The Environmental Protection Agency (EPA) recently published significant updates to 40 CFR part 60 subpart OOOOb in the Federal Register mandating new emissions monitoring requirements for oil and gas facilities and well sites, among other sources.
In this article, we focus on the EPA’s monitoring and inspection requirements targeting fugitive emissions from oil and gas production sites and facilities.
What Facilities are Subject to OOOOb?
The final rule outlines the applicability of standards to different types of facilities within the oil and gas sector, including:
- Well Affected Facilities: Includes single wells drilled for oil or natural gas production.
- Compressor Affected Facilities: Encompasses single centrifugal or reciprocating compressors.
- Process Controller Affected Facilities: Refers to collections of natural gas-driven process controllers.
- Storage Vessel Affected Facilities: Covers tank batteries with specified emissions potential.
- Process Unit Equipment Affected Facilities: Encompasses all equipment within a process unit at an onshore natural gas processing plant.
- Sweetening Unit Affected Facilities: Includes units processing natural gas with subsequent sulfur recovery.
- Pump Affected Facilities: Consists of collections of natural gas-driven pumps.
- Fugitive Emissions Components Affected Facilities: Encompasses fugitive emissions components at various facility types.
In this article our focus is on Fugitive Emissions Components Affected Facilities.
The Table below summarizes the applicability of the various Subparts to 40 CFR part 60 by when the source (facility) was placed into service (Source: Page 16828 Federal Register/Vol. 89, No. 47/Friday, March 8, 2024/Rules and Regulations).
| Subpart | Source Type | Applicable Dates |
|---|---|---|
| 40 CFR part 60, subpart OOOO | New, modified, or reconstructed sources | After 08/23/2011, and on or before 09/18/2015 |
| 40 CFR part 60, subpart OOOOa | New, modified, or reconstructed sources | After 09/18/2015, and on or before 12/06/2022 |
| 40 CFR part 60, subpart OOOOb | New, modified, or reconstructed sources | After 12/06/2022 |
| 40 CFR part 60, subpart OOOOc | Existing sources | On or before 12/06/2022 |
Facilities affected by the OOOOb and OOOOc standards must ensure compliance by May 7, 2024, or upon initial startup, whichever occurs later.
Monitoring Standards for Fugitive Emissions Components
The rule defines the standards for monitoring and repairing fugitive emissions components, depending on the facility type, outlined in subpart § 60.5397b as summarized in the table below (Source: X. Summary of Final Standards NSPS OOOOb and EG OOOOc, Page 16871 Federal Register/Vol. 89, No. 47/Friday, March 8, 2024/Rules and Regulations).
| Type | Frequency | Type |
|---|---|---|
| Fugitive emissions component affected facilities located at single wellhead only well sites | At least quarterly* | Audible, Visual, and Olfactory (AVO), or any other detection method, after the initial survey (see Note below for exceptions) |
| fugitive emissions component affected facilities located at small well sites | At least quarterly* | AVO, or any other detection method, after the initial survey (see Note below for exceptions)and include a visual inspection of all thief hatches and other openings on the storage vessel that are fugitive emissions components must be conducted in conjunction with the monitoring survey to ensure that they are kept closed and sealed at all times except during times of adding or removing material, inspecting or sampling material, or during required maintenance operations. At small well sites with a separator, a visual inspection of all separator dump valves to ensure the dump valve is free of debris and not stuck in an open position must be conducted in conjunction with the monitoring survey |
| fugitive emissions components affected facilities located at multi-wellhead only well sites | A monitoring survey must be conducted at least quarterly* | AVO at least quarterly (see Note below for exceptions) OGI at least semiannually or Method 21 after the initial survey. Consecutive semiannual surveys must be conducted at least 4 months apart and no more than 7 months apart. |
| fugitive emissions components affected facilities located at well sites or centralized production facilities that contain the major production and processing equipment | At least quarterly* | OGI or Method 21. Consecutive quarterly monitoring surveys must be conducted at least 60 calendar days apart. (see Note below for exceptions) |
*NOTE: If the fugitive emissions components affected facilities contain the following major production and processing equipment, inspections must occur at least bimonthly using AVO, or any other detection method, after the initial survey, to include all thief hatches and separator dump valves:
- One or more controlled storage vessels or tank batteries.
- One or more control devices.
- One or more natural gas-driven process controllers or pumps.
- Two or more pieces of major production and processing equipment not specified above.
READ MORE: Enviromech™ Composite Thief Hatch for a complete seal over the long run.
Repair Requirements
The final rule also spells out the requirements for repairing sources of fugitive emissions in subpart § 60.5397(h) as summarized in the table below (Source: Page 17064 Federal Register/Vol. 89, No. 47/Friday, March 8, 2024/Rules and Regulations):
- A first attempt at repair shall be made no later than 15 calendar days after detection of fugitive emissions that were identified using AVO.
- If using OGI or Method 21 to monitor the fugitive emissions components affected facilities, then a first attempt at repair shall be made no later than 30 calendar days after detection of the fugitive emissions.
- The repair shall be completed no later than 15 calendar days after the first attempt for sources detected using AVO and 30 calendar days after the first attempt for sources detected via OGI or Method 21.
It is important to note that the rules provide some flexibility for scenarios when repairs may encounter delays under specific circumstances. These situations include where the repair is technically unfeasible, necessitates a vent blowdown, requires a compressor station shutdown, mandates a well shutdown or shut-in, or poses safety risks during unit operation. In such cases, the repair must be carried out during the subsequent scheduled compressor station shut down for maintenance, planned well shutdown, scheduled well shut-in, following a scheduled vent blowdown, or within two years of identifying the fugitive emissions, whichever comes first.
Note that EPA defines a “vent blowdown” as the deliberate opening of one or more blowdown valves to depressurize significant production and processing equipment, excluding storage vessels.
Monitoring Fugitive Emissions Using Alternative Technologies
In the final rule, the EPA provides a pathway for using alternative monitoring technologies for both periodic and continuous monitoring. Alternative methods for monitoring fugitive emissions have the potential to deliver several benefits, including but not limited to lower costs, faster response to detected leaks, and avoiding the loss of valuable natural gas resources.
Alternatives could include on-site OGI, monitoring from space-based satellites, aircraft and other technologies, but the key here is that the EPA must approve their use for the specific site application before an operator can adopt the alternative(s) as well as the technology characteristics and corresponding detection threshold at a 90 percent probability of detection.
We will cover alternative monitoring technologies and the process for seeking approval for their use in a separate article.
In summary, the recent updates to 40 CFR part 60, subpart OOOOb are comprehensive with the objective of reducing emissions from oil and gas production operations. In this article, we covered the requirements for monitoring and detecting fugitive emissions from specific types and the repair requirements.
We plan on covering updates to Appendix K (LDAR at onshore gas processing plants), alternative emissions monitoring technologies and the super-emitter program soon.
Need LDAR services or help understanding how the new requirements impact your emissions monitoring program? Contact us today for a free consultation.
The Encino Advantage
Encino Environmental Services 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.
