The Super Emitter Response Program

In November 2022, the EPA introduced plans for a Super Emitter Response Program (SERP), part of a supplemental rules proposal for methane. The program would authorize third parties to remotely monitor methane emissions and publicly report data. Companies notified of “super emitter” leaks (100 kg/hour or more) from these reports would have 5 days to analyze and identify the leak source and 10 days to take corrective actions.

The EPA has taken public comments on the proposal and plans to finalize the rules in late 2023.

Several companies and agencies are already detecting and reporting satellite identification of larger methane emissions.

Super Emitter Sources

A study published in 2022 on remote sensing (aerial platforms) concluded that super emitters in 5 major oil and gas basins were the source of 40% of the industry’s 2019-2021 methane emissions.

According to several studies, more than half of methane from U.S. well sites is emitted from wells producing less than 15 barrels a day.

Some methane emissions are sudden, intense bursts due to equipment failure. These may be preventable through routine maintenance and equipment updates.

Third Party Reporting

A public database of third-party data on leaks and company responses/corrections, potentially containing unverified information, may lead to legal and regulatory controversy over EPA functions being outsourced to external third parties.

While communities could see potential health benefits from emissions remediation, the challenges of sorting out valid data and impacts (local and national) remain a concern for the industry. The EPA does have a plan to “qualify” third-party data collectors, but Frank Macchiarola, API senior vice president of policy, economics and regulatory affairs, highlighted “legal, logistical, commercial, safety, and security risks” in SERP implementation.

Confirming Compliance

While regulations are not yet final, production facilities can take steps now to minimize known issues with leaks and emissions – modernizing equipment, sealing wells, and conducting inspections (on-site and remote). Proactive and responsible emissions reductions based on identified, known sources will put your company in control of data and protect resources.