Rules and Regs: Are You Up to Date?
Rules aimed at reducing methane emissions are nothing new, but recent efforts in Europe and the United States necessitate greater dedication to technologies such as optical gas imaging.
As recently as last summer, the United States Department of the Interior announced its updated rules aimed at preventing methane leaks and gas losses by producers on Indian and federal land. These regulations modernize the rules for gas producers in these areas, bringing them on par with regulations already in place for private and corporate oil producers across the US.
At the same time, the European Union passed its first regulations aimed at reducing methane emissions from energy producers. Their goal is to meet standards set by the European Green Deal and REPowerEU to reduce greenhouse gas emissions by at least 55% by 2030—of which methane is the second largest contributor behind carbon dioxide. Fossil gas, oil, and coal industries across Europe will be required to properly measure, monitor, report, and verify their methane emissions along with taking actions to reduce them. New regulations will also apply to those outside the EU for new import contracts that happen after January 2027.
All of these new regulations introduce an even greater need for energy companies to be able to locate gas leaks quickly and perform routine inspections on a regular basis. Enter: optical gas imaging.
"Optical Gas Imaging plays a key role in empowering operators to meet regulatory requirements," explains Craig O'Neill, Director of Business Development for FLIR's optical gas imaging division. "But it's more than that. Using OGI for leak detection and repair (LDAR) improves safety and reduces costs for the oil and gas industry."
FLIR, a Teledyne Technologies company, developed the first commercially-available camera capable of showing and recording what would otherwise be invisible gas leaks.
EU Regulations explained
Under the new regulations, the fossil gas, oil, and coal industries in Europe must measure, monitor, report, and verify their methane emissions using top-tier monitoring standards. They also need to take action to reduce these emissions. The rules require EU gas, oil, and coal operators to stop avoidable and routine flaring and only allow flaring and venting in emergencies, technical malfunctions, or when necessary for safety.
Since Europe imports a significant portion of its fossil energy, the regulation will also help cut methane emissions from imported fossil fuels. Over time, stricter requirements will be introduced to ensure that exporters gradually meet the same monitoring, reporting, and verification standards as EU operators.
FLIR released the first OGI—or, optical gas imaging—camera for commercial use in 2005. Its efficacy in locating invisible methane emissions lead the US Environmental Protection Agency to establish regulations involving the use of OGI cameras for leak detection and repair.
Expanded Rules in the US
The regulations the Department of the Interior announced in May aim to hold oil and gas companies accountable by requiring them to avoid wasteful practices and fix leaks, and to make use of current technology and practices that will better account for the waste of natural gas.
Operators of federal and Indian oil and gas leases will need to take reasonable steps to avoid natural gas waste throughout the extraction process, including following current standards for methane LDAR. They must also reduce methane emissions from venting and flaring.
Among the modern standards these gas producers will be expected to follow are the EPA's final methane LDAR rules which codify previous drafts and supplemental regulations introduced in 2021 and 2022, respectively.
The rulings represent the culmination of a major shift in how the U.S. Federal Government plans to regulate methane and other greenhouse gas emissions that contribute to global warming. The EPA estimates the new rule will reduce methane emissions nearly 80% below what they were projected to be, and that will "prevent an estimated 58 million tons of methane emissions from 2024 to 2038."
Of particular interest are the subparts commonly referred to as New Source Performance Standards (NSPS) OOOOb and Emissions Guidelines (EG) OOOOc. These updates are additions to the 2015 regulations known as OOOOa, which first established optical gas imaging (OGI) as the best system of emission reduction (BSER).
With the introduction of Appendix K, the industry now has simplified guidance on how to use an OGI camera in the field. This represents a significant change for the EPA as historically the agency has focused on the technology used for monitoring, not the operator. In short, the rule keys in on the training, auditing, daily procedures, and use cases of the operator, in addition to the capabilities of the technology. For this reason, some organizations may feel the rule is overly stringent and burdensome to the OGI user and limits the efficiency of OGI versus the before-mentioned Method 21 standard.
Certified Compliant
FLIR is proud to announce its cameras engineered for hydrocarbon, VOC and methane gas detection, including the Gx320, Gx620, G620, GFx320, GF320, GF620, GF300, and G300a, have been independently tested and deemed compliant with the European parliament and the council on methane emissions reduction in the energy sector and amending Regulation (EU) 2019/942, Article 14 sensitivity standard for optical gas imaging equipment. The National Physical Laboratory (NPL) performed the testing and confirmed the FLIR G and GF series optical gas imaging cameras for hydrocarbon, VOC, and methane detection are capable of imaging a gas that is half methane/half propane at a concentration of 10,000 ppm at a flow rate of ≤60 g/hr from a quarter inch diameter orifice for both standards. They can also quantify a Type 1 leak defined as a minimum detection limit and a minimum leak threshold of 17 g/hr.
In addition, these FLIR cameras have been independently tested and deemed compliant with both the EPA’s NSPS 40 CFR part 60, subpart OOOOa and subpart OOOOb sensitivity standards for optical gas imaging equipment, as well as confirmed compliant with the EPA’s Appendix K to 40 CFR Part 60 sensitivity standards for optical gas imaging equipment.
The independent third party confirmed that FLIR G and GF series cameras meet the stringent gas detection criteria out in Appendix K:
- Detecting methane emissions at a rate of 19 g/hr.
- Detecting either n-butane emissions at 29 g/hr or propane emissions at 22 g/hr.
- Performing at a viewing distance of two meters with a delta-T of 5°C in calm wind conditions (≤1 meter/second).
