Overview of NSPS OOOOb & OOOOc
The Environmental Protection Agency (EPA) recently finalized significant rules aimed at reducing methane emissions from the oil and natural gas sector. The New Source Performance Standards (NSPS) OOOOb and OOOOc, effective November 2022, target methane and greenhouse gases.
According to the regulations in OOOOb, a flare is defined as “a thermal oxidation system utilizing an open flame without an enclosure.” Completion combustion devices, as described in this section, do not fall under the category of flares. Additionally, enclosed combustion devices (ECDs) are not classified as flares under the OOOOb and OOOOc regulations.
Both rules mandate stringent measures to curb methane emissions from new, modified, and reconstructed sources in the oil and natural gas industry. These include enhanced monitoring, reporting, and record-keeping requirements.
40 CFR Part 60 Subpart OOOOb
This rule focuses on new, modified, and reconstructed sources and requires continuous monitoring of emissions from certain equipment and processes. This ensures that leaks are detected and repaired promptly, minimizing the release of methane into the atmosphere. The rule also specifies performance standards for various sources, including compressors, pneumatic controllers, and storage vessels.
40 CFR Part 60 Subpart OOOOc
This rule targets existing sources in the oil and natural gas sector, establishing guidelines for reducing methane emissions. The rule emphasizes the importance of regular inspections, maintenance, and upgrades to existing infrastructure to prevent methane leaks and enhance performance.
Key Requirements & Compliance
Enhanced Monitoring
Operators must implement advanced monitoring technologies to detect methane emissions. Every emission control device requires a detailed monitoring plan. The facility is responsible for installing, calibrating, operating, and maintaining each continuous parameter monitoring system as specified in this plan. This includes using optical gas imaging (OPI) and other approved methods to identify leaks not visible to the naked eye.
Process Controller Monitoring: Process controllers require optical gas imaging monitoring to ensure a zero methane emission rate.
Wet Seal Centrifugal Compressors: These compressors must reduce methane and VOC emissions by 95%. Leak Detection and Repair (LDAR) is mandatory, and compressor seal volumetric flow rates must not exceed 3 scfm (9 scfm for Alaska).
Dry Seal Centrifugal Compressors: These compressors require LDAR to maintain volumetric flow rates of 2 scfm or less.
Natural Gas-Driven Pumps: Pumps powered by natural gas must have zero emissions of methane and VOCs.
Natural Gas Processing Plants: These plants can either follow LDAR with OGI as per Appendix K or use Method 21.
Fugitive Emissions Monitoring: The final rule establishes the following requirements:
| Type | Frequency |
|---|---|
|
Multi Wellhead (e.g., production pads) |
Semiannual OGI monitoring (Method 21 is optional at 500 ppm leak definition) |
|
Multi Wellheads with Major Production |
Quarterly OGI monitoring (Method 21 is optional at 500 ppm leak definition) |
|
Compressor Stations |
Quarterly OGI monitoring (Method 21 is optional at 500 ppm leak definition) |
|
Fugitive emissions at Well sites and compressors in Alaska |
Annual OGI monitoring (Method 21 is optional at 500 ppm leak definition) |
Flaring Regulations
Flares are critical control devices used in the manufacturing process to combust waste gases. They play a vital role in ensuring that hazardous air pollutants are effectively destroyed before they are released into the atmosphere. The Environmental Protection Agency (EPA) has set forth detailed requirements to ensure that flares operate efficiently and reduce emissions to the lowest possible levels.
The rules set stringent guidelines on flaring, a common practice in the industry. Operators are required to minimize flaring and implement efficient combustion practices to reduce the release of methane and other volatile organic compounds (VOCs). This includes:
- Ensuring the pilot of the combustion flame is constantly monitored.
- Recording readings at intervals no longer than every 5 minutes.
- Alerting the nearest control room immediately if the pilot or combustion flame is detected as unlit.
- Monitoring the inlet gas flow rate continuously.
- Recording readings at least once every hour.
- Conducting monthly checks for visible emissions using EPA Method 22.
- Keeping detailed records of all testing conducted.
For more details on flare monitoring, read our blog post on Decoding the World of Flare Gas Monitoring.
Reporting & Record-Keeping
Detailed records of emissions and compliance activities must be maintained for at least 5 years and reported to the EPA. This transparency is crucial for tracking progress and ensuring adherence to the standards.
Transition Period
The OOOOb rule provides a 2-year transition period for operators to comply with the new requirements. This allows time for the industry to adapt to the changes and implement the necessary technologies and practices. The OOOOc rule also provides timelines for existing sources to comply with the new standards.
Industry Impacts
Implementing NSPS OOOOb and OOOOc is expected to have significant implications for the oil and natural gas industry; the long-term benefits include reduced emissions, improved performance, and potentially lower operational costs through the efficient use of resources and energy.
Furthermore, companies that proactively adopt these measures may gain a competitive advantage by demonstrating their commitment to regulatory compliance. This can enhance their reputation and foster better relationships with stakeholders, including investors, regulators, and the public.
How ESC Spectrum Can Help Refining & Flare Monitoring
ESC Spectrum are experts in building custom CEM Systems and Process Control Systems for refineries backed by 24/7 support and maintenance services. Our Data Acquisition Systems (DAS) and Analyzer Systems support regulatory compliance and monitoring needs. Learn more about how we help refineries.
Additionally, we provide reliable and robust analyzers and sampling components for process, flare, and natural gas applications.
Reagan Sokolosky - Marketing Specialist III
Reagan is a Strategic Communications graduate from Oklahoma State University who joined ESC Spectrum in April of 2020. She dove headfirst into the air emissions compliance industry with no prior experience. She has been writing and researching about air emissions for 4 years to educate our customers. Within four years, Reagan advanced to Marketing Specialist III, showcasing expertise in ESC Spectrum’s learning offerings, email marketing, video editing, product and software releases, and company rebranding.
Contact Reagan at rsokolosky@escspectrum.com for questions or comments.
