Marrying Different Technologies for Upstream Oil and Gas Methane Inventories

Climate 21 and Methane Emissions

In November 2020, more than 150 experts with high-level government experience composed a series of memos to assist the incoming Biden Administration by delivering actionable advice for a rapid-start, whole-of-government climate response to be coordinated by the White House and accountable to the President.

While these memos are not intended as policy agenda, they do contain recommendations to help the President to ramp up quickly, and to build the capacity of the Administration to address climate issues efficiently and with the tools at hand.  The resulting memos and collaboration (entitled Climate 21) include several priorities aimed at understanding and regulating methane emissions from upstream oil and gas production. Several of the directives in the memo (and timelines) are listed below

The First 100 Days: January 20 – April 30, 2021

• Initiate high-leverage rulemakings to accelerate the pace of decarbonization in major greenhouse gas (GHG) emitting sectors. Direct the Office of Air and Radiation (OAR) to create Clean Air Act rulemaking teams for vehicles, the power sector, and the oil and gas sector. Day 1; January 20^th
• Task OAR with an immediate assessment of whether it remains necessary to update and reinstate the 2016 Information Collection Request. Direct OAR to re-propose with updates the 2016 methane New Source Performance Standard and take all other steps necessary to establish comprehensive methane regulation for the oil and gas sector.
• Direct OAR to address the gap in GHG reporting at the national level and boost work with other nations to both increase the ambition of climate commitments and improve inventories and analyses.
• Direct OAR to build a stronger presence on interagency climate diplomacy teams and elevate the influence of OAR technical experts to ensure the ambition, accountability, and workability of climate actions in the international realm
• Target the use of the EPA Science Advisory Board (SAB) to evaluate policy-relevant research questions in support of program offices for the second tier of climate priorities/actions to account for the process lead time. In particular, support OAR, Offices of Policy (OP)/National Center for Environmental Economics (NCEE), and Office of Research and Development (ORD) on best practices for economy-wide modeling. Additionally, Coordinate with OAR on research related to policy relevant forms of biomass with unequivocal carbon benefits

International EPA role in Executive Branch effort – Extraction and Mining

• Expand partnership programs including re-chartering the Global Methane Initiative with more ambition and greater funding. Address the gap in GHG reporting at the national level.

Within EPA

The EPA has issued an Information Collection Request (ICR) to fill significant gaps in information about facilities’ operations and equipment, and about potential feasible control strategies. OAR should make an immediate assessment as to whether gaps in information remain that can be addressed via the ICR and if so, reinstate the ICR promptly. Other tools to address the major source of methane emissions from the oil and gas sector include strengthening the CAA section 111(b) methane performance standards for oil and gas production, transmission, and distribution—and initiating a section 111(d) rule-making for existing sources. For existing sources, even signaling the intent to proceed in that direction would be beneficial.

Additional authorities for the oil and gas sector include regulation of hazardous air pollutants under section 112 of the Clean Air Act. Although conditions established under section 112(n)(4)(B) put limits on EPA’s authority to regulate hazardous air pollutants from oil and gas production, the beneficial public health impact of such regulation would be significant, especially given the expanding footprint of this sector and the prospect of achieving methane reductions as a co-benefit.

What does this mean for my organization, and what should I be concerned with when it comes to monitoring?

The renewed emphasis on upstream oil and gas GHG emissions will require a coordinated response to accurately count current emission levels and monitor progress of emissions reduction policy and strategy.

I recently reviewed a proposal to assist a client monitor “top down” and “bottom up” methane emissions to create an emissions inventory. The types of sources requiring survey included: pneumatic controllers, tanks, equipment leaks, liquids unloading, pumps, reciprocating compressors, centrifugal compressors, blowdowns, associated gas venting, closed vent systems, control malfunctions, separators, flares, combustors, vapor recovery units, and separator towers. A combination of existing technologies and methodologies are required to accurately create an emissions inventory.

The “top down” approach uses aircraft, drones or satellites to model regional methane emissions. Issues with over reporting can occur due to the timing of the inventories. The majority of data collection occurs at mid-day during good weather conditions. This frequently coincides with maintenance, loading operations, and episodic venting activities that are increased during favorable conditions. These issues have been noted as possible discrepancy factors in multiple top down and bottom up inventory comparisons.

The “bottom up” inventory relies on factoring individual components and summing total emissions. The bottom up method can use optical imaging, existing emission factors, extractive emissions monitoring, and activity data. These monitoring activities provide real time data, but only give a snapshot of process conditions that can change overnight. Another issue is that the emissions factors derived are from a very small subset of a vast number and diverse set of process equipment. 

The Montrose Solution – A wealth of technologies, the most experienced team

New sensor technologies are advancing every day and ambient/perimeter monitoring stations are closing some of the timing issues and non-continuous monitoring concerns of the top down and bottom up methodologies. A combination of all three approaches will provide the most robust emissions inventory to determine baseline emissions and follow up assessments.

The scope of such a monitoring program would typically involve numerous vendors with disparate systems and varying methodologies and levels of expertise.  This isn’t the case with Montrose.  We provide a single partner solution – the extensive experience and depth of knowledge to build and administer the exact program you need, and with the latest cutting-edge technologies to ensure the best monitoring and a specialized inventory team that provides the highest quality of data. We work with you to establish better baselines, and to develop actionable plans that not only identify, but reduce emissions.

For more details and real-world applications of Montrose expertise and technology in action, check out the following:

• Detection Limits of Optical Gas Imaging for Natural Gas Leak Detection in Realistic Controlled Conditions (A study by Colorado State University Energy Institute using Optical Gas Imaging at the Colorado State University Methane Emissions Technology Evaluation Center)
• Using Optical Gas Imaging to Comply with OOOOa Regulations: A Case Study
• Proton Transfer Reaction Mass Spectrometry (PTR-MS) for Ambient and (Compliance) Source Testing Discussion: A White Paper
• Optical Gas Imaging Services: An Overview
• Leak Detection and Repair: An Overview