• Compliance Selfies for Oil And Gas Production Sites?
  • August 30, 2016 | Author: Theodore J. Esborn
  • Law Firm: McDonald Hopkins LLC - Cleveland Office
  • United States EPA has finalized rules (81 FR 35896) that will expand the use of infrared cameras for leak detection at new, reconstructed and modified oil and gas production sites. The rules, which took effect August 2, 2016, will require owners and operators of oil and gas production sites to inspect for and repair methane leaks at their facilities. For well sites, monitoring for leakage must take place twice per year. For compression stations, leak detection monitoring must be conducted quarterly.

    Under the new rules, leak monitoring can be accomplished through optical gas imaging infrared cameras, or by using portable volatile organic compound monitoring instruments, known as “sniffers.” The infrared camera technology (known as “forward-looking infrared” or “FLIR”) cannot determine the type or quantity of chemical compounds “leaked.” It can only produce the image of a fugitive emission or plume. Upon citing a fugitive emission or plume through FLIR, the owner-operator must then further analyze the leak to assess its contents and quantity. The new rules require repair of any detected methane leak within 30 days of its discovery, with a resurvey of the repair to be conducted within 30 days after repair completion.

    One advantage of the FLIR camera is that it can monitor a much larger area since it is able to produce actual images of fugitive emissions. Cameras can be mounted on aircraft, including drones. Sniffers are more limited in their scope, being utilized at the points where leaks typically occur. One criticism of FLIR cameras is that they can be prohibitively expensive for small operators. One camera costs $120,000. FLIR proponents point out that as an alternative to purchasing the cameras, owners/operators can engage the services of contractors who provide FLIR monitoring for a fee.

    EPA has clearly committed to the FLIR technology as part of its “Next Generation Compliance Strategy,” an initiative to attain regulatory compliance through the use of information technology in rules and permits. EPA has also begun requiring FLIR technology in Settlement Agreements to ensure and document compliance. While FLIR technology is an authorized monitoring option under the new federal EPA rule, a proposed Bureau of Land Management rule would make FLIR monitoring mandatory for owners/operators of 500 or more oil and gas wells within a Bureau field office jurisdiction. It appears that cameras are destined to become a staple for demonstrating fugitive emission compliance in the oil and gas industry.