EHS Administration, Sustainability

EPA Utilizing Flyover Emissions Monitoring

The EPA recently announced flyover emissions monitoring of the Permian Basin in Texas and New Mexico to identify super-emitters.

“The Permian Basin accounts for 40 percent of our nation’s oil supply and has produced large quantities of dangerous [volatile organic compounds (VOCs)] and methane over the years, contributing to climate change and poor air quality,” said Region 6 Administrator Earthea Nance, PhD, in an EPA news release. “The flyovers are vital to identifying which facilities are responsible for the bulk of these emissions and therefore where reductions are most urgently needed.”

The flyovers utilize infrared cameras to survey oil and gas operations to identify large emitters of methane, a powerful greenhouse gas (GHG), as well as excess emissions of VOCs.

Helicopter surveillance allows the EPA to monitor large geographic areas and survey the thousands of oil and gas operations located in the basin. When the infrared camera detects hydrocarbon emissions during a flyover, a technician on board the helicopter notes the time, GPS location, and other information about the emissions source. This information is used to identify the facility that released the excess emissions and initiate enforcement follow-up actions with the facility operator.

Enforcement for noncompliance found during the flyovers includes EPA administrative enforcement actions and referrals to the Department of Justice (DOJ). The EPA’s actions to address these violations involve significant penalties, corrective actions to prevent future noncompliance, and monitoring to verify corrective actions have addressed the emissions.

Methane GHG emissions impact the earth’s climate, and VOCs have both short- and long-term health impacts, including damage to the liver, kidneys, and central nervous system; loss of coordination and nausea; headaches; and eye, nose, and throat irritation. VOCs also contribute to the formation of ozone and fine particulates in the atmosphere.

The reduction of methane emissions remains a top priority for the Texas oil and natural gas industry, said Todd Staples, president of the Texas Oil and Gas Association, according to The Texas Tribune.

“Efforts to identify and lower emissions have been a ‘great success’ thanks to companies’ investments in technologies such as handheld optical imaging cameras, drones, flyovers, leak detection and repair techniques and the replacement of pneumatic valves with zero-emission pneumatic controllers, Staples said. He added that methane emissions intensity in the Permian Basin has declined by nearly 70% since 2011.”

Companies operating in the Permian Basin are advised to ensure their facilities are aware of EPA flyover enforcement activities and to take proactive steps to ensure their facilities remain in compliance.

In the event your company receives an EPA notice of alleged noncompliance, be sure to promptly respond to all EPA communications and actively address any issues brought to light in the EPA notifications.

“Companies should keep in mind that EPA often seeks to achieve settlements that provide more than is required by rule and then uses those settlements to benchmark new industry standards through settlements across industry. In the wake of the Supreme Court’s decision in West Virginia v. EPA, … EPA and the [DOJ] may be evaluating ways to achieve concrete [GHG] emissions reductions through their enforcement authority and surrogate pollutant emission reductions,” advises an article by Beveridge & Diamond P.C. in the National Law Review.

The EPA has periodically utilized aerial surveillance in the Permian Basin since 2019. The Agency also utilizes this type of surveillance in Louisiana to monitor air quality and on the mid-Atlantic coast to record marine life sightings, algae blooms, oil slicks, boating, and beach use activities.

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