The New OOOOb Regulations Mandate
In March 2024, the Environmental Protection Agency (EPA) published its final new regulations to 40 CFR part 60 subpart OOOOb (“quad-o” or OOOOb) in the Federal Register and they went into effect in May 2024. The new OOOOb regulations mandate far-reaching new emissions performance standards and compliance requirements for the oil and gas industry in the United States.
The table below summarizes which subparts of 40 CFR Part 60 apply to what facility type, and their effective dates.
| 40 CFR Part 60 Subpart | Facility (Source) Type | Effective Dates |
|---|---|---|
| Subpart OOOO | New, modified, or reconstructed sources | After 08/23/2011, and on or before 09/18/2015 |
| Subpart OOOOa | New, modified, or reconstructed sources | After 09/18/2015, and on or before 12/06/2022 |
| Subpart OOOOb | New, modified, or reconstructed sources | After 12/06/2022 |
| Subpart OOOOc | Existing sources | On or before 12/06/2022 |
Are My Facilities Subject to OOOOb
and EG OOOOc?
By 2029, just about every oil and gas well, tank battery, production facility, and compressor station will be subject to the 95% reduction standard under NSPS OOOOb or EG OOOOc. The types of well sites and facilities, or “Sources” of emissions as the EPA calls them, include just about every type of oil and gas production operation.
If you own or operate one of the facility types in the table below, then that source is subject to New Source Performance Standards (NSPS) OOOOb or Emissions Guidelines (EG) OOOOc, depending on when it was placed into service.
| Facility Type | Description |
|---|---|
| Well Affected Facilities | Single wells drilled for oil or natural gas production |
| Compressor Affected Facilities | Single centrifugal or reciprocating compressors |
| Process Controller Affected Facilities | Collections of natural gas-driven process controllers |
| Storage Vessel Affected Facilities | Tank batteries with specified emissions potential |
| Process Unit Equipment Affected Facilities | All equipment within a process unit at an onshore natural gas processing plant |
| Sweetening Unit Affected Facilities | Units processing natural gas with subsequent sulfur recovery |
| Pump Affected Facilities | Collections of natural gas-driven pumps |
| Fugitive Emissions Components Affected Facilities | Fugitive emissions components at various facility types |
The Future is Now – EG OOOOc
The industry’s primary focus has understandably been on NSPS OOOOb, leaving many to wonder: What is EG OOOOc?
Notably, NSPS OOOOb complements both the original OOOO and the subsequent OOOOa Subparts of 40 CFR Part 60, covering all affected sources placed into service between August 23, 2011, and December 6, 2022.
In contrast, EG OOOOc is not a regulation itself but a “model rule” designed for State agencies and Tribal land administrators to use when crafting new regulations for affected sources placed into service before December 6, 2022. Once EG OOOOc takes effect in 2029, after all the approval of the State Implementation Plan (SIP) of each State, nearly all affected sources will be subject to updated regulatory standards.
The EPA has given State and Tribal agencies until March 2026 to submit the SIP for review, with final approval expected in 2027. If a plan is not submitted or deemed inadequate, the EPA will impose a federal plan, with EG OOOOc taking full effect in 2029.
There are two key considerations when it comes to understanding the potential impact of EG OOOOc. First, readers should know that the plans developed by State and Tribal agencies must be as stringent as those in OOOOb, but they can also be more stringent..
Second, keep in mind that even if you operate an existing facility that is not subject to NSPS OOOOb, it is not out of the regulatory “woods,” so to speak. If an operator of a designated facility makes a change to a facility or facility component that meets the definition of modification after December 6, 2022, then that facility becomes subject to subpart OOOOb, superseding the existing OOOOc applicability. (Source: Page 17143 of the Federal Register/Vol. 89, No. 47/Friday, March 8, 2024/Rules and Regulations, §60.5375c).
Encino’s Environmental Performance Solutions for NSPS OOOOb and EG OOOOc Compliance
The new regulations are voluminous, making it both tedious and difficult to comprehend. A frequently asked question we get is: How can Encino help me comply with OOOOb? The table below helps answer that question.
Please scroll left, right, up or down to see the entire matrix.
How Encino Environmental Solutions Make NSPS OOOOb and EG OOOOc Compliance Easy
Encino Environmental solutions make it easy to comply with NSPS OOOOb and EG OOOOc.
EmSat™ High Resolution Satellite Emissions Monitoring
When it comes to the Super Emitter Response Program (SERP), the best defense against spurious claims and scrutiny is a proactive offense. Encino Environmental Services offers Oil and Gas operators an effective and proactive defense with our EmSat satellite methane detection system.
- Proactive Defense. Gain awareness of a super-emitter event and other significant leaks before a third-party submits a report to the EPA and generates a notification. Minimize the impact of any event and have the data to disprove any false reports.
- Comprehensive Monitoring for Early Warning. Cost-effective monitoring of entire fields and infrastructure, including hard-to-reach operations like offshore platforms, ensuring early detection of methane emissions.
- Optimized Deployment. Enables efficient deployment of Leak Detection and Repair (LDAR) crews to areas with the highest impact, minimizing false positives and maximizing emission reductions.
- Integrated Solutions. Combined with EmVision™ Continuous Emissions Monitoring System (CEMS), EmSat delivers comprehensive, verifiable data for precise emissions management and compliance with regulatory requirements.
- OGMP 2.0 Certification. Satellite methane monitoring can be used to meet OGMP 2.0 Level 5 purposes.
READ MORE: EmSat Satellite Methane Detection System from Encino Environmental
Enviromech™ Composite Thief Hatch
Standard thief hatch integrity degrades over time and with exposure to the corrosive environments of liquids storage tanks (hydrocarbons and produced water) and seasonal changes in temperature and precipitation. As a result, legacy thief hatches have been recognized as one of the most significant sources of fugitive emissions of methane and Volatile Organic Compounds (VOC).
Encino’s proprietary EnviromechTM composite thief hatch is a breakthrough product, manufactured in an AS 9100/ISO:9001 facility in the USA, ensuring a complete seal of the tank over the long-term and in varying weather conditions, eliminating the key source of liquid storage tank emissions.
- Made from durable composite material resistant to corrosion, warping and morphing.
- Greater integrity over the long-term, mitigating emissions from liquid storage tanks.
- Improved well site safety profile.
- Low-cost, high-impact solution for both new tanks and retrofits.
- Manufactured in an AS 9100/ISO:9001 facility in the USA.
READ MORE: Eliminating the Key Source of Liquid Storage Tank Emissions
EmVision™ Quantitative Optical Gas Imaging (QOGI) CEMS System
EmVision quantitative optical gas imaging delivers accurate, actionable, and auditable emissions data providing you with fewer false positive alerts, a true picture of your emissions profile, and confidence in reporting from tactical compliance to strategic ESG.
- Visual continuous emissions monitoring at the well site or facility.
- High-definition, multispectral and hyperspectral imaging technology for intelligent, real-time analysis and quantification.
- Real-time visual leak detection that you can see.
- Accurate quantification of emissions volumes.
- Maximize the ROI on LDAR teams.
- Fix leaks fast, keep product in the pipe.
- Achieve environmental performance goals.
- Improved safety profile.
- Capitalize on certified natural gas markets, including RSG.
READ MORE: EmVision™ Quantitative Optical Gas Imaging (QOGI) CEMS system
Engine Performance Emissions Testing
Encino operates advanced mobile emissions performance engine testing laboratories that are compliant with US EPA testing protocols to measure criteria pollutants and speciated GHG compounds, including methane and CO2. Our proprietary systems, managed by highly skilled Encino technicians, deliver near real-time data, expediting diagnosis and enabling the implementation of performance optimization strategies.
- Reliable and comprehensive engine testing.
- Electronic Reporting into EPA’s CEDRI.
- Measure and understand the emissions profile of key assets and infrastructure.
- Can be combined with EmVision™ and EmSAT™ to expand measurement coverage.
- Near real-time data for quick diagnosis and performance optimization.
READ MORE: Emissions Source Testing Across the Energy Value Chain
READ MORE: CEDRI Reporting FAQ
Enclosed Combustion Device (ECD) Performance Testing
Encino offers Enclosed Combustion Device (ECD) testing for Method 25A, for OOOOb compliance. Utilizing approved EPA technologies and staff with comprehensive knowledge on combustion devices and operations, we offer a solution to the ever-changing regulations and needs of our customers. This method is applicable for the determination of total gaseous organic concentration of vapors, including methane, consisting primarily of alkanes, alkenes, and/or arenes (aromatic hydrocarbons).
- Compliance Testing:Verifying that the ECD adheres to local, state, and federal environmental regulations, including EPA standards. This process typically involves measuring the destruction and removal efficiency (DRE) of VOCs and HAPs to ensure emissions stay within permitted levels.
- Performance Testing:Assessing the ECD’s efficiency and effectiveness in pollutant destruction. This may involve testing under various operating conditions to identify optimal performance parameters.
- Safety Testing:Ensuring the ECD operates safely across different scenarios, including normal operation, startup, shutdown, and emergency situations. This includes checking for leaks, ensuring the proper function of safety devices, and confirming compliance with safety standards.
READ MORE: Determine The Total Gaseous Organic Concentration from Your ECDs
Leak Detection and Repair (LDAR)
Achieve your Low Carbon Economy (LCE) goals with state-of-the-art leak detection and repair (LDAR) services from Encino Environmental Services. Our skilled LDAR crews use class-leading technology, including quantitative optical gas imaging (QOGI) cameras, and are unmatched in their professionalism. Encino LDAR technicians have decades of experience conducting surveys for both compliance and voluntary emissions reduction initiatives.
- OGMP 2.0 (Level 4 and Level 5 “Gold Standard” reporting).
- Meet NSPS OOOOb requirement.
- Comply with Method 21 LDAR (OOOOa, VVA, and additional permit conditions).
- Support certified natural gas initiatives.
- Support Voluntary Emissions Reduction (VER) initiatives for Carbon Capture Credits and shelter from Methane Tax regulations and other emissions reduction goals.
- NSPS KKK compliance for gas plants.
- Texas 28M Series.
- Colorado Reg 7.
READ MORE: Meet Today’s Standards and Tomorrow’s Regulations Appendix K & NSPS OOOOb/c
Net Heat Value (NHV) Vent Gas Testing for Flares & Enclosed Combustion Devices
We are revolutionizing net heating value (NHV) testing with an EPA-approved mobile-based measurement technology, designed to meet NSPS OOOOb regulatory compliance. Our compact system requires no site power and minimal interface with site infrastructure allowing for rapid deployments across multiple sites. This innovative solution provides real-time data output and hourly averaging, ensuring immediate and accurate results to meet regulations. Ultimately, the Encino NHV solution outweighs all other methods by reducing costs and enhancing efficiencies for achieving environmental compliance.
Mobile-Based Measurement Technology:
- Provides real-time data analysis for the NHV of gas streams.
- Ensure accurate and timely results to help you meet regulatory requirements with confidence.
Compact and Efficient Design:
- Our system is housed within a 5’x12’ trailer, ensuring a compact footprint for easy deployment.
- Requires no site power and minimal interface, offering flexibility and ease of use in various field conditions.
READ MORE: Achieving Compliance with Cost-Effective, Real-Time Measurement Technology
Flare Monitoring
Encino’s high-definition Optical Gas Imaging (OGI) solutions help you monitor flare stack performance, ensuring operational safety and evidence environmental performance through measurement and quantification of emissions.
- Assist with assessing compliance with combustion efficiency requirements.
- Measurement and quantification of flare stack Combustion Efficiency (CE) and Destruction and Removal Efficiency (DRE).
- Achieve ESG performance objectives.
- Fix inoperable flares quickly and maintain a safe jobsite and community.
- Maintain a positive public image and community relations.
READ MORE: Ensured Flame Efficiency
Technology-Neutral Advisory Services
Encino helps clients get the most out of their investment in environmental performance solutions while meeting their compliance obligations. No matter what technology you are using, we can help you get the most out of it.
- Data Services and Management. Data services to synthesize multiple data sources into a comprehensive view of your emissions profile from the ground up to space and establish one source of truth for emissions data.
- ESG and GHG Reporting. Reporting for ESG and Compliance needs based on comprehensive, reliable, and verifiable data.
- Permitting and Regulatory Advisory. Experienced advisory for emissions reduction strategy including tools and resources for preparing compliance assessments and permits.
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 artificial intelligence (AI)-enabled Optical Gas Imaging (OGI)
- Satellite Monitoring for Methane and Visual applications via Satlantis micro satellites (EmSat™)
- Emissions performance testing for Engines, Combustors, 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
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.
The Enviromech Composite Thief Hatch can help you mitigate the risk of tank battery emissions resulting from faulty, malfunctioning, and aging thief hatches, and reduce operating costs.
Contact us today for a free consultation and evaluation of how Encino can help you achieve environmental performance that generates economic results.
