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Super Emitters: What are they and why are they important?

Did you know that a small number of sources are responsible for a significant percentage of methane emissions? They're called "Super Emitters". These emissions impact our environment and air quality.

On November 11, 2022, the U.S. Environmental Protection Agency (EPA) released an update to its 2021 rules proposal (0000b and 0000c) for the oil and natural gas industry, aiming to reduce methane and other harmful air pollution from both new and existing operations. The supplemental proposal enhances the 2021 rules by improving standards and expanding the scope to include previously uncovered sources.

The key points of this program include:

  1. Defining Super Emitters: The EPA defines super-emitting events as emissions of 100 kilograms of methane per hour or more, primarily at specific sites like well sites, production facilities, compressor stations, or processing plants.
  2. Leveraging Technology: The program relies on expertise and data from regulatory agencies or approved third parties with access to remote methane detection technology.
  3. Notification Process: Approved notifiers, which can be technology vendors, industry experts, researchers, or non-profit organizations, will inform facility owners and operators when a super-emitter event is detected. Notifications must include detailed information to verify the source.
  4. Root Cause Analysis: Upon notification, owners and operators must conduct a root cause analysis and take corrective actions to eliminate the emissions source.
  5. Revocation Mechanism: There's a provision for owners and operators to seek the revocation of a notifier's EPA certification if multiple notifications contain demonstrable errors.
  6. Transparency: The EPA will maintain a document repository with notices to operators and reports submitted by owners and operators. This ensures transparency and access to information for notifiers, communities, and stakeholders.

The table included in the post summarizes the proposed requirements for super emitters, detailing the Best System of Emission Reduction (BSER) and the proposed standards. This program aims to reduce emissions from super emitters and improve overall environmental outcomes in the oil and gas industry.

Summary of Proposed Requirements for Super Emitters

(Presumptive Methane Standards for the Emissions Guidelines are the Same)

Type of siteProposed BSERProposed Requirements
Supper-emitter sitesRoot cause analysis and corrective action following notification of super-emitter emissions event- Root cause analysis within five days of receiving a notification of a super-emitter event AND Corrective action, if needed, following notification of super-emitter emissions event

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