As you probably know, critical regulatory changes are on the horizon, coupled with increased scrutiny of emissions management. You may wonder how to prepare your leak detection and methane mitigation strategies from now on. You can rest assured that you’re not alone. Several federal and state rulemakings will affect how every oil and gas company manages methane emissions from their facilities long into the future. In this blog, our own Brian Taylor, Senior Advisor – Air Quality, breaks down what you need to know.
There are active methane rulemakings underway across oil- and gas-producing states, but in this blog, we’re going to focus on the EPA. The EPA’s supplemental proposal, Standards of Performance for New, Reconstructed, and Modified Sources and Emissions Guidelines for Existing Sources [Docket ID: EPA-HP-OAR-2021-0317], better known as New Source Performance Standards, Subpart OOOOb and OOOOc. The proposed rule, as drafted, includes the following:
- Routine leak monitoring at all well sites and compressor stations;
- Continued leak monitoring at abandoned and unplugged wells, including a final leak survey once a well is permanently closed;
- Creation of a Super Emitter Response Program to detect and report (through a 3rd party) emissions exceeding 100 kg/hr;
- Increased stringency for flares, including flare performance, monitoring, and minimal ability to flare associated gas;
- Install or retrofit pneumatic pumps to have zero emissions;
- Emissions Guidelines for states to develop and implement complementary rules to existing locations;
- And more. You can dive into the documents and comments here.
Once these regulations become effective, we will have an answer for the “what” (i.e., what needs to be done to control methane leaks). What’s less clear, however, is the “how?” The EPA and certain state regulatory agencies allow organizations to use advanced technologies to supplement or even supersede currently approved leak detection techniques, such as Optical Gas Imaging (OGI) cameras and Method 21. This is an excellent opportunity to detect leaks faster and more efficiently, allocate resources to known leaks, and reduce emissions more quickly, rather than spending hours searching for nonexistent ones. However, there is no one-size-fits-all solution to methane management, especially concerning Leak Detection and Repair (LDAR) programs.
There are many potential causes of unintended methane releases on oil and gas sites, which can vary in the underlying cause, source, and emission rate. Detection of these emissions with any LDAR solution can range from immediate notification of a leak to not knowing about it for months between inspections. Put simply, different detection solutions have different purposes. Understanding these differences is critical to creating a comprehensive digital representation of a company’s assets. Continuous monitoring provides the best temporal capability for detecting, investigating, and repairing unintended releases, preventing more significant amounts of methane from escaping into the atmosphere (meaning they also can’t be sold). But new technology allows operators to mix and match hardware solutions, coupling periodic methane detection solutions (such as planes, drones, and aerial surveillance) with real-time on-the-ground monitoring for a holistic picture of total site emissions.
Alternative monitoring solutions for methane management are on the horizon thanks to federal and state regulations. However, it’s still too early to tell where federal and state regulations may steer us. At Project Canary, we believe that technology is the key to modern methane management. As corporations set their sights on ambitious climate targets, we anticipate the emergence of cutting-edge technology to take methane management to the next level. 2023 marks the start of a new era for methane management, driving us ever closer to a world powered by carbon-neutral energy.
