A Brief Regulatory History in California
On June 22, 2023, the California Air Resources Board (CARB) approved amendments to the Greenhouse Gas Emission Standards for Crude Oil and Natural Gas Facilities (Oil and Gas Methane Regulation). On November 2, 2023, CARB proposed additional modifications for public review. The public comment period ends November 17, 2023.
The Oil and Gas Methane Regulation was originally adopted in 2017 to reduce emissions by requiring:
Then in 2018, this regulation was included in California’s State Implementation Plan (SIP) to address VOC control requirements from the US EPA’s 2016 Control Techniques Guidelines (CTG) for the Oil and Natural Gas Industry. In 2022, the US EPA reviewed the SIP submittal and developed a list of deficiencies. Therefore, the Oil and Gas Methane Regulation was amended to address deficiencies and avoid sanctions under the Clean Air Act.
The Oil and Gas Methane Regulation was also amended so that CARB can use remote monitoring data from approved technologies to detect methane emission plumes and then mandate correction actions.
For example, it is anticipated that CARB will start receiving satellite data in late 2023. Once notified by CARB of a remotely detected methane plume, a facility will need to conduct inspections and repairs as well as submit reports as required by the amended regulation.
Finally, additional amendments were made to clarify the regulatory language based upon CARB’s experience with implementing the regulation over the past five years. Based on this summary in California, there is more movement in other states and not just for oil & gas facilities, but many more.
What to Expect in 2024 – Nationwide
The use of satellites and Carbon Mapper are game changers. Carbon Mapper is a nonprofit entity that started flying key mission sectors and not just landfills or waste management sites. They target energy production facilities, agriculture, particularly livestock coal, mining operations, and oil and gas facilities.
The purpose is to track strong methane emissions, obviously. But the kicker is that the data is free and open to the public in the form of a methane plume overlaid on a map. The imagery usually has estimated emissions rates. Many facility owners, managers, and businesses are not aware of these monitoring events, let alone the accessibility and transparency via the Internet to the public.
Our clients reach out to us knowing that SCS has a robust drone and monitoring program – we can fly the sites and locate leak sources in hours. By using drones, our clients could respond quickly and we could identify current limitations of satellite technology for them. The resolution at a satellites high altitude does not detect and localize leak sources, but remote monitoring and control does.
Many of our clients take a proactive approach now of reoccurring drone methane inspections. We can identify areas of concern before the site is flown by manned aircraft or capture by satellites, and mitigate any potential issues ahead of making headline news. The benefit for implementing long-term operational enhancements and efficiencies prevents odors, complaints, nuisance suits, and negative headlines.
There are complementary technologies that work together, satellites, planes, drones, robot-dogs, automated wellheads, and the traditional boots on the ground. The key is combining the ones that work together to provide a more holistic view of of what’s going on at your facility. That’s where the ROI is and provides a single source to combine all data elements – so no need to move back and forth between software systems.
Additional GHG Emissions Resources
David Hostetter, Sam Rice, Joy Stephens, and Chris Woloszyn take us on a landfill technology journey in their recent EM Magazine article. It is amazing what these YPs are developing and implementing nationwide. The future looks bright!
Most equipment data and system data are collected manually for regulatory compliance; this process is time-consuming, expensive, and sometimes dangerous. Consequently, some sites only collect a few data points per day, which may not provide a complete picture of landfill operations. They also contend with the control and maintenance of remote equipment. These YPs explain how they’ve solved these challenges using RMC and SCADA systems.
Field technicians—heavily laden with instruments, printed data collection sheets, logbooks, clipboards, maps, and other gear—spend long days collecting immense amounts of data. Additional labor awaits supervisors and managers as they transcribe, digitize, or otherwise prepare the data for analysis. This team deciphers the information recorded on sheets and logbooks, often accompanied by leachate stains, mud spatters, and water damage. GIS provides a low-cost way to streamline data collection, track progress, visualize task completion, and analyze collected data to deliver an overview of the landfill’s status.
Beyond cameras, various sensors can be attached to a drone. These sensors range from infrared cameras to LiDAR sensors to gas identification tools. One such tool helps identify the presence of methane leaking out of a landfill. A drone pilot can maneuver over the entire landfill, sniffing out methane leaks and seeking out poor landfill-cover integrity, all in a matter of hours. Drones collect methane data quickly and accurately without the need for traversing the ground on foot or by vehicle.
Integration of additional automatic and manual data collection methods, such as quarterly or annual drone flights, RMC systems, and remotely monitored and controlled wellheads, provide a comprehensive view of landfill performance and overall condition. UAVs or drones allow for safe inspections, quick data gathering, and lower operating costs.
SCS is also providing a non-commercial webinar on drone technologies providing the best return on investment in March 2021. View the recording in our Learning Center after March 24, 2021.