Frequently Asked Questions: Fugitive Emissions
View frequently asked questions about EPA's 2024 final rule for oil and natural gas operations - fugitive emissions. On this page:
What are the requirements for well closures?
You must complete the following requirements before closing a well or well site as required by §60.5397b(l) for NSPS OOOb and §60.5387c(l) for EG OOOOc:
- Submit a well closure plan to the Administrator within 30 days of the cessation of production from all wells located at the well site. The well closure plan must include, at minimum, the following:
- Description of the steps necessary to close all wells at the well site, including permanent plugging of all wells;
- Description of the financial requirements and disclosure of financial assurance to complete closure; and
- Description of the schedule for completing all activities in the well closure plan
- Submit a notification of intent to close the well site to the Administrator 60 days before you begin well closure activities
- Conduct a survey of the well site using Optical Gas Imaging (OGI), including each closed well, after completing all well closure activities outlined in the well closure plan. If any emissions are imaged by the OGI instrument, then you must take steps to eliminate those emissions and you must resurvey the source of emissions. You must repeat steps to eliminate emissions and resurvey the source of emissions until no emissions are imaged by the OGI instrument. You must update the well closure plan to include the video of the OGI survey demonstrating closure of all wells at the site.
- Maintain records and submit reports according to §60.5420b(c)(14) and §60.5420b(b)(9) for NSPS OOOOb, and §60.5420c(c)(13) and § 60.5420c(b)(8) for EG OOOOc.
Yes, test separators are considered major production and processing equipment because “separators” are included in the definition of that term. Please see the definitions for NSPS OOOOb at § 60.5430b and EG OOOOc § 60.5430c.
An owner or operator is subject to the fugitive emissions monitoring requirements in 40 CFR part 60 subpart OOOOb for each fugitive emissions component affected facility, which is the collection of fugitive emissions components at a crude oil or natural gas well site, centralized production facility, or a compressor station for which you commence construction, modification, or reconstruction after December 6, 2022. The fugitive emissions monitoring and repair program requires audible, visual, and olfactory (AVO) inspections at all site types (except those located on the Alaska North Slope) and OGI or EPA Method 21 monitoring at some site types. For well sites, the type and quantity of equipment located at the site (not an emissions threshold) determine the monitoring requirements. See § 60.5397b for more details.
Further, a fugitive emissions component is any component that has the potential to emit fugitive emissions of methane or VOC such as valves (including separator dump valves), connectors, pressure relief devices, open-ended lines, flanges, certain covers and closed vent systems, certain thief hatches or other openings on a storage vessel, compressors, instruments, meters, and yard piping.
The term fugitive emissions (see definition at § 60.5430b), for the purposes of §60.5397b, means:
- any indication of emissions of methane or VOC observed from a fugitive emissions component using AVO;
- an indication of visible emissions of methane or VOC observed from an OGI instrument; or
- an instrument reading of 500 ppmv or greater using Method 21 of appendix A–7 to 40 CFR part 60.
All fugitive emissions composed of methane, VOCs, or both, must be repaired according to the provisions in 60.5397b(h).
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