Owners and operators must meet zero emissions requirements for VOC and methane
To reduce methane emissions, the United States Environmental Protection Agency (EPA) recently promulgated new rules impacting the oil and gas industry. Standards of Performance for New, Reconstructed and Modified Sources and Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review (40 CFR 60 subparts OOOO, OOOOa, OOOOb and OOOOc, often referred to as “Quad O”) notably covers process controllers (formerly referred to as pneumatic controllers) and pumps (formerly referred to as pneumatic).
Owners and operators have one year from the effective date of May 7, 2024, to replace their pneumatic process controllers and pumps with equipment that meets EPA’s new standard. Considering compliance options now is critical due to challenges associated with lack of power in remote locations, equipment sizing, operating challenges, or limited engineering availability.
Compliance Requirements Focus on Reducing Emissions
Several factors, including the number of pumps and access to electricity, will determine final applicability.
Under the final rule, process controllers for production, transmission and natural gas processing plants are required to meet a methane and VOC emission rate of zero. EPA has clarified the difference between “zero emissions” and “non-emitting” controllers with the following explanation:
Colorado … defines a “non-emitting” controller as “a device that monitors a process parameter such as liquid level, pressure or temperature and sends a signal to a control valve in order to control the process parameter and does not emit natural gas to the atmosphere. Examples of non-emitting controllers include but are not limited to no-bleed pneumatic controllers, electric controllers, mechanical controllers and routed pneumatic controllers.” A routed pneumatic controller is defined as “a pneumatic controller that releases natural gas to a process, sales line or to a combustion device instead of directly to the atmosphere.”
EPA defines the difference between non-emitting and zero emissions as process controllers that capture and route emissions to a combustion device do not have zero emissions. Therefore, routing emissions to a combustion device is not an option for compliance with this standard.
Next Steps: TRC Can Help
TRC’s team of engineers can review your process operations and conditions to help you determine the compliance status of your existing equipment. Should replacement equipment be required, our team can assist with the proper selection and sizing of compliant process controllers and pumps that meet the specific requirements of your operations. We have decades of oil and gas engineering experience and the depth of staff to help operators meet the aggressive one-year compliance deadline.
For more information, review our related services or contact us today.