring, is that an operator can be exempted from monthly EPA Method 22 (visual determination of fugitive emissions) inspections.
We plan to cover this in more detail in a future article.
The Agni Optical Gas Imaging (OGI) Solution
For operators seeking an effective flare monitoring and compliance solution, the Sensia Agni Optical Gas Imaging (OGI) camera from Encino is a leading option. The Agni camera can help you monitor flare stack performance continuously, ensuring operational safety and provide visual flame confirmation.
Benefits and Features:
- RedLook technology translates infrared imaging to artificial vision for human interpretation, creating huge potential in a single multifunctional interface.
- Agni, powered by Redlook, is the most advanced 24/7 monitoring system specially designed for the surveillance of pilot flames and flared gases. Redlook is the system that interprets the information sensed and reported by Agni and includes artificial intelligence capabilities.
- Flare Efficiency – Smoke index warning, destruction and removal efficiency (DRE) indicator
- Flare Monitoring – Real time performance monitoring and early detection of liquid carryover (burning rain)
- Continuous flare pilot flame monitoring.
- Continuous flare monitoring.
- Automatic and precise fire detection for contributing to a safe and efficient operation.
LEARN MORE: Flare Monitoring using Agni OGI cameras from Encino Environmental
Summary
In summary, one of the primary goals of EPA’s inclusions in NSPS OOOOb is minimize fugitive emissions from combustion control devices, including flares, by ensuring their proper and efficient operation.
Encino Environmental has the technologies and expertise to be your ally for meeting these stringent regulations efficiently and sustainably.
The Agni camera from our strategic partner SENSIA is a reliable and effective solution for continuous flare and pilot flame monitoring. 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 systematic 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.
The Encino Advantage
Encino offers the most comprehensive lineup of environmental performance solutions, services, and expertise for mitigating emissions from Energy operations with a focus on Oil & Gas and Biogas markets. We are a pioneer in emissions monitoring in the Energy sector, providing clients with a complete range of environmental services to help companies comply with regulation requirements and voluntary sustainability objectives.
Our offerings include:
- CEMS (Continuous Emissions Monitoring Systems) via AI-enabled Optical Gas Imaging (OGI)
- Satellite Monitoring for Methane and Visual applications via Satlantis micro satellites (EmSat™)
- Emissions performance testing for Engines and Industrial Stacks,
- LDAR (Leak Detection and Repair)
- Composite Thief Hatches (Enviromech™) composite thief hatches for a durable, long-term seal of liquid storage tanks
- Advanced environmental data software
- Advisory services
Our solutions help ensure regulatory compliance and ESG strategies and objectives. Encino operates across the U.S. covering all major oil and gas basins and select international markets.
We view ourselves as an oilfield services company, dedicated to helping operators improve their environmental and economic sustainability for providing the world with reliable and affordable energy.
Contact us today for a free consultation and evaluation of how Encino can help you achieve environmental performance that generates economic results.
About Encino Environmental Services
Formed in 2010 and headquartered in Houston, Texas, Encino Environmental Services, LLC is an emissions performance testing fand monitoring firm that specializes in Engine and Stack testing, LDAR (leak detection and repair), CEMS (continuous emissions monitoring systems) via AI-enabled Optical Gas Imaging (OGI) cameras, environmental consulting, combustion analysis, Satellite monitoring for methane emissions and visible applications, and advanced environmental data platforms for the measurement and minimization of emissions to support regulatory compliance and ESG strategies and objectives. The Company operates across the U.S. covering all major oil and gas basins and select international markets.
