Compliance with EPA’s 40 CFR 60 Subpart 0000(b) Rules for Methane and VOC Emissions from Oil & Gas Facilities, Including Compression Facilities

     As explained by Cimarron Products:

“On December 2, 2023, the U.S. Environmental Protection Agency (EPA) announced the final rulemaking regarding methane (CH4) and volatile organic compounds (VOC) emissions from oil and natural gas industries. The new final rules cover:

“40 CFR 60 Subpart OOOOb—Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification or Reconstruction Commenced After November 15, 2021 (NSPS OOOOb).”

“40 CFR 60 Subpart OOOOc—Emissions Guidelines for Greenhouse Gas Emissions from Existing Crude Oil and Natural Gas Facilities (EG OOOOc).”

“The NSPS OOOOb rules will become effective after 60 days of publication in the Federal Register.”

     An EPA summary of the final rule from March 8, 2024, is below:

“The Environmental Protection Agency (EPA) is finalizing multiple actions to reduce air pollution emissions from the Crude Oil and Natural Gas source category. First, the EPA is finalizing revisions to the new source performance standards (NSPS) regulating greenhouse gases (GHGs) and volatile organic compounds (VOCs) emissions for the Crude Oil and Natural Gas source category pursuant to the Clean Air Act (CAA). Second, the EPA is finalizing emission guidelines (EG) under the CAA for states to follow in developing, submitting, and implementing state plans to establish performance standards to limit GHG emissions from existing sources (designated facilities) in the Crude Oil and Natural Gas source category. Third, the EPA is finalizing several related actions stemming from the joint resolution of Congress, adopted on June 30, 2021, under the Congressional Review Act (CRA), disapproving the EPA's final rule titled, “Oil and Natural Gas Sector: Emission Standards for New, Reconstructed, and Modified Sources Review,” September 14, 2020 (“2020 Policy Rule”). Fourth, the EPA is finalizing a protocol under the general provisions for optical gas imaging (OGI).

     Companies must submit plans within two years and have up to three years after EPA approval of those plans. Thus, they have up to five years to fully comply. The rule is 1690 pages long and I have seen at least one summary of it. I like to simplify things so a rule that is detailed and long seems like overkill, though I realize there are many different sources of leaks, methods of detecting and measuring them, and means of fixing and preventing them. In any case, it appears that companies specializing in leak detection, repair, and site monitoring are taking the lead in getting to compliance. Many larger companies are already in full compliance, except maybe in the Permian and Bakken and other oil plays where there are more sources of leaks. Continuous air emissions monitoring is becoming common at many well pads and oil & gas facilities. The rule allows for periodic leak detection at regular intervals in specific details. While the Trump administration will no doubt apply some pushback, already targeting the removal of the methane emissions fee or tax, I agree that the fee should be removed or at least be small, especially for small operators. Below are some summaries of compliance strategies:

The following emission sources are included in OOOOb.

·        Associated gas from oil wells

·        Completions of hydraulically fractured wells

·        Centrifugal compressors

·        Wet seals

·        Dry seals – new OOOOb source

·        Reciprocating compressors

·        Fugitive emissions from equipment leaks

·        Liquids unloading – new OOOOb source

·        Pneumatic controllers using natural gas

·        Pneumatic pumps using natural gas

·        Storage vessels aggregation at tank battery

·        Super-emitters of methane – new OOOOb source

·        Sweetening units

·        Well closure requirements – new OOOOb requirement

     According to Canusa EPC, a company that does engineering, procurement, and construction (EPC), compliance with the new EPA rules for natural gas compression facilities is as follows:

What is OOOO(b) Compliance?

The EPA’s OOOO(b) Rule is a major regulatory update aimed at curbing methane emissions from oil and gas operations. The EPA’s Rule mandates “strict performance standards for new, modified, and reconstructed sources”.

For gas compression facilities, compliance requires a shift in operational practices. There are three distinct applications that apply:

1. Process Controllers & Pneumatic Pumps
   Natural gas-driven controllers and pneumatic pumps, which historically vented methane into the atmosphere, must be replaced with zero-emission alternatives (IE. instrument air-driven controllers).
    
2. Dry Seals for Compressors
   Dry-seal centrifugal compressors must maintain a volumetric flow rate at or below 10 standard cubic feet per minute (scfm) per compressor seal to minimize emissions.
    
3. Storage Vessels/Tank Batteries
   Storage tanks at compression stations must now achieve a 95% reduction in methane and VOC emissions, significantly changing how operators manage emissions control systems.

     According to Encino Environmental:

“…the table below summarizes the screening frequency with minimum detection threshold of the technology used for the screening at well site, centralized production facilities, and compressor stations subject to AVO inspections with quarterly OGI or EPA Method 21 monitoring (this table is just one of several in the final rule).”

     Cimarron Products seems to offer the full range of services for complying with the rules as shown in the tables below.

     Canusa EPC notes that applying compliance to multiple sites saves money and that converting pneumatic controllers to be powered by compressed air rather than natural gas can also save time and money. I wrote about company-wide conversions from natural gas to compressed air (and occasionally compressed nitrogen) pneumatic controllers in 2023. It is an easy, though expensive way for companies to achieve a lot of emissions reduction.

Instrument Air Conversions: Save Time & Money

“Converting from instrument gas to instrument air across multiple sites is a capital-intensive process. In a recent methane reduction project, CANUSA EPC achieved substantial cost savings and accelerated schedule for their operator using these strategies.”

 

New Focus on Tank Battery Emissions

Emissions Reduction. 

Emissions Reduction. The final rule

 includes an important addition to what was 

originally proposed by requiring storage 

vessels (i.e., tank batteries) to demonstrate

a substantial 95% reduction in methane and 

VOC (volatile organic compound) emissions.

This requirement raises several issues, such as:

• What is the baseline from which the 95% reduction will be measured?
• What technologies are approved for evidencing the reduction?
• How does this requirement dovetail with the Waste Emission Charge (WEC) mandated by the Inflation Reduction Act?

We will be delving into more detail on answering

these questions in future articles.

We do know that significant sources of tank 

battery emissions include worn thief hatches and seals. The Enviromech™ Composite Thief

 Hatch ensures a complete seal of the tank over

 the long-term and in varying weather

 conditions, reducing emissions and improving well site safety.

Additionally, the Enviromech Composite Thief

Hatch is made of extremely durable composite

material that is highly resistant to changes in

environmental conditions, reducing maintenance, repair and replacement costs.

    The Enviromech Composite Theif Hatch is shown below.

References:

 

OOOOb Explained: Navigating the Maze of the EPA’s Methane Rule with Solutions. Cimarron. January 10, 2024. OOOOb Explained: Navigating the Maze of the EPA's Methane Rule with Solutions - Cimarron

EPA's Final Rule to Reduce Methane and Other Harmful Pollution from Oil and Natural Gas Operations and Related Actions. U.S. EPA. March 8, 2024. EPA's Final Rule to Reduce Methane and Other Harmful Pollution from Oil and Natural Gas Operations and Related Actions | US EPA

IndustryVoice: Navigating OOOO(b): Methane Emission Reduction Cost-Management Strategies for Compression Sites. Canusa EPC. February 19, 2025. IndustryVoice: Navigating OOOO(b): Methane Emission Reduction Cost-Management Strategies for Compression Sites | Hart Energy

Standards of Performance for New, Reconstructed, and Modified Sources and Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review. A Rule by the Environmental Protection Agency on 03/08/2024. Federal Register. Federal Register :: Standards of Performance for New, Reconstructed, and Modified Sources and Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review

Navigating the EPA Final Rule for Methane Reduction: Solutions for Oil and Gas Operators Subjected to NSPS OOOOb and More. Encino Environmental. July 5, 2024. NSPS OOOOb | The Final Rule for Methane Reduction in Oil & Gas