EPA OOOOb Requirements for Combustion Control Devices – Flare and Combustor Pilot Flames
Complying with EPA’s New Emissions Regulations: NSPS 60 OOOOb
In May 2024 the U.S. Environmental Protection Agency (EPA) adopted its Final Rule for Methane Reduction 40 CFR Part 60 Subpart OOOOb (NSPS OOOOb) to reduce methane emissions from the oil and gas industry.
Note that NSPS OOOOb is applicable for well sites and facilities that were constructed or modified on or after December 6, 2022. Emissions Guideline OOOOc (EG OOOOc) is substantially similar to NSPS OOOOb and is not a regulation, but instead a model rule for states and tribal authorities to use when creating their oil and gas emissions regulations that will apply to facilities constructed before December 6, 2022 and replace the current NSPS OOOOa regulation as those plans are approved by the EPA.
Clear as mud? You’re not alone. Because the new NSPS OOOOb regulation is over 1,600 pages long and published in small font, so no single article can cover it comprehensively.
One of the most important takeaways, however, is the gist of the rule is operators must reduce emissions of methane from oil and gas production facilities and well sites by 95%. How they do that is a combination of emissions monitoring, LDAR practices, vapor management, flaring or combusting in certain situations, and minimizing fugitive emissions, among other things.
In this article, we focus its requirements for maintaining a pilot flame in combustion control devices.
EPA OOOOb Requirements for Combustion Control Devices
In our article Keeping the Flame Alive – Minimizing Emissions from Flares with Improved Flare DRE we noted that researchers discovered that on average 4.1% of flares were unlit based on a study focused on the Permian Basin, Bakken and Eagle Ford. One of the priorities of NSPS OOOOb is to keep those flames lit to prevent fugitive emissions.
As a result, the final regulation underscores the role of combustion control devices, including flares and combustors (enclosed flares), for reducing emissions from Oil and Gas production operations. New requirements under NSPS OOOOb include:
All flares and enclosed combustion devices (combustors) must operate with a continuously burning pilot flame and with no visible emissions, except for periods not to exceed a total of one (1) minute during any 15-minute period.
Compliance with visible emissions can be verified by monthly EPA Method 22 testing or continuous video surveillance.
During each fugitive emissions inspection with an OGI camera, including those during periodic screenings with alternative technologies, owners and operators must check each enclosed combustion device and flare to ensure they are operating properly, confirming a flame is present and there are no uncontrolled emissions.
During AVO inspections, check that the flare is working correctly by confirming the pilot flame is lit and functioning.
Maintain records and report the results of all performance tests conducted on combustion control devices.
Risks of Non-Compliance with OOOOb Pilot Flame Requirements
There are several risks of non-compliance with the requirement for a continuous pilot flame, including:
Fines or Penalties. Unlit pilot flames can result in fines and potential enforcement actions by both federal and state regulators.
Super Emitter Event. An unlit pilot flame usually means that raw gas is being released into the atmosphere. If the emissions levels are in excess 100 kilogram per hour (kg/hr) of methane or greater, which is equivalent to 129 mscfd, then it could be flagged as a Super Emitter event requiring a lengthy troubleshooting process and cause damage to your corporate reputation.
Waste Emissions Charge. Emissions from unlit pilot flames may result in increased exposure to the new Waste Emissions Charge (WEC) levied on oil and gas facilities that emit more than 25,000 metric tons of CO2e annually, reported through the Greenhouse Gas Reporting Program (GHGRP). The WEC starts at $900 per metric ton of methane in 2024, increases to $1,200 in 2025, and reaches $1,500 in 2026 and after.
Loss of Revenue. Fugitive emissions, including those from unlit pilot flames, represent a loss of natural resources that could have been otherwise sold or used beneficially.
Although we expect that some of these rules and laws may change in the future, for now they are in effect as of this writing.
The Platinum Control Advantage: Technology for Continuous Pilot Flame Compliance
Use an automated burner management system (BMS), like the Platinum-600 BMS, to avoid risks from an unlit pilot flame and ensure continuous compliance with OOOOb requirements for combustion control devices.
The Platinum-600 provides safe, reliable combustion control with unmatched flexibility and savings. The Platinum-600 BMS unit can be rapidly configured to work on any type of fired equipment with the click of a switch.
One Unit for Every Piece of Equipment. Four operating modes means the Platinum-600 can be used on flares, combustors, heater treaters, line heaters, separators, and most types of fired equipment.
Flexibility. The Platinum-600 BMS can be moved from one piece of equipment to another and reconfigured with the click of a switch.
Save Money. One unit for every piece of fired equipment allows you to standardize and avoid purchasing a different model for each equipment type.
One Set of Parts. One unit means one set of parts, no need to keep multiple components in stock.
Dependable. Platinum-600 units have proven themselves reliable in one of the industry’s most competitive and demanding regions.
Improved Safety Profile. The Platinum-600 provides reliable re-ignition and reduced risk of unplanned events.
Reduced Emissions. Significantly reduces the chance of an unlit pilot flame releasing raw gas to the atmosphere, reducing the risk of fines, compliance actions, and super-emitter events.
LEARN MORE: Platinum Control BMS-600 Product Page
Contact us today to learn more about how the Power of ONE Platinum-600 BMS for multiple equipment types from Platinum Control can help you with compliance, improve operational efficiency, save money, enhance worker safety, and mitigate risk.
Contact
Chance Lauer VP Sales & Service Platinum Control Email: clauer@platinumcontrol.com Phone: 800-994-0579
About Platinum Control
Our core competency in Facilities Optimization sets us apart by helping operators harness the full potential of their well sites and facilities. We work with operators in the most active oil and gas regions, from companies having only a handful of wells to supermajors. As a result, we leverage the experience gained with larger operators, build best practices into our products and services, and then disseminate that knowledge to our smaller customers.
A well site or facility with an optimized configuration will help you harness its full potential, maximizing its long-term economic value and environmental performance.