An ExxonMobil subsidiary, XTO Energy, Inc., announced that it filed the first-ever application to the US Environmental Protection Agency (EPA) for an Alternate Means of Emission Limitation (AMEL) pertaining to the EPA’s “Quad Oa” (40 CFR Part 60 Subpart OOOOa) to satisfy its requirements for Leak Detection and Repair under NSPS OOOOa using new technology in April 2021.
ExxonMobil’s AMEL application requests the use of LiDAR technology from aircraft to detect leaks at XTO facilities across the Midland portion of the Permian Basin to satisfy its federal requirements for Leak Detection and Repair at those facilities.
This is a particularly exciting breakthrough since industry and technology providers alike have spent years trying to figure out how to demonstrate equivalency for the purposes of applying for an AMEL in order to unlock the potential of newer technologies to find and fix emissions sources from oil and gas facilities. This is a significant move by a leader in the oil and gas industry to open new paths to leverage emerging technology to tackle leaks.
Here are three reasons why XTO’s AMEL submission to the EPA is so important:
1. An approval could pave the way for new approaches to leak detection, offering the promise of enhanced efficiency and cost-effectiveness and encouraging further innovation
The current EPA-approved Quad Oa methods for detecting and locating methane and VOC leaks include Optical Gas Imaging (OGI) and Method 21, both of which involve ground crews detecting leaks with handheld instruments. Scanning oil and gas sites from the air is significantly faster than scanning with ground crews and handheld instruments. Bridger’s LiDAR technology allows for these aerial scans to quickly survey all of the facility over a matter of days, which enables crews to prioritize and fix the largest leaks first.
Further, ExxonMobil’s AMEL is an important step, paving the way for the oil and gas industry to deploy modern technologies to tackle methane leaks. The application provides a framework by which to assess equivalent emissions reductions from very different leak detection approaches. This framework will guide other operators in making similar applications, spark further innovation across the technology ecosystem with this concrete demonstration of operationalization, and provides a first pass at streamlining for regulatory applications.
2. Leak detection toolkits would be greatly expanded with broader regulatory acceptance of LiDAR
XTO’s submission for AMEL approval in the US follows previous submissions of Bridger’s Gas Mapping LiDAR for analogous regulatory approval by oil and gas operators in Canada (e.g., Alternative Fugitive Emissions Management Programs, or Alt FEMPs). While each oil and gas operator must submit its own AMEL for its facilities in the US, XTO’s application will go through public notice and comment, so the processes will be adaptable for others’ use. This offers the hope of significant streamlining for future AMEL submissions.
Bridger’s Gas Mapping LiDAR
ExxonMobil conducted extensive field tests of eight different emerging detection technologies applied to over 1,000 sites in Texas and New Mexico. Five different aerial surveillance methods were tested, along with one satellite surveillance method, one truck-mounted monitoring method, and one fixed position monitor.
Bridger Photonics’ patented Gas Mapping LiDAR technology is unparalleled in the industry enabling detection of over 90% of typical basin emissions, coupled with actionable data to direct crews straight to the leak source. Bridger flies aircraft fitted with its Gas Mapping LiDAR sensors to scan oil and gas infrastructure in search of leaks. Using this technology, leaks are pinpointed and given GPS coordinates typically to within a few meters.
Read the full press release here.
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