On December 2, 2023, the Environmental Protection Agency (EPA) issued the final New Source Performance Standard (NSPS) OOOOb and Emissions Guidelines (OOOOc) for the Oil and Natural Gas industry.
The rule is dense, so this blog will focus on key takeaways for oil & gas operators and how Project Canary can help you best navigate this regulatory landscape going forward.
How Project Canary can help you navigate this new landscape
Minimize SEP risk using CMS for SPEED TO ACTION, proactively addressing leaks as soon as they begin. With CMS, you can monitor and detect many release events as they happen. A robust continuous monitoring solution, like Project Canary, can minimize your chances of having an event that is detected under SEP.
Use CMS and operational data to defend against third-party claims. CMS and operational data can be used during an investigative analysis, to help identify if the detected event was the result of normal operation (e.g., blowdowns).
With CMS, avoid the additional cost of OGI inspections. Since use of an approved CMS technology will satisfy the LDAR requirements of the new rules, you can avoid costly additional OGI monitoring.
Let Project Canary be your CMS partner on this journey. We will be applying for EPA approval for Project Canary’s sensors to be an approved CMS technology. We have a history of continuously improving our CMS hardware and software suite to create the most accurate facility-level methane emissions monitoring system, with performance demonstrated by third-party testing. Using our high-fidelity sensor and state-of-the-art software, you can detect leaks faster and more accurately.
Project Canary also supports multi-scale detection sources in our holistic software platform. Our SENSE software platform is technology inclusive and can help you visualize and track other methane measurement technologies that can assist in capturing and mitigating leaks faster. This includes other continuous monitoring point sensors, fixed OGI, aerial, satellite and drones.
Key takeaways from the rule
More frequent monitoring will be required at nearly all sites. All sites (even shut-in locations) require some level of monitoring. LDAR (OGI or Method 21) is now required quarterly on most upstream and midstream sites. Approved screening technologies meeting certain detection thresholds can reduce the frequency of required inspections.
Approved continuous monitoring systems (CMS) can be used in lieu of OGI/Method 21 inspections. Systems are subject to EPA application and approval. CMS must have a minimum sensitivity of 0.40 kg/hr of methane and must determine a methane mass emissions rate at least once every 12 hours. “Action levels” have been revised to account for site-specific baseline methane emission levels from normal operations.
New Super Emitter Program (SEP) enabling public third-party reporting of emission events. EPA-approved third parties using an approved methane detection technology can report emissions events exceeding 100 kg/hr methane. The report will go to the EPA, who will evaluate the reported event. If necessary, the EPA will notify the operator that emissions exceeding the SEP threshold have been discovered. Data will be posted publicly by the EPA.
Operators will need to investigate all SEP notifications. Upon notification, the operator will have 15 days to conduct an investigation to determine the cause of the event. Approved CMS can be used to provide supporting evidence for the investigation.
Contact us to learn more.