How to Plan for OOOOb and OOOOc LDAR Compliance in 2024
January 24, 2024
By: Jared Metcalf
When it comes to OOOOb and OOOOc in 2024, compliance can be a complicated matter to unpack. In its final ruling, the EPA establishes performance standards with the expressed goal of reducing emissions from Oil and Natural Gas facilities. To help operators comply with these standards as efficiently as possible, the EPA is also establishing a “fast track” process to allow for the rapid approval and adoption of new and advanced leak detection technologies.
If a well site, compressor station, or even processing facility operator can demonstrate that an advanced technology meets the EPA’s performance requirements for leak detection, then receiving approval for that technology will be far easier than in the past. While this added agility is a net positive, it simultaneously makes the issue of compliance a tricky one. That’s because the sensitivity of the measuring technology you’re using will dictate what your response to a leak must be. The EPA refers to this sensitivity as spatial resolution.
Leak detection response by advanced technology
One condition when using advanced technology for leak detection is the requirement to conduct monthly surveys. Should you identify a leak during one of these surveys, you’ll need to take a specific follow-up action based on which spatial resolution classification your technology falls under, of which there are three:
Component-level spatial resolution: The ability to identify emissions within a radius of 0.5 meters of the source.
Area-level spatial resolution: The ability to identify emissions within a radius of 2 meters of the source
Facility-level spatial resolution: The ability to identify emissions within the boundary of a facility
If you detect a leak using technology with component-level spatial resolution, a technician will need to inspect all components within a 1-meter radius. If you detect a leak using technology with area-level spatial resolution, the follow-up survey expands to include all fugitive emission components within a 4-meter radius. And if a technology with facility-level spatial resolution, such as satellite, identifies a leak within your facility’s boundaries, then you must conduct a full inspection of the entire facility.
The alternative to using advanced technology is to conduct quarterly inspections with OGI.
Continuous Methane Monitoring (CMMS)
EPA’s final ruling also allows facility operators to use CMMS technology, which consists of on-site, stationary OGI cameras and/or sensors for monitoring and identifying leaks. When emission levels rise to 0.40kg/hr (0.88 lb/hr) above your baseline, CMMS automatically alerts the proper personnel. Like other advanced technologies, CMMS can be fast-tracked for implementation.
Unfortunately, there’s one caveat regarding CMMS: Before you can implement the technology, you must prove that your facility is completely free of leaks before establishing a baseline over 30 days. This could prove a time-consuming hurdle for some.
So advanced technology or quarterly OGI surveys?
Well, it depends. There are other regulations in the pipeline, with overlapping implications for virtually every type of Oil and Natural Gas facility. For example, natural gas processing sites have the added guardrails of Appendix K, which dictates how OGI inspections are performed.
Location will play a critical role as well. OOOOc stipulates that every state in the U.S. must enforce certain provisions found in OOOOb. Most states are likely to adopt the requirements of OOOOb in full.
Then there’s Subpart W. This ruling will establish a tax for each leak identified, with the monetary penalty determined by how long the leak persisted. Even if a leak was active for only two days before being identified in your monthly survey and then repaired, the regulating agency will assume that the leak had been ongoing since your last monthly survey when calculating your tax bill.
And what about the cost of these technologies? There are implementation and maintenance costs associated with any LDAR technology. Are the upfront investments and ongoing expenses of a given technology justifiable if you can identify leaks faster and thus reduce your tax penalties? How much money will you spend on a monthly survey versus a quarterly one? What are the financial implications of one follow-up action compared to another when a leak is identified? With so many variables in play, we recommend a cost-benefit analysis as a great first step toward narrowing down your feasible options.
Let’s get a handle on OOOOb and OOOOc regulations
The more we learn about your facility, the better we’ll understand your unique situation and how we can best prepare you for what’s ahead. Get in touch.
VP of US OGI Operations
Jared Metcalf has over 20 years of Oil & Gas Industry experience. His extensive experience in providing professional fugitive emission monitoring services across North America and internationally has given him the expertise to help our clients meet their compliance/voluntary requirements. Jared specializes in the design, setup, and implementation of LDAR programs using Optical Gas Imaging.