Current federal regulations for hydrocarbon emissions from natural gas wellhead operations (including storage of natural gas condensates and produced waters at the wellhead) are limited in number and scope. [The only current federal regulation is 40 CFR 60, Subpart – Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution.] A few states, such as Colorado, are developing and implementing more stringent regulations but, in comparison to most industrial operations, air emissions from natural gas production facilities are lightly regulated. The EPA is interested in requiring owner/operators to implement leak detection and repair programs at natural gas production sites. The goal is to reduce emissions from leaking equipment components and from equipment that is not properly operated (e.g. an open thief hatch on a condensate storage tank). In lieu of traditional leak detection methods (e.g. U.S. EPA Method 21), EPA is exploring the potential application of remote monitoring systems that would quickly notify the operators of excessive emissions at wellhead operations. Once notified, the operators would be required to find and fix the source of emissions. In order to adress these challenges, Atmosfir have developed the remote wise-LDAR product. The wise-LDAR includes single or serveral low-cost open path total hydrocarbon monitors and associated spatial algorithm to locate the leaks.
Technical challenges overcome by wise-LDAR:
1. System is robust enough for permanent installation at sites that do not have full-time operators.
2. System is robust enough to operate under extreme ambient conditions.
3. System is reliable; i.e., can operate for extended periods of time without the need for hands-on maintenance, calibration, etc.
4. The equipment is able to operate without access to on-site electricity.
5. The system is able to operate in very remote locations.
6. The system is simple, quickly providing information that indicates a leak at the site – and potentially where to look.
7. The system is relatively low cost.
Because remote wise-LDAR adresses these challenges, it is now possible for the EPA to overcome the objections of the industry when they proceed to selective enforcement actions and, eventually, to rulemaking.