Burning Clear: Navigating the New Flare Guidelines (OOOOb Edition)
On March 8, 2024, the U.S. Environmental Protection Agency (EPA) issued new regulations that specifically target methane (CH4) and volatile organic compound (VOC) emissions from the onshore oil and natural gas (O&G) industry. These rules are referred to as NSPS OOOOb and EG OOOOc. They will take effect on May 6, 2024 (60 days after their publication in the Federal Register).
Here are the key points regarding these rules:
This discussion is regarding flares used to meet the OOOOb and OOOOc CH4 and VOCs emission limits.
Flare Definition
The rules in OOOOb define a flare as “a thermal oxidation system using an open (without enclosure) flame. Completion combustion devices as defined in this section are not considered flares.” Enclosed combustion devices (ECDs) are not considered flares under OOOOb or OOOOc.
Flares as Control Devices for OOOOb Emission Sources
Flares are used to control emissions from:
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Exemption from Performance Testing
Flares are not required to be performance tested for OOOOb and OOOOc if they comply with inlet gas net heating value (NHV) requirements and are monitored for visible emissions using EPA Method 22.
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Flare Operating Requirements
Flares operating requirements include:
For each of these operating requirements, records must be maintained for at least 5 years.
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Flare Monitoring Requirements
1.???? Continuously monitor for a pilot or combustion flame. Record a reading at least every 5 minutes. Send alerts to the nearest control room whenever the pilot or combustion flame is unlit.
2.???? Continuously monitor inlet gas flowrate. Record a reading at least every 1 hour.
3.???? Monthly monitor for visible emissions using EPA Method 22. Maintain records of testing.
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Flare Continuous Parameter Monitoring Plan
A monitoring plan is required for each emission control device. The facility must install, calibrate, operate, and maintain each continuous parameter monitoring system in accordance with the monitoring plan. The monitoring plan should include:
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Consult the section above titled “Flare Monitoring Requirements” for details on the parameters that need continuous monitoring.
The facility must conduct performance checks, system accuracy audits, or other audit procedures specified in the monitoring plan at least once every 12 months.
Heat sensing devices used to indicate the continuous pilot or combustion flame are exempt from the calibration, quality assurance and quality control requirements.
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Net Heating Value (NHV) of Flare Inlet Gas
Flare inlet gas must meet specified net heating values (NHV) shown in Table 1 below. For certain applications, periodic or continuous monitoring of NHV may be required by OOOOb.
NHV Monitoring Requirements
Facilities must monitor the NHV of inlet gas to demonstrate the gas meets the required Btu (Table 1 above). NHV monitoring/testing options include:
1.???? Collect a minimum of 28 gas samples over a 14-day period and determine the Btu of the gas. This periodic sampling and chemical analysis are required once every 5 years. Steam-assisted and air-assisted flares do not have this option.
2.???? Continuously measure Btu of inlet gas using a calorimeter, gas chromatograph, mass spectrometer, or grab sampling and chemical analysis of the vent gas.
In the case of unassisted or pressure-assisted flares that consistently exceed the NHV requirements during the initial testing, continuous NHV measurement is not required. Instead, the facility is required to collect three samples of the inlet gas once every 5 years and conduct chemical analysis to ensure that the NHV is adequate.
Monitoring of NHV monitoring is not required for inlet gas that is only associated gas from a well with high enough NHV.
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Summary and Conclusion
The EPA's new rules, NSPS OOOOb and EG OOOOc, aim to reduce methane (CH4) and volatile organic compound (VOC) emissions from the onshore oil and natural gas (O&G) industry. This blog post specifically examines the compliance requirements for flares used to meet these emission limits.
Flares are used to comply with emission limits since they can easily meet the required 95% control efficiency.
Specific operating and monitoring requirements apply to all flares, with records kept for at least 5 years. The net heating value (NHV) of the inlet gas must meet certain criteria based on the flare type. Several options exist for demonstrating compliance with NHV requirements, including periodic sampling and analysis or continuous monitoring.
The new EPA rules represent significant changes for O&G facilities, requiring them to invest in and operate flares to meet stricter emission standards. Understanding the specific requirements for flares, including operation, monitoring, and NHV compliance, is crucial for ensuring facilities remain compliant. Contact Cimarron with any questions regarding OOOOb compliance.
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Cimarron – Who We Are
With decades of operating history and innovation across our trusted brands, Cimarron provides technology-driven emissions management solutions for the global energy system. Our leading-edge products, services, and real-time monitoring systems reduce emissions, optimize operations, ensure regulatory compliance, and drive sustainability progress for our customers operating in oil & natural gas production, energy storage & distribution, renewables & biogas, coal mine methane, and certain industrial end markets.
?Cimarron boasts a collection of well-established technologies which have been assembled and innovated from trusted industry brands. Our vast global experience, spanning tens of thousands of equipment installations, serves as a testament to our ability to achieve success in every project upon which we embark.
?Cimarron is headquartered in Houston, Texas with approximately 550 employees serving our global customer base. In addition to being present in all major regions in the U.S., Cimarron operates across more than 45 countries around the world. We support our customers from sales, engineering, manufacturing, and field service locations across the United States, Italy, India, England, and the United Arab Emirates, further supported by our network of international partners.
Please contact us to learn more about our products and services and about all our solutions at?[email protected]?or visit our website?www.cimarron.com.
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Adapting to new regulations is the first step toward innovation and environmental stewardship. As Aristotle once said - excellence is a habit. Let's work together for a cleaner future. #InnovationForSustainability ???