Quad-O: EPA’s Methane Emissions Standards for the Oil and Gas Industry

In 2012, the EPA published 40 CFR Part 60 Subpart OOOO, more commonly known as Quad-O, which set forth substantial new methane emissions monitoring and reduction requirements, as well as provisions mandating that owners and operators in the oil and gas industry implement comprehensive leak detection and repair (LDAR) programs throughout their facilities.

In June of 2016, EPA published amendments to Quad-O which expanded the number of affected facilities and equipment types subject to the regulation, as well as new methane emissions standards, LDAR requirements, and additional reporting obligations. Affected facilities include all hydraulically fractured gas wells for which construction began on or after January 1, 2015, as well as all new or modified compressor stations, pneumatic controllers and storage vessels in service throughout the natural gas production, processing and transmission segments.

Quad-O also creates new operating and maintenance requirements for emission control devices installed throughout the network of affected facilities; including storage tank covers, wet seal degassing systems, closed-vent systems, bypass devices, enclosed combustion devices, vapor recovery units, and flaring systems. The rule’s control device requirements are intended to prevent waste of saleable gas, while simultaneously reducing emissions from those types of equipment. Affected facility owners and operators must install continuous parameter monitoring systems (CPMS) to demonstrate that control devices are achieving the 95 percent emissions reduction targets established under the regulation, and thoroughly document control device operating parameters and performance.

Under the provisions of Quad-O, EPA also requires owners and operators of affected facilities, including processing and transmission systems, to prepare and implement comprehensive LDAR programs for inspecting and repairing methane leaks. EPA prescribes very specific methods and criteria for detecting and measuring equipment leaks, including threshold concentrations, approved types of monitoring devices, and physical testing procedures. Operators must perform monthly inspections of all affected facilities and control devices in accordance with these test methods, and provide clear documentation that leaks have been inspected and repaired within the time limit specified for that equipment type.

Initial and continuous compliance of affected facilities is demonstrated through the recordkeeping and reporting requirements of the rule, with each facility type requiring its own unique set of information that must be electronically submitted to the EPA on an annual basis. The required information includes items such as affected facility location and dates of operation, detailed inspection records, corrective action and maintenance logs, continuous emissions monitoring data, and verification of control device performance test results. As U.S. oil and natural gas production continues to boom, newly constructed and modified facilities throughout the upstream and midstream oil and gas segments must be well-versed in these requirements in order to ensure compliance with the standards under Quad-O.

Potential Expansion of Methane Emissions Standards

On February 14th, the EPA released its 2017 Greenhouse Gas Emissions and Sinks Inventory, a more than 600-page study compiling U.S. GHG emissions data from across a wide variety of industrial sectors and process types. The data reveals that in 2015, the U.S. oil and gas industry emitted approximately 201.5 million metric tons CO₂ equivalent (MMT CO₂-e) of methane to the atmosphere, and that annual emissions generated by the oil and gas industry have been consistently at or above this level each year since 1990. In 2013 alone, the U.S. oil and gas industry reported approximately 379 billion cubic feet (Bcf) of atmospheric methane emissions. At today’s NYMEX natural gas spot price of $2.94 per thousand cubic feet (Mcf), this volume of natural gas would be worth approximately $1.2 billion.

In an effort to further address the significant level of emissions, EPA has recently issued its final Information Collection Request (ICR) seeking information to help the agency determine how to best reduce methane and other harmful emissions from existing sources in the oil and natural gas industry. Owners and operators subject to the ICR are legally required to submit information related to the installation, operation and maintenance of equipment and control devices at their facilities. ICR recipients will also be required to submit emissions data for natural gas venting that occurs as part of existing processes or maintenance activities, such as well and pipeline blowdowns, equipment malfunctions and flashing emissions from storage tanks. Considering the recent requirements contained in Quad-O, as well as the United States’ ongoing international commitments to reduce methane and other greenhouse gas emissions, EPA’s effort to collect this information through the ICR sends a strong signal that the agency is seeking to implement similar emissions monitoring, LDAR, and reporting requirements on existing production, processing and transmission systems.

Let VelocityEHS Help!

Quad-O compliance is a big challenge for companies in the oil and gas industry. VelocityEHS offers a comprehensive suite of EHS management software solutions designed to dramatically reduce the time, effort, and cost required to meet Quad-O and other air emissions standards. The VelocityEHS Air Emissions solution uses OSIsoft_© PI to interface directly with your CPMS remote sensor arrays, automatically collecting and recording emissions monitoring data. Integrated PDF data collection forms give field technicians the ability to record leak inspection results and other emissions unit data using their tablet or smartphone, and instantly upload it to your central database via the cloud. The system’s proprietary calculation engine and built-in library of industry-standard emissions factors and formulas lets you perform complex emissions calculations in real-time. You can then automatically generate emissions reports to make compliance with Quad-O, Title V permits, NSPS, NESHAPs, emissions trading programs, GHGRP Subpart W requirements, and a whole host of air emissions standards easier than ever before.

In addition, the VelocityEHS Audit & Inspection solution gives you an all-in-one system to help schedule, manage and document your LDAR programs, streamline compliance with leak detection and repair requirements, and enhance the safety of both your crews and the communities you serve. Combined with our Corrective Action management solution, you’ll have everything you need to schedule affected facility inspections, document inspection findings, assign and track corrective actions, send escalating notifications for inspection and repair deadlines, and document it all to ensure compliance with Quad-0 recordkeeping requirements. Visit our website at www.ehs.com for additional resources, and to learn how VelocityEHS can help you.