The wait was worth it. Over two years after the U.S. Environmental Protection Agency (EPA) proposed new source standards and existing source guidelines to limit pollution of methane and ozone-smog forming volatile organic compounds (VOCs) from the oil and gas sector, the agency has finalized rules that are worthy of celebration. Announced Saturday at COP28, the requirements represent the first time the U.S. will address VOC and methane pollution from both new and existing sources nationwide. This is significant in-and-of itself. Adding to that, EPA’s final rule recognizes the enormous technological advancements in the methane monitoring industry, which are already being used voluntarily. EPA wrote a rule that will require adoption of these advancements while allowing future innovative solutions to be incorporated as they become commercial.
What are those requirements, and why are they so important?
Routine Flaring of Associated Gas
Following the lead of states like New Mexico and Colorado, EPA’s final rule requires operators of new oil wells to capture the co-produced, or “associated,” natural gas these wells produce and utilize or store the gas rather than wastefully send it to a flare to be burned off, creating climate-harming pollution. As those states have recognized, operators have long had other options to deal with this associated gas, such as sending the gas to a pipeline, using it onsite, or storing it underground. This common-sense but important step forward, once fully implemented, will provide enormous benefits to communities and workers living in or working around oil and gas developments that have had to deal with pollution associated with this wasteful practice. Moreover, this exciting component of the final rule will provide benefits to communities, the climate, and operators by ensuring natural gas is not wasted.
Meanwhile, existing sources will also be required to send the gas to a pipeline or, if that is unavailable, utilize or store the gas unless a technical analysis demonstrates that doing so is infeasible.
Leak Detection and Repair (LDAR)
Leaks are the largest source of methane emissions from the industry and tend to be underestimated because of the presence of large “super-emitter” events. To reduce emissions from both small and large leaks, EPA included two critical approaches in the final rule:
- First, every production site and compressor station must carry out a required number of inspections per year, based on the type and amount of equipment at the site. For example, for operators of facilities that have equipment known to be problematic sources of leaks and malfunctions – such as flares, regulated storage vessels, and gas-driven pneumatic equipment – are required to perform four instrument-based inspections per year. Small well sites are required to inspect four times a year using audio, visual or olfactory inspections. But importantly, all sites will be required to perform at least one inspection each year.
If an operator prefers to utilize advanced technologies (rather than inspecting site “by hand” with inspectors on the ground at the site), they now have that option. EPA finalized a matrix that defines the required frequency of inspections using advanced technologies, based on the sensitivity of the technology and the type of site. Allowing the utilization of advanced technologies is critical to support the development of innovative detection capabilities over time.
- Second, EPA also finalized the Super Emitter Program in which third-parties that detect emissions above 100 kg/hour will be able to notify EPA of their findings. EPA will then analyze the notification and, if the information is verified, will contact the operator to begin a process to repair the leak. Satellite and remote sensing projects, such as Carbon Mapper and MethaneSAT, are expanding their efforts to provide publicly available, high resolution data showing point source emissions from facilities around the world. By finalizing this program, EPA opened a process to spot harmful super-emitters much earlier than under the baseline inspection, thus providing crucial additional protections to front-line communities who suffer the most harm from these emissions, and greatly reducing the climate impacts of these super-emitters.
Process Controllers and Pneumatic Pumps
Emissions from certain process controllers (known as pneumatic controllers) and pneumatic pumps are the second largest source of methane pollution from the sector. But those emissions are unnecessary, as there are numerous technologies available that can result in no emissions from the equipment by utilizing electricity or compressed air to operate the devices. EPA recognized this and finalized a zero-emitting standard, with limited exceptions for controllers and pumps.
There is more included in the rule, including reductions from compressors, storage vessels, and, for the first time, from the process known as liquids unloading.
Collectively, and once fully implemented, EPA estimates that this rule will achieve 58 million tons of methane reductions and 16 million tons of VOC reductions between 2024-2038, while also resulting in reductions of 590,000 tons of toxic air pollution. This is a larger reduction than EPA’s estimates for the proposed rules, reflecting stronger provisions in the final rule. Because we know that reducing methane is the most important and immediate thing we can do to bend the climate curve, we look forward to working with EPA and all stakeholders to ensure that the rules are fully implemented to achieve the maximum pollution reductions and protections to communities.
This rule has been a long time coming, but it was worth the wait.