American Oil and Gas Reporter - December 2022 - 31

a primary leak detection method on smaller
facilities. " Expensive forward-looking infrared
(FLIR) cameras are not necessary
to figure out what is going on at a small
facility, " he reasons. " A U.S. Department
of Energy study shows that most emissions
originate not from process equipment, but
from tanks because of factors such as
open thief hatches or separators with failing
pneumatic controllers. Those can be identified
in routine equipment reviews. "
Industry representatives such as the
Kansas Independent Oil & Gas Association
have faulted EPA's proposal for giving
short shrift to the DOE study, a concern
Fuller shares. " EPA does not seem to
have used the DOE study information as
well as it could have, " he assesses. " We
are analyzing that and will try to address
it in comments. "
Fuller notes EPA's matrix for optical
gas imaging (OGI) requirements according
to facility size accounts for sites with an
individual well, a two-well site, a small
site well with equipment, and finally,
larger wells. " The OGI dynamic is different
for each of those, and the larger it is, the
more frequent it becomes, " he outlines.
" DOE's study shows that wells producing
fewer than six barrels a day are not responsible
for significant emissions, but
EPA is not relying on production rates. It
is sticking with equipment counts. "
The proposal does take an aggressive
approach to creating pathways for deploying
new technologies, Fuller credits.
" EPA is trying to avoid issues so that,
once a technology is certified, it can be
utilized by anyone, anywhere, " he explains.
" The prior approach relied on an extraordinarily
time-consuming and difficult siteby-site
process. This streamlined mechanism
will bring in new technologies. "
The OGI change also could complicate
the proposal's low-production well fugitive
emissions process, Fuller continues. " The
agency's references to OGI and the matrix
for the fugitive program are confusing at
best, " he describes. " For a wellhead-only
site with two or more wells, the operator
has to perform AVO on a quarterly basis,
as well as a semiannual OGI requirement.
Is EPA basically saying 'FLIR camera'
when it says 'OGI?' Then, the second
process can create an alternative, but that
carries with it the frequency from that
process instead of the fugitive matrix process.
" That seems convoluted, which is a
concern, " he continues. " How do these
things fit together for smaller wells?
The OGI alternative is worth a look for
larger wells because new technologies
are considered more cost-effective, but
not at a frequency that it offsets the
benefits. For smaller wells, the categorization
breaks out according to pieces
of equipment on site and number of
wells, but it is unclear whether that reflects
the reality on the ground. "
Controllers And Tanks
Although zero-emission pneumatic
controllers figure prominently in EPA's
package, Fuller says, the proposal leaves
the 2021 version of that section largely
unchanged. He says the text tends not to
distinguish between larger, new operations
and small, existing ones.
technology to quickly identify large-scale
emissions for prompt control. " Studies
show that large leaks from a small number
of sources are responsible for as much as
half of the methane emissions from the
oil and natural gas industry, along with
significant amounts of smog-forming
VOCs, " EPA states.
According to Fuller, the super emitter
threshold is 100 kg an hour, or about 130
Mcf a day. Since the average U.S. lowoutput
gas well produces about 22 Mcf/d,
" Expensive forward-looking infrared cameras are not necessary
to figure out what is going on at a small facility. A U.S.
Department of Energy study shows that most emissions originate
not from process equipment, but from tanks because of factors
such as open thief hatches or separators with failing pneumatic
controllers. Those can be identified in routine equipment reviews. "
Lee Fuller
Independent Petroleum Association of America
" It may be a challenge to apply new
source requirements for existing pneumatic
controllers, pumps and tanks if we consider
the collective amount of equipment that
small operations may need to replace, "
he considers.
Fuller points out that storage tanks have
their own rules. EPA proposes to change
the definition of pneumatic-controller-affected-facility
to include all-not each
of-the site's controllers, he notes, which
means the proposal addresses one set of
activities associated with controllers and
another set associated with tanks, as well
as the generic fugitive emissions program.
" How does that fit in with the requirements
of the general fugitive program? "
he poses. " What are you looking for and
what does that mean in terms of, for
smaller wells, making sure your thief
hatches are closed and the pneumatic
controllers on your separator are operating
properly? How much are you really gaining
out of OGI if you have a routine
AVO program? "
Then comes the proposal's provisions
for continuous monitoring of wells until
they are plugged. " That area is also new
to this process and somewhat beyond
where the CAA has gone in the past, "
Fuller remarks. " It also may compete with
states' bonding requirements for the same
operation. How does that fit together? "
Super Emitters
EPA notes that its supplemental proposal
also seeks to establish a superemitter
response program that will leverage
data from approved third parties with expertise
in certain remote methane detection
it is arguably impossible for those wells
to leak 130 Mcf/d. " The super-emitter
program is going to be a larger well
issue, " he maintains.
The proposal's authorized third-party
detectors will require government certification,
Fuller says, likening them to
people who assist meteorologists during
severe weather alerts. " Think of tornado
chasers: people who are certified to use
certain technologies, " he compares. " In
this case, they are limited to technologies
such as aircraft, satellites and drive-by
monitoring. If they detect a leak remotely
and notify the operator and regulators
that they have found super emitters, the
rule triggers response activities with specific
time frames. "
Although Fuller says EPA's proposal
appears to be crafted to prevent thirdparty
detectors from trespassing to obtain
their readings, he suggests that such risks
may remain. " There are also concerns
about harassing operators with false
claims, " he observes. " The rule includes
language to revoke the certification of
people who provide false information. "
Nevertheless, Fuller warns, the sort
of sampling collected in such short-term,
" drive-by " remote monitoring can be less
than representative. " Past studies show
some of those mobile tests may only
have 10 minutes worth of data, " he details.
" There is a need to consider the time
window so an anomalous spike does not
skew the data. "
Associated Gas
According to Fuller, the proposal's
section on associated gas management
DECEMBER 2022 31
American Oil and Gas Reporter - December 2022

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