The Environmental Protection Agency's (EPA) March 2024 NSPS OOOOb regulations introduced new standards for methane and volatile organic compound (VOC) emissions from the oil and gas industry. NSPS OOOOb applies to facilities, including wells, compressors, process controllers, storage vessels, sweetening units, pumps, and processing and production equipment that initiated construction, modification, hydraulic fracturing, or reconstruction after December 6, 2022.
This article focuses on the leak detection and repair (LDAR) inspection requirements for well sites and compressor stations, as outlined in NSPS OOOOb.
Inspection Frequencies and Methodologies
Well sites and compressor stations must undergo regular monitoring to detect and repair fugitive emissions.The NSPS OOOOb regulations employ a tiered approach, outlining specific inspection frequencies and methods for various facility types. This includes distinct requirements for single-wellhead and small well sites, multi-wellhead sites, well sites with extensive production and processing equipment, and compressor stations. Any equipment with the potential to release methane or VOCs, including valves, connectors, and pressure relief devices, is a fugitive emissions component. Monitoring involves using Optical Gas Imaging (OGI) and Audible, Visual, and Olfactory (AVO) inspection methods. The specific requirements vary based on facility type:
| Facility Type | Monitoring Frequency | Repair Timeline |
Single Wellhead and Small Well Sites | Quarterly AVO | AVO: Initial repair attempt within 15 days of discovery, final repair attempt within 15 days of first attempt |
| Multi-Wellhead Only Well Sites (2 or more wellheads) | Quarterly AVO Semiannual OGI | AVO: Initial repair attempt within 15 days of discovery, final repair attempt within 15 days of first attempt OGI: Initial repair attempt within 30 days of discovery, final repair within 30 days of first attempt |
| Well Sites with Major Production and Processing Equipments and Centralized Production Facilities | Bimonthly AVO Quarterly OGI | AVO: Initial repair attempt within 15 days of discovery, final repair attempt within 15 days of first attempt OGI: Initial repair attempt within 30 days of discovery, final repair within 30 days of first attempt |
| Compressor Stations | Monthly AVO Quarterly OGI | AVO: Initial repair attempt within 15 days of discovery, final repair attempt within 15 days of first attempt OGI: Initial repair attempt within 30 days of discovery, final repair within 30 days of first attempt |
Repair Procedures and Documentation
Upon discovery of a leak, immediate repair is required. If immediate repair is not feasible, the leaking component must be tagged and documented with detailed information, including a digital photograph. The photograph should capture the component, its location, and its date.
Repairs deemed impossible without significant operational disruptions or unsafe to perform during operation must be scheduled for the next available maintenance or shutdown period or completed within two years of detection, whichever is sooner.
It is important to note that devices with vents as part of their normal operation, such as natural gas-driven controllers or pumps, are not considered fugitive emissions sources. However, emissions originating from other components of these devices, like thief hatches on storage vessels, are classified as fugitive emissions.
A leak is considered repaired when OGI does not detect emissions.
Data Management and Recordkeeping
The effective management of inspection data is crucial. Facilities must maintain detailed records of inspection results, repair actions, and relevant data. This includes the parameters measured during OGI inspections and observations made during AVO inspections.
Compliance and Reporting
Annual reports detailing inspection activities, monitoring results, and repair efforts must be submitted to regulatory authorities. Compliance with these reporting obligations ensures transparency and accountability, aiding regulatory assurance. The specific reporting requirements are outlined here.
Your NSPS OOOOb Compliance Strategy
Trihydro’s air quality and regulatory specialists remain current on changing regulations to support you in maintaining compliant operations and reporting. We can help you set up a notification response program, conduct proactive monitoring, and understand the overall implications of NSPS OOOOb compliance or introduce you to our LeakTracker Pro software to help with the record keeping and compliance requirements.