January 17, 2024

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Article

Navigating the New EPA Final Rule and WEC: The Critical Role of SensorUp GEMS in Methane Emissions Management

The EPA recently finalized two major actions that together establish a rigorous framework aimed at driving deep reductions in methane emissions across the oil and gas industry: a new rule under the Clean Air Act regulating methane emissions from new and existing operations and a forthcoming proposed rule to establish a Waste Emissions Charge for high-emitting facilities. These build on steps taken in the Inflation Reduction Act and Administration efforts to curb methane pollution.

While stringent, these new EPA rules also incorporate innovative flexibilities intended to promote new advanced technologies that can cost-effectively detect and reduce methane emissions. As explained below, these technologies will play a pivotal role in the ability of companies to achieve compliance. 

Key Components of EPA's New Methane Regulations

The EPA rule regulates methane emissions from new and existing oil and gas facilities under Clean Air Act authority. It establishes emissions standards, requires more frequent monitoring for methane leaks, enhances leak detection and repairs, limits routine flaring, and includes a novel program tailored to large emission events that account for approximately 50% of methane pollution.  

The rule allows companies to use advanced monitoring technologies as an alternative to required ground-based surveys to detect fugitive emission leaks from equipment. These include continuous emissions monitoring systems and aerial or satellite surveys capable of covering large areas quickly if they meet performance criteria.  

The Waste Emissions Charge, established by Congress in the Inflation Reduction Act, will impose an annual per ton fee on methane emissions above facility-specific "waste emissions" thresholds. This graduated fee starts at $900/ton in 2024 and rises to $1500/ton. Exemptions and the ability to average emissions across facilities provide potential compliance flexibilities.

Critical Role of New Technologies

These regulations create ample openings that allow oil and gas companies to employ advanced technologies to improve the detection and reduction of methane emissions. EPA crafted the rules recognizing rapid innovations in monitoring and mitigation technologies that can complement and enhance conventional leak detection practices.  

Although the rules establish stringent standards, EPA built-in implementation flexibilities, alternative monitoring options, and technology approval pathways intended to spur the development and deployment of those technologies. Put simply, compliance without leveraging these technologies will become increasingly complex and resource-intensive impacting cost centers..

For monitoring fugitive emissions, EPA's core standards are based on periodic manual ground-level surveys using optical gas imaging. However, the alternative allows high-performing technologies - such as continuous emissions monitoring systems, aerial surveys, or satellites - to provide more frequent and extensive oversight.  

These can canvass facilities faster, drastically expanding covered equipment. Precision monitoring can rapidly pinpoint leak locations and support timely repair. It also generates robust emissions data - some may say a tsunami of data -, providing companies with valuable intelligence to optimize operations.

Technologies with continuous emissions monitoring offer particular advantages for avoiding waste emissions fees. With precision documentation of emission levels, sites can demonstrate they fall under thresholds triggering non-compliance fines under the fee program.  

Super-Emitter Detection

The super-emitter program represents another groundbreaking opportunity to deploy remote sensing and other technologies for compliance. The program requires companies to address large, intermittent emissions events that account for half of methane pollution, notified through third-party monitoring entities certified by EPA to use advanced detection tools.  

Upon notice, companies must investigate the potential super-emitter on their sites within strict timeframes using technologies that can provide the spatial resolution and technical capacity needed to locate and quantify emissions for such events. Advanced monitoring technologies will thus provide invaluable capabilities to comply with the super-emitter program requirements.

Gaining Approval for New Technologies  

Recognizing these technologies are rapidly evolving, EPA established streamlined alternative test method approvals for periodic and continuous monitoring technologies. EPA approval can authorize advanced monitoring approaches company-wide or for an individual site. The process incentivizes emissions detection technology developers and oil and gas firms advancing proprietary systems to seek authorization.

The technology approval avenue will let cutting-edge monitoring techniques fully substitute for ground-level surveys if performance criteria and data standards are achieved. Even absent formal approval, companies may pilot new technologies to complement required practices.  

Continued Opportunities for Innovation

While enabling technologies to support compliance, the rules are structured to drive continuous advancement. By incorporating rigorous emissions monitoring and mitigation requirements that tighten over time, the regulations will likely prompt sustained technology innovation cycles for methane emissions reduction throughout the industry.

And technology adoption and development prompted by EPA's rules won't occur in a vacuum. The Department of Energy is doling out over $1 billion in grants for emissions-reducing technologies and practices funded through the Inflation Reduction Act, providing a powerful additional spark for progress.

Furthermore, separate from EPA's actions, the Bureau of Land Management and Pipeline and Hazardous Materials Safety Administration have proposed new methane emissions requirements that can further hasten technological innovation.

Getting Ahead Now

In the dynamic world of environmental regulation, the introduction of the EPA's new methane rules and the Waste Emissions Charge (WEC) presents a dual challenge and opportunity for the oil and gas sector. At the heart of effectively navigating these regulatory waters is deploying sophisticated technology, a domain where SensorUp's Gas Emission Management Solution (GEMS) is indispensable.

Aligned with the EPA's drive for innovative methane monitoring and management solutions, GEMS integrates various data sources, including aerial, ground, and satellite surveillance. This integration facilitates a comprehensive, real-time perspective on methane emissions, crucial under the EPA's new regulations that favor advanced technological approaches over traditional manual methods. GEMS's prowess in continuous emissions monitoring positions companies to navigate the intricacies of the WEC advantageously. Its precise emissions tracking capability is instrumental in avoiding the steep penalties associated with surpassing methane emission thresholds, thus ensuring compliance and bolstering operational efficiency. The insights gleaned from GEMS's data analytics are vital for optimizing processes to minimize emissions effectively.

GEMS emerges as a vital asset in response to the stringent EPA regulations and the financial implications of the WEC. It enables compliance, mitigates financial risks, and supports sustainable operational practices. The adoption of GEMS is more than a regulatory response; it's a strategic commitment to environmental stewardship, setting companies apart as leaders in industry innovation. In an era increasingly defined by carbon constraints, employing such advanced systems is advantageous and essential for sustaining competitiveness and a robust industry standing.

Furthermore, GEMS addresses the burgeoning challenge of increased data management. The 'data tsunami' brought on by new regulatory demands could overburden existing systems. However, GEMS's advanced data processing and management capabilities ensure this information influx is collected intelligently, organized, and utilized. Its scalability means that as companies expand, GEMS can effortlessly incorporate and make sense of an ever-growing array of sensor data, maintaining its status as a genuinely multi-sensor, vendor-agnostic solution in methane management. By implementing GEMS now, companies are complying with current regulations and future-proofing their operations against an increasingly stringent regulatory landscape.

SensorUp GEMS is more than a compliance tool in the face of evolving environmental regulations. It's a strategic innovation, ensuring companies meet the current compliance requirements and are well-equipped for future environmental mandates while managing the increasing complexities of data in today's digital age.

David Fleck