How to Prepare Your Site for Proposed OOOO Regulations for Methane Emissions

OOOO Methane Emissions Regulations

The U.S. Environmental Protection Agency (EPA) proposed changes to their Standards of Performance for New, Reconstructed, and Modified Sources and Emissions Guidelines for Existing Sources on November 15, 2021. Regulatory specialists at APTIM have been following the progress of these environmental compliance rule updates since their initial release.

The EPA specifically posited two new rules to the 40 CFR Part 60 Subpart OOOO (Quad-O) family of emissions regulation: OOOOb and OOOOc. The purpose of this proposal is to revise the new source performance standards for greenhouse gas (GHG) and volatile organic compound (VOC) emissions from the Crude Oil and Natural Gas source category under the Clean Air Act. These revisions reflect the agency’s most recent review of the feasibility and cost of reducing emissions from these sources.

If you are an oil or natural gas facility whose operations may be affected by these proposed rule changes—which are expected to take effect by the end of 2023—it is important to begin planning for future compliance now. Below we will guide you through the first steps your facility should take to begin assessing your needs for comprehensive leak detection and repair (LDAR).

1. Identify Quad-O policy changes relevant to your site.

The grander Quad-O emissions regulation family applies to air emissions from new, modified, and reconstructed compressors; pneumatic controllers; pneumatic pumps; well completions; fugitive emissions from well sites and compressor stations; and equipment leaks at natural gas processing plants.

OOOOb, the first of the proposed changes, aims to reduce methane and VOC emissions specifically from new and modified oil and gas facilities. Definitively, these are facilities that commenced construction, modification, or reconstruction after November 15, 2021.

The other proposed change, OOOOc, applies to existing oil and gas facilities currently subject to other regulations (40 CFR part 60 subparts KKK, subpart OOOO, or OOOOa). These new standards serve as an outline for states to follow in developing, submitting, and implementing state plans to establish performance standards and limit GHG emissions.

2. Understand the critical requirements for your operation.

OOOOb requires operators to use specified methods and technologies to detect and repair leaks, as well as limit emissions from pneumatic pumps and other equipment. As it is currently written, the proposal increases the frequency of required LDAR monitoring at new or modified natural gas well sites, compressor stations, and natural gas processing plants. The rule also requires operators to submit reports on their emissions and compliance efforts.

OOOOc sets limits on emissions from storage tanks, pneumatic pumps, and other equipment, and it requires operators to use best LDAR practices and technologies to minimize leaks and venting. As with OOOOb, the proposal increases the frequency of LDAR monitoring required to maintain regulatory compliance.

To help support the objective of reducing GHG and VOC emissions, the EPA also proposes to support the use of advanced emissions monitoring and detection technologies in lieu of optical gas imaging (OGI) and EPA Method 21-based programs. The proposal would establish a matrix approach—tying required monitoring and screening frequencies to the minimum detection ranges and corrective action windows for different detection techniques and technologies, including continuous monitoring technologies.

Additional Protocols for Optical Gas Imaging Cameras

Appendix K is another component of Subpart 60 that provides specific requirements for all aspects of the optical gas imaging survey, including:

1. Camera quality and appropriate care
2. Equipment performance verification
3. Operator training
4. Establishing an operating envelope
5. Site monitoring plans, including monitoring route, survey pace, rest periods, and verification videos
6. Recordkeeping and reporting

These requirements are extensive and must be followed strictly to produce compliant inspections. More information on these specific details will be highlighted in an upcoming article.

3. Prepare and execute your plan to curb non-compliance.

As previously mentioned, the proposed changes and additions to Quad-O are expected to take effect after being published sometime in late 2023. If you would like to learn more about the updated rules and how they will affect your facilities, our LDAR compliance team is here to help. Some of our services include:

Contact:

John Leitel
Client Manager
John.Leitel@APTIM.com