Background
The Environmental Protection Agency (EPA) has been proactive in advancing airborne flyovers in key oil and gas production areas across the United States, aiming to identify significant emission events from extraction, processing, and distribution facilities. Between 2020 and 2022, the EPA identified hydrocarbon emissions from a natural gas midstream operator in the Permian Basin. Following extensive investigations, the EPA issued a consent decree against the Operator in September 2024, imposing a civil penalty and implementing stringent regulatory requirements mandating advanced monitoring and emission control measures.
Appendix C of the consent decree specifically outlined these regulations, requiring the Operator to adopt sophisticated monitoring techniques for volatile organic compounds (VOCs), hydrocarbon leaks, flare efficiency, and methane detection across its facilities. Recognizing the importance of regulatory compliance, Cimarron, a leader in environmental solutions, partnered with the Operator to provide a comprehensive, integrated, and data-driven compliance solution through its Sytelink360® real-time performance monitoring platform.
Challenge
The consent decree imposed rigorous compliance requirements under the Clean Air Act, including:
- Conducting Optical Gas Imaging (OGI) surveys to monitor VOC and hydrocarbon emissions from various equipment, including tanks, vapor recovery units (VRUs), and separators.
- Conducting continuous monitoring of methane emissions and combustion devices via autonomous detection cameras and flare monitoring systems.
- Performing timely reporting and providing corrective action documentation for any identified emissions or operational malfunctions.
Given the complexity and scale of the Operator’s operations, the company needed a robust, automated solution capable of continuous monitoring, real-time data collection, and regulatory compliance reporting.
Solution
The Operator adopted Cimarron’s Sytelink360® Real-Time Performance Monitoring Solution, enhanced by advanced Visual Automation OGI technologies. This comprehensive platform was designed to monitor emissions, identify leaks, ensure the efficiency of flare systems, and continuously detect methane leaks throughout its facilities.
Key Components of the Solution:
- OGI Visual Monitoring for LDAR Compliance: The consent decree mandated the implementation of Optical Gas Imaging (OGI) for Leak Detection and Repair (LDAR) at the Operator’s facilities. Cimarron’s Visual Automation Sytelink360® solution provided automated, real-time OGI monitoring, capturing and logging any visible emissions to facilitate prompt corrective actions.
- 24-Hour Methane Detection: To comply with the decree’s methane detection mandates, Sytelink360® employed autonomous methane detection cameras equipped with alarming and quantification capabilities. These cameras continuously surveyed the facilities, ensuring real-time monitoring of each emission source and accurate methane quantification while providing alerts on exceedances.
- Sytelink360® Flare Monitoring: The platform also enabled continuous flare monitoring to evaluate combustion equipment efficiency, such as flares and combustors. The Sytelink360® system tracked destruction and removal efficiency (DRE) and promptly identified pilot flame issues, centralizing alerts and reports for easy access.
- Tank Pressure Monitoring and Thief Hatch Sensors: To meet the requirement for tank pressure monitoring, Sytelink360® utilized wireless electronic pressure transducers and thief hatch tilt sensors. These devices continuously recorded tank system data, providing real-time insights and triggering automatic investigations whenever pressure thresholds were exceeded, or hatches were left open.
- Automated Reporting and Corrective Action Logs: Sytelink360® streamlined the reporting process to the EPA by automatically generating survey logs, video documentation of emissions, and records of corrective actions taken. This automation ensured the Operator could efficiently comply with the requirement to submit records bi-monthly and within 30 days of completing an OGI survey.
Results
By leveraging Sytelink360®’s real-time data and automation, the Operator achieved:
- Full compliance with the EPA’s requirements for OGI-based emissions monitoring, methane detection, flare monitoring, and tank pressure recording.
- Reduced operational risk through the real-time identification and rectification of leaks and equipment failures, thereby minimizing VOC and methane emissions.
- Comprehensive documentation that alleviated the administrative burden on the Operator by automating regulatory reports, corrective action logs, and video evidence submissions to the EPA.
- Enhanced environmental performance and operational efficiency through a proactive approach to emissions monitoring and mitigation.
Conclusion
Cimarron’s Sytelink360® Real-Time Performance Monitoring Solution was instrumental in enabling the Operator to meet and exceed its regulatory obligations as stipulated in the EPA consent decree. The platform’s Visual Automation and data-driven approach not only ensured compliance but also fostered operational transparency and environmental stewardship.
Furthermore, Cimarron’s Sytelink360® integration was explicitly included in the consent decree, underscoring its significance as a vital component for ongoing compliance in the energy sector. As a proven solution for navigating complex environmental regulations, Sytelink360® enhances operational sustainability and positions companies to proactively address emission challenges.
For more information about this case study, find the public link to the EPA’s consent decree here.
About Cimarron
Cimarron’s vision is to work with our clients to create a cleaner environment. We engineer and manufacture environmental, production and process equipment for the upstream, midstream and downstream energy industries, as well as environmental control solutions for biogas at wastewater facilities, digester tanks and landfills. Additionally, our Sytelink360® technologies deliver smart hardware and software solutions for driving efficiency, ensuring safety, and reducing emissions.
Cimarron offers our customers the know-how and environmental expertise to meet the environmental standards of today and tomorrow. As a company, we thrive every day to make a difference through innovation, customer focus, sustainability, and operational efficiency. In addition to being present in all major regions in the US, Cimarron serves more than 45 countries around the world, ranging from offshore to desert. From key operational centers in the United States, Italy and the United Arab Emirates, Cimarron offers ongoing service and support through its own field service personnel and strategic third-party partners, creating a cleaner environment for our customers and their shareholders.
Please contact us to learn more about Cimarron’s Sytelink360 solutions, visit https://cimarron.com/services/sytelink360/ and contact sales@cimarron.com.