LDAR Compliance Guide

Part 1: Overview of EPA LDAR Regulations – OOOOa to OOOOb/c

The EPA’s regulations around leak detection and repair (LDAR) have evolved significantly with the transition from OOOOa to OOOOb/c standards. These rules specifically target the management of fugitive emissions from oil and gas facilities, aiming to reduce methane and other harmful emissions.

Key Compliance Dates:

• OOOOa applies to facilities built, modified, or reconstructed after September 18, 2015.
• OOOOOb covers sites constructed, modified, or reconstructed after December 6, 2022.
• OOOOc applies to sites built, modified, or reconstructed on or before December 6, 2022.

Well Site Applicability: All sites, including those with single wellheads, must now comply with these standards, especially after the 2021 amendment which repealed the exemption for sites producing less than 15 barrels of oil equivalent per day (BOED).

Optical Gas Imaging (OGI) and Acoustic Leak Detection (AVO):

• OGI monitoring frequency ranges from quarterly to semi-annual, depending on the facility type.
• AVO inspections are required monthly, bi-monthly, or quarterly, again depending on the type of operation. These inspections aim to identify fugitive emissions early to prevent significant environmental and regulatory consequences.

Part 2: Detailed Breakdown of OOOOb/c Regulations

The OOOOb/c standards provide a deeper, more structured approach to monitoring emissions, depending on the facility’s specific characteristics. Here’s a closer look at the requirements for various site types:

Monitoring Frequency by Facility Type:

• Single Wellhead and Small Well Sites: These locations are required to perform AVO inspections quarterly. However, they are exempt from more frequent OGI surveys due to their smaller scale and simpler operations.
• Multi-Wellhead Sites: Sites with two or more wellheads must conduct AVO inspections quarterly and OGI surveys semi-annually. The higher risk of leaks due to multiple wellheads increases the need for regular OGI inspections.
• Large Production Sites and Centralized Facilities: These sites must conduct bi-monthly AVO inspections and quarterly OGI surveys. With major production and processing equipment on-site, more frequent monitoring ensures early detection of emissions.
• Compressor Stations: Given the critical role of compressors in the natural gas process, these stations are required to perform AVO inspections monthly and OGI surveys quarterly.
• Alaska North Slope Sites: Due to the unique environmental conditions and infrastructure, well sites and compressor stations in this region have a reduced inspection frequency. AVO is not required, and OGI surveys are annual.

Repair Timelines for Detected Leaks:

• AVO Survey Repairs: The first repair attempt must be made within 15 days of detecting a leak. This immediate response helps prevent emissions from escalating. The final repair must occur within 15 days of the initial attempt.
• OGI Survey Repairs: For leaks detected via OGI, the first repair attempt must be completed within 30 days of discovery. The final repair must occur within 30 days of the initial attempt.

Part 3: Super-Emitter Events and Associated Fines

One of the most critical aspects of the EPA’s methane regulation is the identification and handling of super-emitter events, which involve high volumes of methane emissions. A super-emitter event is defined as an emission exceeding 100 kilograms of methane per hour. These events require immediate action from the facility and involve strict reporting and repair protocols.

Super-Emitter Event Timeline:

1. Day 0-15: Certified third-party notifiers are responsible for reporting any super-emitter events to the EPA within 15 days of detection. This ensures that significant leaks are addressed promptly.
2. Day N: After the EPA receives the notification, it reviews the information and verifies the completeness of the notification process.
3. Day N+5: The EPA notifies the owner or operator of the facility where the super-emitter event occurred, prompting an investigation within five days of the notification.
4. Day N+15: Within 15 days of receiving the notification from the EPA, the operator must submit the results of the investigation back to the EPA. This includes the details of the leak, how it was addressed, and the steps taken to prevent future occurrences.

Important Compliance Details:

• Certified third-party notifiers are required to use approved remote sensing technologies such as satellites or aerial surveys to detect super-emitter events.
• Initially, the operator’s name will not be publicly disclosed. However, if the operator fails to address the event or the facility is confirmed to be within 50 meters of the emission source, the EPA will update the report to include the operator’s name and make it publicly available.

Potential Fines for Non-Compliance:

• Under the Inflation Reduction Act, methane emissions are taxed at $1,500 per ton for emissions that exceed 0.2% of the natural gas sent to sale from a facility. This tax applies to periods up to 182 days unless the facility conducts more frequent LDAR inspections.
• Additionally, the Clean Air Act imposes daily fines of $37,500 per day for each day past the last LDAR inspection. Increasing the frequency of LDAR inspections can significantly reduce exposure to these fines and help facilities stay compliant.

Part 4: New Subpart W Overview and Measurement Methods

The EPA has introduced updates to Subpart W, which covers the reporting and measurement of greenhouse gas emissions, including methane, from the oil and gas industry. These revisions are designed to close existing gaps in emission reporting and improve the overall accuracy of methane measurements.

Key Revisions in Subpart W:

1. New Emissions Sources: The updated Subpart W rules require companies to report additional emissions sources that were previously overlooked. This includes significant or “large release events” that may not have been fully captured under the previous guidelines.
2. Improved Calculation Methods: The EPA has added or revised several calculation methodologies to provide a more accurate representation of emissions. These improvements are aimed at ensuring more precise emission estimates, better reflecting the real environmental impact.
3. Enhanced Reporting Requirements: To ensure compliance, the EPA has revised the reporting process to improve the verification of submitted data. This change is critical to ensuring that the reported methane emissions align more closely with actual emissions, as it provides a more stringent system for verifying the information provided by operators.

New Measurement Methods:

The updated Subpart W also introduces new and more accurate methods for measuring methane emissions:

• Direct Emissions Measurement: Continuous monitoring systems are now encouraged, allowing companies to measure emissions in real-time. This approach offers the most accurate and immediate data on methane leaks.
• Combined Measurements and Calculations: This method integrates both direct measurements from monitoring equipment and engineering calculations to estimate emissions. For example, tools like Promax with meters can provide both measured and estimated values.
• Engineering Calculations: In cases where direct measurements are not possible, engineering calculations can be used, often based on site-specific data. These estimates are valid for periods up to 182 days or since the last LDAR inspection.
• Existing Leak Detection Methods: Operators can still use established leak detection methods, such as Optical Gas Imaging (OGI) and emission factors based on population counts. However, these factors are being increased by up to 10 times in some cases to reflect the higher potential for emissions than previously assumed.
• Population Emission Factors: This method uses population emission factors based on the number of components at a facility. The EPA is transitioning from a focus on individual components to equipment-level factors, which provide a more accurate representation of emissions for larger systems.

These measurement methods are designed to improve the accuracy of methane reporting and ensure that companies remain compliant with EPA standards.

Part 5: Appendix K and Automation for Compliance

Appendix K of the EPA’s regulations is specifically targeted at gas processing plants, outlining strict training and audit requirements for operators involved in leak detection and repair. These measures are intended to ensure that personnel are properly equipped to manage emissions effectively and maintain compliance with federal regulations.

Operator Training Requirements:

• Senior Operators: Senior OGI (Optical Gas Imaging) camera operators must complete a minimum of 1,400 hours of survey experience, with at least 40 hours of that training completed within the last 12 months. This extensive requirement ensures that senior operators have the necessary expertise to detect leaks accurately and perform thorough inspections.
• Junior Operators: Junior OGI operators must undergo at least 30 hours of training under the supervision of a senior OGI operator. This is followed by a final field test, which lasts for a minimum of 2 hours, to assess their capabilities in real-world conditions.

Audit Requirements:

• Gas processing plants must conduct 2-hour audits twice per year to ensure ongoing compliance with the EPA’s regulations. These audits help verify that operators are following proper procedures and that the facility remains compliant with LDAR requirements.

Automating LDAR Compliance:

The growing complexity of LDAR inspections and regulations makes it difficult for companies to manage compliance manually. Automation has become an essential tool for handling the increased inspection frequency and reporting demands.

At Vision Aerial, we understand the importance of automation in simplifying compliance. By integrating automated LDAR management solutions, companies can streamline their entire leak detection process—from identifying leaks to reporting and repairing them. Automation tools help reduce the risk of human error, enhance the efficiency of inspections, and ensure that all required reports are submitted on time.

Final Thoughts:

As the EPA continues to strengthen regulations around methane emissions, facilities must stay ahead of these changes by adopting advanced detection technologies and compliance strategies. Vision Aerial’s drone-based OGI solutions, combined with automated LDAR management tools, provide a comprehensive and efficient way to meet these stringent requirements while minimizing operational disruptions.