that it is not technically feasible . Considerations for deeming a Low-E solution technically infeasible include cases where the low-E technology is unsuitable for the valve ’ s intended use , retrofit requirements ( like re-piping or space limitations ), commercial unavailability for specific types of valves , or issues with certain instrumentation assemblies . Operators must annually report instances where it was infeasible to use low-E technology for repairs , including the reasons for infeasibility . |
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• Definition of Low-E Valves and Packing : |
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Low-emission ( Low-E ) valves and packing are defined as follows : A low-E valve is a type of valve for which the manufacturer provides a guarantee that it will emit fugitive emissions at a rate of less than 100 parts per million by volume ( ppmv ) over the first five years . Similarly , low-E packing , used in these valves , adheres to the same emissions standard as per the manufacturer ’ s warranty . Additionally , there is low-E injectable packing , which is specifically designed for drill-and-tap valve repairs and also comes with a manufacturer ’ s guarantee regarding emission levels . The EPA outlines that low-E equipment meets the specifications of API 622 or API 624 and typically includes a manufacturerwritten warranty or a performance guarantee that it will not emit fugitive emissions at a concentration greater than 100 ppmv during the first 5 years . |
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Another area of significant impact is pneumatic controllers . According to the EPA , “ pneumatic controllers are process control automation devices used widely in the natural gas industry to operate valves |
that control liquid level , pressure , and other process variables . While they can be powered by natural gas or compressed air , natural gas-powered pneumatic controllers are commonly used . Some pneu- |
matic controllers are designed to bleed ( or emit ) continuously , while others may emit natural gas into the air only when actuated or malfunctioning . Pneumatic controllers are one of the largest sources of vented methane emissions from the natural gas industry .” 3
The new EPA rules regarding controllers , specifically natural gas-driven process controllers , are designed to significantly reduce emissions , particularly methane , from these devices in the oil and gas sector . The key rules for controllers include :
• Zero Emissions Standard : For sites outside of Alaska , all process controllers are required to achieve zero emissions of VOCs and GHGs , specifically methane . This standard applies to both new and existing sites . Compliance can be attained through several methods : utilizing process controllers that are not driven by natural gas , thus not being classified as affected facilities ; routing vapors from natural gas-driven process controllers through a closed vent system to a process where they can be controlled ; or using self-contained natural gas-driven process controllers , among other methods , to ensure the numerical standard of zero emissions for methane and VOCs is achieved .
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• Bleed Rate Requirements : For certain types of process controllers , such as continuous bleed controllers , there may be specific bleed rate requirements . For instance , these controllers might be required to have an emissions rate ( or bleed rate ) of less than or equal to 6 standard cubic feet per hour ( scfh ).
In conclusion , the final rule set by the EPA marks a critical step towards mitigating the impact of the oil and gas industry on the environment and public health . By targeting equipment emissions , the rule addresses one of the key sources of air pollutants in this sector . The anticipated reduction in methane , VOC , and HAP emissions over the next 15 years underlines the rule ’ s potential to contribute significantly to cleaner air and a healthier environment . Moreover , the inclusion of advanced detection technologies and the focus on energy-efficient emissions control highlight the rule ’ s approach to balancing environmental goals with economic considerations . The 79 % projected reduction in methane emissions underscores the rule ’ s potential for significant climate benefits .
REFERENCE
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• Special Provisions for Emergency Shutdown Devices : Process controllers that are used as emergency shutdown devices ( ESDs ) or are not natural gas-driven are not included under the affected facility category in these standards . |
1 . https :// www . regulations . gov / docket / EPA-HQ- OAR-2021-0317
2 . https :// www . epa . gov / system / files / documents / 2023-12 / eo12866 _ oil-and-gas-nsps-eg-climate-review-2060- av16-final-rule-20231130 . pdf
3 . https :// www . epa . gov / natural-gas-star-program / pneumatic-controllers
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ABOUT THE AUTHOR |