Recent updates to 40 CFR Part 60, specifically Subpart OOOOb (60.5398b), significantly shift how emissions monitoring is performed in the oil and gas industry. A key feature of the new rule is the pathway the Environmental Protection Agency (EPA) has paved the way for the adoption of Alternative Technologies for monitoring emissions at well sites and facilities. This provides operators with the potential to replace traditional, labor-intensive methods like Leak Detection and Repair (LDAR) with more efficient and effective technology-based approaches.
The term “Alternative Technologies” is a large umbrella covering a range of innovative approaches, including but not limited to continuous emissions monitoring systems (CEMS), satellite-based systems, aircraft and airborne sensors, and other emerging technologies in the future. These methods offer the potential for real-time or near-real-time monitoring, which can provide more accurate and timely data on emissions, allowing for quicker identification and mitigation of leaks or other issues.
Moving away from LDAR traditional methods like EPA Method 21 or optical gas imaging (OGI) camera inspections could address some of the limitations associated with these approaches, such as the intermittent nature of inspections and the potential for missed emissions events. Additionally, Alternative Technologies used in combination with each other and/or traditional methods provide operators several advantages in terms of scalability, cost savings and richness of emissions data, allowing for monitoring across a wider range of sources and locations.
The good news is that the EPA did not define specific technologies, which could have excluded future innovations, and instead created a process for approving any alternative method that meets specific performance criteria. In this article, we cover the process EPA has established for obtaining approval to use Alternative Technologies for monitoring Oil and Gas emissions.
Alternative Technology for Emissions Monitoring in the Oil and Gas Sector
One of the key provisions within the updated regulations is the inclusion of using an Alternative Technology under § 60.5398b, which outlines alternative standards for fugitive emissions components affected facilities when employing alternative technologies. These technologies offer both periodic screening and continuous monitoring capabilities, providing operators with greater flexibility and accuracy in emissions management.
The EPA defines two types of alternative technologies:
Periodic Screening: Operators can opt for periodic screenings using approved methane measurement technologies. These screenings must meet specified detection thresholds and frequency requirements. Additionally, operators must notify the Administrator of their adoption of alternative standards and ensure compliance through annual reporting.
Continuous Monitoring: Alternatively, operators may choose continuous monitoring. The EPA defines “continuous” as “…the ability of a methane monitoring system to determine and record a valid methane mass emissions rate or equivalent of affected facilities at least once for every 12-hour block.” The detection system must be able to detect at least 0.40 kg/hr (0.88 lb/hr) of methane. Additionally, continuous monitoring systems must undergo regular health checks and transmit data at specified intervals. Compliance also requires adherence to a comprehensive monitoring plan and reporting obligations.
READ MORE: White Paper: Best Practices for Emissions Monitoring in the Energy Sector
Inspection Requirements for Alternative Technologies for Emissions Monitoring
The EPA has established requirements for the frequency of periodic OGI and Audible, Visual, and Olfactory (AVO) inspections at affected facilities using approved Alternative Technology methods.
Table 1 (below) specifies the minimum screening frequencies for any Alternative Technology at affected locations with quarterly inspection requirements, based on its minimum detection threshold.
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.
| Minimum Screening Freequency | Minimum Detection Threshold (kg/hr) |
|---|---|
| Quarterly | ≤1 |
| Bimonthly | ≤2 |
| Bimonthly + Annual OGI | ≤10 |
| Monthly | ≤ 5 |
| Monthly + Annual OGI | ≤15 |
Table 2 (below) summarizes the minimum screening frequencies for any Alternative Technology at affected locations with semiannual inspection requirements, based on its minimum detection threshold.
Table 2 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 Semiannual OGI or EPA Method 21 Monitoring.
| Minimum Screening Freequency | Minimum Detection Threshold (kg/hr) |
|---|---|
| Semiannual | ≤ 1 |
| Triannual | ≤ 2 |
| Triannual + Annual OGI | ≤10 |
| Quarterly | ≤ 5 |
| Quarterly + Annual OGI | ≤15 |
| Bimonthly | ≤15 |
Pathway for Approving Alternative Technologies
Given the variety of new emissions monitoring technologies that have come to market in recent years and to encourage continued innovation, instead of approving specific Alternative Technologies by name, the EPA established a clear pathway for approving technology-based alternatives to accommodate alternative methods that are available today and potentially in the future.
One of the key benefits of using one or more Alternative Technologies is to eliminate or minimize traditional inspections like AVO/OGI LDAR. Any proposed Alternative Technology, however, must undergo rigorous evaluation and approval by the Administrator.
The process of obtaining approval includes:
Submission and Review: An organization seeking approval for alternative technologies must submit comprehensive requests outlining the proposed technology’s capabilities and compliance with regulatory standards. The Administrator then conducts a thorough review, considering factors such as detection thresholds, measurement accuracy, and operational protocols.
Note that almost any organization may apply for an alternative test method to be considered, including an operator, system provider or manufacturer of the measurement system based on advanced methane detection technology.
Determination: The EPA can take up to 90 days to make an initial determination assessing the completeness of the application. If the assessment is satisfactory, it can take up to 270 days for the EPA Administrator to issue an approval or disapproval decision on the adequacy of the proposed Alternative Technology. Approvals may be site-specific or broadly applicable, depending on the technology’s efficacy and reliability.
It is important to note that the application submittal is complex and comprehensive, more than can be covered in a single article. We encourage interested parties to both familiarize themselves with the regulations and/or obtain expert advisory.
READ MORE: Advisory Services from Encino Environmental
Alternative Technologies for Emissions Monitoring from Encino
Encino Environmental offers a variety of Alternative Technology methods for emissions monitoring to complement its traditional compliance solutions, providing you with monitoring capability from space to ground.
Our Alternative Technology offerings include:
- EmVision™ CEMS (Continuous Emissions Monitoring Systems) via AI-enabled Optical Gas Imaging (OGI)
- EmSat™ Satellite Monitoring for Methane and Visual applications via Satlantis micro satellites
We can help you evaluate which technologies are right for your operations, given its compliance and voluntary emissions performance objectives and develop a comprehensive emissions solution.
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.
Other offerings include:
- 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 and 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.
