The New Methane Rule and Continuous Monitoring: What You Need to Know
Author: Dave Levy
The new rule enables operators to use approved advanced monitoring technologies, including continuous monitoring systems, to detect fugitive emissions. Qube’s platform meets and exceeds the technical requirements for using continuous monitoring systems under the rule.
The new methane rule is finalized
On December 2, 2023, the Environmental Protection Agency (EPA) announced its final ruling aimed at reducing methane emissions from the oil and gas sector. This promulgation establishes new source performance standards (NSPS) and emissions guidelines for methane and volatile organic compounds (VOCs) from new or modified oil and gas sources; new emissions guidelines for states to follow in designing and executing implementation plans to cover existing sources; and a new Super-Emitter Program that allows third parties to track large emissions events, and which prescribes prompt remedial steps when such an event is detected and attributed.
Of broad consequence, the new rule requires more frequent monitoring and repair of methane leaks at well sites, production facilities, and compressor stations. Crucially, and pursuant to EPA’s stated goal of driving innovation, it provides operators the option of using approved advanced monitoring technologies for detecting fugitive emissions.
What’s the rationale for allowing advanced methane detection technologies in place of traditional detection technologies?
In the ruling, EPA acknowledges that some advanced methane detection technologies have important advantages, including the “ability to detect fugitive emissions quickly, cost-effectively, and in a manner that may be less susceptible to operator error or judgment than traditional leak detection technologies”.
EPA emphasizes that some advanced methane detection technologies, such as continuous monitoring systems, may also be used to identify super-emitter events sooner since these events are unpredictable and may occur outside prescribed OGI monitoring schedules for fugitive emissions. EPA finds that the real-time detection capabilities of a CM system can lead to significantly faster find-and-fix times for large emission events.
What are the technical requirements for a continuous monitoring system under the new rule?
The rule finalizes technical requirements for using an advanced measurement technology alternative to OGI and AVO monitoring at well sites, centralized production facilities, and compressor stations. Key system and operational requirements for a continuous monitoring system under the new rule include:
the system must be set up in a manner to generate a valid methane mass emission rate (or equivalent) once at least every twelve-hour block
have checks in place to monitor the health of the system
be capable of transmitting data at least once every 24 hours
maintain detection thresholds of 0.40 kg/hr of methane or lower
have an operation downtime of less than 10 percent
EPA also updated the short-term (rolling 7-day period) and long-term (rolling 90 day period) action levels for continuous monitoring systems based on site types. Site-specific baselines must be based on a 30-day period, excluding periods where maintenance activities took place.
How Qube meets the technical requirements for a Continuous Monitoring system under the new rule
Qube’s platform exceeds the performance standards for a continuous monitoring system under the new methane rule:
First, Qube’s quantification algorithm is capable of accurately determining the emission rate of an emission, which is foundational to the operational standard. Qube uses a proven plume model that filters for offsite emissions and localizes based on wind direction for quantification. Qube sensors are calibrated in the lab prior to deployment; once deployed in the field, Qube sensors use a patented technology to continuously verify their gas concentration measurement outputs and self-calibrate to account for potential baseline drift over time, which ensures consistent device performance and quantification accuracy of the platform. The following image captures an emission rate display in the Qube dashboard.
Visualization of an emission rate in the Qube dashboard
The methane rule requires that continuous monitoring systems generate a valid methane mass emission rate (or equivalent) once at least every twelve-hour block. Qube’s monitoring devices capture emissions data every minute, which is sent to a proprietary cloud-based analytics platform and displayed as a rolled-up average every 15 minutes in the web-based user dashboard.
The Qube dashboard displays a rolled-up emissions average from data captured every minute
Among the most stringent requirements for a continuous monitoring system under the new rule is that the system must maintain a detection threshold of 0.40 kg/hr of methane or lower. Qube’s minimum detection threshold, verified in METEC testing, is 0.12 kg/hr - more than triple the required detection sensitivity threshold.
Another essential requirement of a continuous monitoring system under the new rule is that it must have the ability to monitor device health in real-time and maintain an operational downtime of less than 10%. The Qube platform monitors device health in real-time to ensure consistent, reliable system outputs.
Qube’s dashboard has a device health module that provides performance data on individual monitoring devices. If a performance issue is detected, operators are notified within the dashboard, in real-time of the discovery. The following image shows how individual device health is displayed in the Qube dashboard, including each device’s anemometer performance, signal strength, and battery condition.
Real-time device health is displayed in the Qube dashboard
Qube’s applicability to OOOOa, OOOOb, and OOOOc
In the final rule, new emission sources are regulated under OOOOb through New Source Performance Standards (NSPS). Existing sources are regulated under OOOOc through presumptive standards called Emissions Guidelines (EGs) that states will implement through state-specific plans in accordance with requirements in the rule. New, modified, or reconstructed sources that began construction after Sept. 18, 2015, and on or before Dec. 6, 2022, are regulated under OOOOa.
Since Qube meets and/or exceeds all technical and performance criteria for a continuous monitoring technology under OOOOb as described above, the Qube platform can also be used to satisfy regulated equipment and sites under OOOOa and OOOOc where advanced technologies are permitted as an alternative to AVO and OGI monitoring programs.
How can operators gain approval to use Qube as an alternative monitoring technology?
The new rule allows operators to replace traditional leak detection programs with advanced measurement technologies such as continuous monitoring. These technologies must be approved by EPA when an operator submits a monitoring plan under the new rule.
The final rule proposes a streamlined approach to approving new technology that is similar to EPA’s current alternative test method approval process. This approach ensures that advanced methane detection technologies used to conduct periodic screening or continuous monitoring will provide comparable detection performance to traditional methods while encouraging innovation and adoption of emergent technologies.
The final rule directs operators to make alternative technology approval requests to EPA’s Measurement Technology Group through the methane detection portal. EPA will assess the completeness of the submission within 90 days and issue an approval within 270 days of receiving a request.
Qube will submit an application to EPA’s Measurement Technology Group for approval as an advanced measurement technology. Once approved, operators can ‘opt-in’ to use the Qube platform for compliance with the new rule.
Qube is ready to help operators gain approval to use our system
Qube is ready to help operators navigate the alternative technology application process and implement our system. Contact us to learn how Qube can help manage and reduce your emissions under the new methane rule.