How to Optimize EPA Compliance for OOOOb and OOOOc with Advanced Emissions Monitoring Tech
The U.S. Environmental Protection Agency’s (EPA) final oil and gas methane rule was recently published to the Federal Register, establishing sweeping new methane reduction requirements. For the oil and gas industry, the clock is ticking; operators should be evaluating compliance strategies today to adapt to this new regulatory landscape. At Bridger Photonics, we’re working side by side with our industry partners to help them evaluate their options and implement compliance strategies that minimize emissions and maximize efficiency. The new rule became effective on May 7th, 2024.
There are two main sections to the rule: Subpart OOOOb and Subpart OOOOc. Subpart OOOOb applies to infrastructure that is new, modified or reconstructed after December 6th, 2022, while Subpart OOOOc is a set of guidelines for how states should develop their own requirements in the coming months and years via “state implementation plans,” or SIPs. These plans will cover older infrastructure sources from on or before December 6th, 2022. Additionally, the rule allows advanced tech to be used according to the OOOOb work practice for fugitive emissions monitoring at sites subject to the OOOOa rule.
There is much to unravel in the rule, especially surrounding the EPA’s allowance for operators to use advanced technology to meet leak detection requirements. This article will focus on that portion of the rule.
Here are a few of the main takeaways:
- Advanced technologies can be used for leak detection for EPA compliance for the first time.
- EPA will approve advanced technologies prior to their use for compliance.
- The required screening frequency depends on the capabilities of the advanced technology, and one or more approved technologies may be used.
A New Era for Methane Detection
While the methane rule prescribes extensive emissions reduction measures, it also opens the door for operators to utilize new and innovative technologies for their emissions monitoring programs. This is the first time there has been a clear pathway to use advanced methane detection technologies for EPA compliance. With this latest rule, it is truly a new era of methane detection for the oil and gas industry.
In the final rule, EPA notes that advanced detection technologies “have important advantages, including the ability to detect fugitive emissions quickly and cost-effectively in a manner that may be less susceptible to operator error or judgement than traditional leak detection technologies.”
To implement advanced technologies, the EPA outlined two alternative emissions monitoring frameworks. One of the frameworks is for periodic site screening, and the other is for fixed-sensor systems.
Periodic Emissions Monitoring
For the first time, the oil and gas production sector has some choice when it comes to conducting leak detection and repair for compliance purposes. The exact requirements depend on the emission rate detection sensitivity of the advanced tech, described as the Minimum Detection Threshold in EPA’s Periodic Screening Matrix, shown below.
When using less-sensitive technologies (e.g., a Minimum Detection Threshold, or detection sensitivity of ≤ 10 kg/hr), sites must be scanned with greater frequency and/or include an annual OGI survey. Technologies with better detection sensitivity (e.g. ≤ 2 kg/hr) require less frequent scans, and no OGI survey. An interim option is available for the quarterly scan frequency that allows operators to use a technology with a detection sensitivity of ≤ 3 kg/hr instead of ≤ 1 kg/hr for the first two years.
Operators may use a combination of technologies, but sites must be screened at least as frequently as the requirement associated with the least-sensitive method (i.e. the highest detection threshold). Any site screening instance in the matrices can be replaced with a default OGI survey.
Additionally, under the new rule, only sites with “confirmed detections” will need to be visited for follow-up using ground crews. This means crews can spend their time focusing on sites where there are emissions present. For sites with confirmed detections, follow-up investigations can be targeted to a specific region on the site according to the leak detection method’s emission source localization capability, or spatial resolution. For example, when using a technology for compliance that can localize emissions down to the equipment scale, instead of requiring a full-site OGI sweep for detection events, operators will be allowed to perform more targeted follow-up on a smaller radius around the detection.
Continuous Emissions Monitoring
A separate framework in the new rule applies specifically to fixed, or stationary, methane detection sensors at sites. The framework requires remedial action when site-level emissions rise above emission rate “action-thresholds.” Operators must initiate response to threshold exceedances within five days, and work to reestablish acceptable emission levels.
Advanced Technology Approval
The EPA’s new rule ensures that advanced leak detection methods used for compliance are well-vetted. The rule outlines a pathway for leak detection technologies to acquire EPA approval before they can be used for compliance.
Technologies must provide detailed technical and suitability information, including the “potential limitations of the candidate measurement system, including application limitations.” Bridger Photonics has submitted an application for technology approval. The EPA has a maximum of 270 days to make an approval determination. Technology approvals can be for specific sites, for specific regions, or broadly applicable.
Once approved, technologies will be listed on EPA’s website.
What is the Super Emitter Program?
One of the most significant changes the final EPA rule brings is the new Super Emitter Program. The Super Emitter Program creates a mechanism for third parties, like environmental organizations and scientists, to report “super-emitters” to EPA, and for EPA to subsequently require operators to investigate and repair these emissions. EPA, which defines a super-emitter as an emission with a release rate > 100 kg/hr, will approve third parties to ensure data quality and the integrity of the program.
Operators will have very short timelines to respond to suspected super-emitter notifications they receive from EPA. This highlights the importance of having response plans and methane measurement systems in place to confirm or refute suspected super-emitters. Since additional proposed regulations mean that super-emitters may be reportable under Subpart W beginning in 2025, there is potential for significant financial consequences associated with finding or dismissing suspected super-emitters.
Adapt with Bridger Photonics
We expect to be the only remote sensing technology approved in the first year that can offer OOOOb compliance at any matrix level requirement, including the quarterly screening option that eliminates regular OGI surveys.
Bridger Photonics’ highly actionable and granular Gas Mapping LiDAR (GML) data gives operators the foundation to evaluate and safeguard against super emitters. Systematic emissions management combined with the ability to conduct scans in nearly all environmental conditions means operators using GML can reduce prevalence and manage the residual risk of super-emitter events. Working with Bridger for compliance means a flexible and streamlined approach to emissions reduction.
Advanced Tech Boosts Efficiency
The ability to use advanced technologies for methane leak detection marks a major step forward in efficiency for oil and gas operators. Significant voluntary adoption of advanced methane detection technology over the past several years shows that operators value the benefits of advanced technology, and the EPA acknowledged the opportunity to make more impactful emissions reductions through their use. The flexibility to choose among leak detection methods in a performance-based framework is advantageous as the industry strives to reduce emissions and comply with new regulations.