In November 2022, the U.S. Environmental Protection Agency (EPA) published proposed rulemaking regarding methane and VOC emissions from oil and natural gas industries. This proposal supplemented the proposed rulemaking published on November 21, 2021. The proposal includes:
- 40 CFR 60 Subpart OOOOb—Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification or Reconstruction Commenced After November 15, 2021 (NSPS OOOOb)
- 40 CFR 60 Subpart OOOOc—Emissions Guidelines for Greenhouse Gas Emissions from Existing Crude Oil and Natural Gas Facilities (NSPS OOOOc)
This discussion addresses the proposed rules in NSPS OOOOb.
Link to proposed NSPS and Emission Guidelines for O&G.
The main purpose of the rules is to reduce the volatile organic compounds (VOCs) and greenhouse gases (GHG) methane from new onshore oil and gas facilities. Below are the OOOO rules and applicability dates.
Comments Requested by EPA
Public comments on all parts of the proposed rule can be submitted to the EPA. The comment period. Link for instructions on how to comment: Link for Comments Instructions
EPA prefers that you submit comments online through the Federal eRulemaking Portal. Visit https://www.regulations.gov/ and type EPA-HQ-OAR-2021-0317 in the search box. That will take you to a link to the docket for the proposed rule. Under the link, there will be a button that says “Comment.” Click on that button to submit your comments, or you can open the link, and use the blue button in the upper left to enter your comments.
Approval Timeline
NSPS OOOOb expected be finalized in mid to late 2023.
Definitions
The proposed rule includes new definitions of important concepts and terms. Some of these include:
- Centralized production facility means one or more storage vessels and all equipment at a single surface site used to gather, for the purpose of sale or processing to sell, crude oil, condensate, produced water, or intermediate hydrocarbon liquid from one or more offsite natural gas or oil production wells. This equipment includes, but is not limited to, equipment used for storage, separation, treating, dehydration, artificial lift, combustion, compression, pumping, metering, monitoring, and flowline.
- Major production and processing equipment means reciprocating or centrifugal compressors, glycol dehydrators, heater/treaters, separators, and storage vessels collecting crude oil, condensate, intermediate hydrocarbon liquids, or produced water, for the purpose of determining whether a well site is a wellhead only well site.
- Small well sites are single wellhead well sites with no controlled storage tanks, control devices, pneumatic controller affected facilities or pneumatic pump affected facilities) and only one other piece of major production and processing equipment.
Flares
Some of the requirements for flares in the proposed rule includes:
- Comply with 40 CFR 60.18(b).
- Monitoring to ensure that a pilot flame burns at all times.
- Meet specified net heating values (BTU/scf) of gas combusted – depending on the type of flare.
- Operate flare with no visible emissions
- Use a continuous burning pilot flame
Enclosed Combustion Devices
Some of the requirements for enclosed combustion devices (ECD) in the proposed rule includes:
- Operate flare with no visible emissions
- Use a continuous burning pilot flame
- Operate at a minimum temperature of 760°C, if the control device demonstrated, during the performance test that combustion zone temperature indicates destruction efficiency.
- If the combustion zone temperature is not an indicator of destruction efficiency, operators must maintain the net heating value (NHV) of the gas sent to the combustor above rule specified Net Heating Values (NHV).
- Maintain NHV of the gas sent to the combustor at or above the following:
- 200 BTU/scf for ECD that do not use assist gas or pressure-assisted burner tips
- 300 BTU/scf for ECD that use assist gas
- 800 BTU/scf for ECD that use pressure-assisted burner tips.
- Use continuous measurement of the BTU/scf of the gas sent to ECDs unless the facility demonstrates the BTU of the gas does not vary significantly.
- Maintain NHV of the gas sent to the combustor at or above the following:
Super-Emitter Events – New Proposed Emission Source
A new category of regulated emissions is the super-emitter event. A super-emitter event is defined as a
quantified emission rate of 100 kg/hr of methane or greater at an individual well site, centralized production facility, or compressor station with emissions detected, using remote detection methods.
Emissions of 100 kg/hr of methane equals about 5,213 scf/hr of methane.
For this effort, EPA is enlisting the help of third-party, qualified notifiers that have technical expertise in remote methane detection. The notifiers can use satellite detection, remote-sensing equipment on aircraft and mobile monitoring platforms. The notifications must include location of event, technology and sampling protocol used, event description and the quantified emission rate in kg/hr with uncertainty boundaries and associated meta data.
Within 5 days of being notified of super-emitter events the operator must conduct a root cause analysis to determine the cause and take corrective actions as listed in the rule. Corrective action plans are required to be submitted to the USEPA if corrective actions require more than 10 days to complete. A corrective action report to USEPA will be required for all super-emitter notifications. Super-emitter events must be reported in the OOOOb annual report.
Super-emitter reports will be publicly available on an USEPA website.
Well Closure Requirements – New Proposed Emission Source
Abandoned and unplugged wells have been identified as significant methane sources. To limit this as an emission source, the proposal requires a well closure plan be submitted to the EPA. The plan will include steps needed to plug all wells, document financial assurance to complete the well closure and a schedule for closure activities.
Once a well is closed, the operator must conduct a leak survey using Optical Gas Imaging (OGI) to demonstrate no emissions. If emissions are found, then corrective actions must be taken to stop the emissions.
Well Completions
Proposed standards for well completions are similar to the existing NSPS OOOO and OOOOa.
Well Liquids Unloading – New Proposed Emission Source
The proposal adds well liquids unloading vent gas to the list of sources.
The proposed rule requires performing liquids unloading with zero methane or VOC emissions. Best management practices may be used if this is not feasible to achieve zero emissions for safety or technical reasons. A report to the USEPA is required to justify safety/technical reason that zero emissions is not feasible.
Associated Gas from Oil Wells – New Proposed Emission Source
Natural gas produced from some oil wells is not able to be sent to a natural gas pipeline and is often flared. This associated gas in the past has been regulated by a State’s oil and gas mineral agency (e.g., Texas Railroad Commission, Oklahoma Corporation Commission).
The proposed rule requires sending associated gas to a sales pipeline, fuel gas system or use for enhanced oil recovery (EOR).
If these options are demonstrated to be infeasible, the gas must be sent to a control device (e.g., ECD, flare). A professional engineer or other qualified individual must certify the technical or safety reasons for the infeasibility.
Wet Seal Centrifugal Compressors
Centrifugal compressors not located at a single well site are exempt from these rules.
Wet seal centrifugal compressors must capture and route emissions from the wet seal fluid degassing system to a control device or to a process.
Self-contained wet seal centrifugal compressors would have to comply with the standard for dry seal
compressors. Self-contained wet seal compressors, in general, send their gas back to the system process. These wet seal compressors must not exceed 3 standard cubic feet per minute (scfm). Wet seal flow rate must be measured on or before 8760 hours of operation.
Dry Seal Centrifugal Compressors – New Proposed Emission Source
Centrifugal compressors not located at a single well site are exempt from these rules.
Dry seal centrifugal compressors are a new emission source regulated by OOOOb. Dry seal centrifugal compressor gas vent flow rate must not exceed 3 scfm. Dry seal compressor flow rate must be measured on or before 8760 hours of operation.
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Reciprocating Compressors
Reciprocating compressors located at a well site are exempt from these rules.
Annual flowrate monitoring of rod packing seal leaks is required. Seal flow rate measurements must be conducted on or before 8760 hours of operation. A temporary meter or high-volume sampler may be used to quantify leak rates.
The measured leak rate must be maintained less than or equal to 2 scfm. As an alternative, the rod packing seal can be sent to a closed vent system to a process (e.g., fuel gas system). Closed vent systems for reciprocating compressors does not include an emission control device (e.g, flare).
Optical Gas Imaging (OGI) EPA Test Method
The proposal included an EPA test method conducting LDAR monitoring in 40 CFR 60, Appendix K, “Determination of Volatile Organic Compound and Greenhouse Gas Leaks Using Optical Gas Imaging.”
Legally and Practicably Enforceable Limits
Operators will still be able to limit their potential to emit (PTE) from storage tanks so that OOOOb emission standards, monitoring, recordkeeping and reporting requirements do not apply. Typically, limiting PTE is done using an enforceable State air permit.
The proposal includes criteria that must be met for “legally and practicably enforceable limit” as it relates to PTE limits for VOC emissions from storage vessels. This includes:
- Production limits
- Averaging time period for the production limit (equal to or less than 30 days)
- Performance tests for control devices
- Ongoing monitoring, recordkeeping and reporting
Storage Tanks
The proposed rule has the following emission limitation on storage tanks:
- 6 ton per year (tpy) of VOCs
- 20 tpy methane (approximately 945,885 standard cubic feet of methane per year)
The proposed limit is on tank batteries (groups of tanks that are adjacent and receive fluids from the same source) and not on an individual tank basis. The existing rules in NSPS OOOO and OOOOa have a 6 tpy of VOC per individual storage tank threshold that requires emission controls (ECD, flare). The 6 tpy VOC limit would be applicable to the group of tanks at a tank battery.
Tank hatches or openings would have to be monitored for leaks as a part of LDAR program.
Based on the definition of a “centralized production facility,” process vessels and process tanks are not considered storage vessels or storage tanks.
Natural Gas Pneumatic Controllers
The rule states that the collection of natural gas-driven pneumatic controllers at a facility is the regulated “affected facility.” NSPS OOOO and OOOOa listed each natural gas-driven pneumatic controller as a affected facility.
Proposal requires all new pneumatic controllers to have zero methane and VOC emissions, except for sites in Alaska that do not have power.
Self-contained natural gas-driven pneumatic controllers can be used to meet the zero emissions requirement. These natural gas-driven controllers send gas to the downstream piping and not to the atmosphere.
Natural gas-driven pneumatic controllers that function as emergency shutdown devices and pneumatic controllers that are not driven by natural gas are exempt.
Pneumatic Pumps
New pneumatic pumps are prohibited from using natural gas. The exceptions to this include:
- A site that does not have electrical power
- A site that cannot use solar powered pump
- Not feasible to use a generator to power a compressed air system
Written certification by a qualified professional engineer or in-house engineer is required to justify the need for natural gas-powered pneumatic pump.
If a company can justify the use of a gas-powered pneumatic pump, then must reduce methane and VOC emissions by 95%.
Pneumatic pumps that use compressed air are not regulated by this rule. A lean glycol circulation pump (e.g., Kimray) that uses energy exchange with rich glycol from the contactor is exempt from the proposed rules.
Recordkeeping and Reporting
The proposed rules have numerous requirements for recordkeeping and reporting. Consult the proposed rule for details. Reports submitted to comply with the rule will use EPA’s CEDRI website.
Annual reports (due 90 days after compliance period) regarding compliance with the rule are required. EPA should supply an Excel formatted report like the one for NSPS OOOOa.
Alternative Technology Periodic Screening
The proposal request comments on the use of advanced technologies as an alternative to OGI or EPA Method 21. EPA proposes a matrix approach that links frequency of required monitoring surveys to the detection capability of the technology used and sets deadlines for repairs that are tied to the type of monitoring used.
Summary and Conclusions
Federal New Source Performance Standards (NSPS) in 40 CFR 60 Subpart OOOOb are proposed for new oil and gas facilities constructed, modified, or reconstructed after November 15, 2021. The focus of the rules is to reduce emissions of volatile organic compounds (VOCs) and methane. The rules affect air emissions generated by equipment operating at crude oil and natural gas well sites, tank batteries, compressor stations and gas processing facilities.
These proposed rules are similar to NSPS OOOOa and add new requirements for the equipment and facilities included.
Interested parties may submit comments on the rule. The comment period ends on February 13, 2023. Comments should be sent via the web portal at
NSPS OOOOb expected be finalized in mid to late 2023.
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