Industry: Emissions Reduction

Summary

Develop a basis for the evaluation of your emissions reduction efforts in your sites. With some basic quantities, we can use our project experience to estimate the costs of the reduction implementation as well as the impact of lowering your Green House Gas (GHG) footprint.

Summary

EPA 40 CFR Part 60 establishes emission reduction standards for the control of methane and other VOCs emitted from onshore facilities. Subpart OOOO(a/b/c) of EPA 40 CFR Part 60 detail measures for proper Closed Vent System (CVS) design.

CANUSA EPC is here to help with code interpretation, requirement clarification, compliance evaluation, and certification. Enclosed is a framework detailing steps to prepare for a OOOO(a/b/c) Closed Vent System Compliance Evaluation.

This guide includes:

• Applicability Dates
• Process Flow Information
• Closed Vent System Specifications
• Documentation

As the Oil & Gas industry adapts to new environmental standards introduced through the EPA regulation OOOOb, operators are looking for low-emission substitutes for traditional instrument gas systems for pneumatic devices. Factors like power availability, extreme climates, retrofit feasibility, and long-term operating costs influence the most economical and technically viable instrument gas alternatives factor into the decision. 

Although instrument air is a popular choice for pneumatic devices, there are a variety of instrument gas alternatives that are worth considering. These options include using liquid nitrogen tanks to supply gas to pneumatic devices, using electric actuators on valves, using a combustion-based or compressor-based vent capture system, and implementing low-emission alternatives to traditional pneumatic devices. 

 

Controlling Instrument Gas Emissions 

Natural gas-driven pneumatic devices have been the standard across upstream and midstream oil and gas sites for decades. These systems are simple, reliable, and easy to integrate, but they are a significant source of methane and VOC emissions in the oil and gas industry.  

In the U.S., regulatory frameworks like EPA “OOOOb” (and soon, “OOOOc”) have required the transition away from traditional instrument gas systems. EPA Subpart OOOOb section 60.5390b requires operators to “design and operate each process controller affected facility with zero methane and VOC emissions to the atmosphere”, beginning January 22, 2027. The regulation includes mandatory monitoring and reporting for all facilities.    

In Canada, producers are adopting emissions reduction strategies to align with both internal and external ESG targets, investor expectations, and net-zero commitments. 

Controlling instrument gas emissions by implementing low-emission alternatives is the future of the industry.  

The challenge? Each instrument gas alternative comes with its own trade-offs. Let’s evaluate! 

 

Key Considerations 

These three considerations often stall progress or lead to overbuilt systems that don’t actually meet site needs. These are the top 3 we see: 

1. Site Limitations 
   
   Power availability, space constraints, and environmental conditions will determine what is feasible.
2. Budgeting & ROI 
   
   Every solution requires both CAPEX & OPEX. Liquid nitrogen systems, while low in initial cost, come with recurring delivery fees. Electric actuators are expensive, power-intensive, and, on existing sites, require retrofitting of every actuated valve.
3. Technology Trade-offs 
   
   Each alternative has a unique set of pros and cons. Some offer zero emissions but require significant upfront investment. Others are easier to implement but come with ongoing operational costs or limited scalability. 

 

Comparing the Top Alternatives for Traditional Instrument Gas Systems  

Instrument Air Systems

Instrument air is one of the most established alternatives to gas-driven pneumatics, particularly in midstream facilities. These systems use electric-driven compressors to deliver clean, dry air to valves and controllers, eliminating methane emissions entirely. 

Pros: 

• Easy integration  
• Eliminates all process controller emissions – OOOO(b) compliant with no continued reporting 
• Compatible with most existing pneumatic devices 
• Product saved – no longer using sales gas to operate pneumatic devices 
• Air is non-corrosive and abundant 
• Expandable to pneumatic pumps and other emission reduction efforts (i.e. start air) 

Cons: 

• Introduces an additional piece of rotating equipment  
• Requires power and space for compressors and dryers  
• Higher upfront capital costs  
• Possible rework of existing piping   
• Introduces an oxidizer into pneumatic lines  
• Increased operational effort due to required maintenance and troubleshooting  

Best for: Midstream or central facilities with power availability.

Vendors Offering Compression: UECompression Packages 

• 5 HP or 15 HP Reciprocating Packages 
• Duplex Recip. Package 
• 5 HP Rotary Scroll  
• Custom Packages 

 

Liquid Nitrogen Supply Systems 

An option for remote or off-grid sites, liquid nitrogen provides a zero-emission, power-free alternative for driving pneumatic equipment. Suppliers deliver nitrogen in pressurized vessels, and nitrogen is passed through regulators to send vaporized nitrogen to drive pneumatic devices. 

Pros: 

• Easy integration 
• Eliminates all process controller emissions – OOOO(b) compliant with no additional reporting 
• Product saved – no longer using sales gas to operate pneumatic devices 
• Pros over air – no additional rotating equipment 
• Pros over gas – removes requirements for reporting to the EPA 
• N2 is inert and does not provide an oxidizer into the process 
• No additional power requirements 
• Easily scalable & reliable  
• No upfront capex requirements 
• Minimal operator involvement 
• Minimal seasonal, weather, or temperature implications 

Cons: 

• Requires regular nitrogen delivery (every 30–60 days) – adds to OPEX, delivery scheduling, risk of delays/impact to schedule 
• Safety concerns with the addition of a pressurized vessel 
• Not yet widely used, may face internal approval challenges 

Best for: Small well pads or facilities without power infrastructure.

Vendors Offering Liquid Nitrogen Systems: Kathairos Solutions  

• Provides services through the full timeline for integration, from site assessment to commissioning, monitoring, reporting, and operation. 

 

Electric Valve Actuators 

Electric actuators provide an emissions-free solution to control valve actuation, eliminating the need for access to pneumatic supply lines. They’re ideal for on/off valves in remote pipeline applications. 

Pros: 

• Emission-free 
• Self-calibrating 
• Low energy requirement 
• Can be used in low temperature operation 
• No need for routing of pneumatic lines 
• Remote monitoring and configuration are available 
• Solar-powered options are available – remote, power-free pipeline applications 

Cons: 

• Significant upfront capex – not realistic for large facilities with many actuated valves  
• Slow response time – not suitable for tight process control  
• Not suitable or realistic for existing facilities – requires significant modification to existing valves  
• May not eliminate the need for pneumatic systems; other pneumatic signal users may exist apart from control valves  
• Limited applicability as an emissions reduction technology in industry   
• New technology – lack of familiarity or approval with clients and operators  
• Although additional energy requirement and cable routing.   
• Cannot operate on loss of power  

 Best for: Remote oil and gas sites with few pneumatic valves, and no additional pneumatic users. 

Vendors Offering Electric Actuation: Emerson  

• Varied applications suited for shut-down valves and control valves.  
• Offering range of sizes and duty cycles. 

 

Combustion-Based Vent Gas Capture 

This strategy captures emissions from gas-driven pneumatics and routes them to a combustor, converting natural gas into CO₂. Although this method requires continued reporting with the EPA, it can offer OOOOb compliance with minimal disruption in operations.

Pros: 

• Can continue to use instrument gas, no need to modify existing piping  
• Eliminates need for additional rotating equipment, leading to equipment and operational savings  
• Low initial Capex (if combustor is existing on site)  
• No additional power requirements  
• Possible tank battery applications – routing captured pneumatic emissions to tank venting header  

Cons: 

• Requires design and installation of a cover that can capture emissions from existing equipment 
• Only realistic if there is an existing combustor that captured emissions can be routed to 
• Significant engineering and design time 
• Does not fully eliminate emissions from pneumatic devices. Monitoring and reporting are still required for OOOO(b) compliance 

Best for: Facilities with an existing combustor and limited resources for a full system overhaul.

 

Capturing Compressor Emissions for Instrument Gas Use 

This approach captures small amounts of vented gas from compressors and reuses it to power pneumatic devices. It’s a creative way to minimize waste and emissions using existing infrastructure. 

Pros: 

• Reduces total emissions from compressors 
• Removes the need for header routing to compressors 
• No additional power requirements 
• Marginal increase in sales of gas 
• OOOO(b) compliance for compressor emissions capture and process controllers 

Cons: 

• Significant engineering and design time, modification of on-skid piping 
• Does not fully eliminate emissions from pneumatic devices. Monitoring and reporting are still required for OOOO(b) compliance. 

Best for: Sites looking to improve compressor efficiency or reduce emissions without installing new systems. 

 

Which Pneumatic Emissions Reduction Technology is Best?  

There are numerous technologies available to reduce or eliminate emissions from instrument gas lines, whether it be implementing solutions within an existing instrument gas system, adopting instrument air or vaporized nitrogen, or utilizing electrically actuated valves. Although instrument air has been the most widely used pneumatic signal alternative within the industry, operators should understand that other technologies exist and may be a more practical solution for eliminating instrument gas emissions.  

The technologies available allow for flexibility in a wide range of applications. There are options for sites with limited power availability, existing facilities looking to retrofit or upgrade their traditional instrument gas system, remote pipeline operations, and new facilities looking to build out with an emissions-free pneumatic system.   

At CANUSA EPC, we help operators make informed decisions based on real-world experience. We’ve seen the nuances of site power, valve density, weather risk, and regulatory targets. 

When you’re ready to talk instrumentation upgrades or emissions strategies, we’d be happy to share what’s working in the field.  

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FURTHER EMISSIONS-REDUCTION READING  

Instrument Gas Alternatives Comparison Guide
To accompany this blog, we have created a free comparison guide for your convenience. Download the Instrument Gas Alternatives Comparison Guide.

OOOO(b) for Compression Sites: Cost-Management Strategies for Methane Reduction
Want to ensure you meet budget and timelines? Read on for 7 strategies to consider.
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Author(s) 

Megan Hurley, Engineer I 

External Sources 

1. https://www.epa.gov/natural-gas-star-program/rulemakings-policy-and-laws-address-methane-emissions-oil-and-gas-sector#:~:text=Methane%20Emissions%20Standards,-Final%20Rules%20to&text=In%202024%2C%20EPA%20issued%20a,methane%20emissions%20from%20existing%20sources.&text=In%202016%20%2D%20EPA%20issued%20three,permitting%20requirements%20for%20the%20industry. 
2. eCFR :: 40 CFR Part 60 Subpart OOOOb — Standards of Performance for Crude Oil and Natural Gas Facilities for Which Construction, Modification or Reconstruction Commenced After December 6, 2022  
3. https://www.canada.ca/en/services/environment/weather/climatechange/climate-plan/2035-emissions-reduction-target.html 

Summary

The EPA’s latest methane rule – OOOO(b) – mandates zero-emission process controllers and pneumatic pumps, pushing gas compression facilities to invest in compliance projects. Want to ensure you meet budget and timelines? Read on for 7 strategies to consider in your compliance project program.

This whitepaper compiles data from previous projects and studies to support the financial analysis for power generation projects for operators determining what is the best onsite power solution for their project.

This OOOO(b) for compression sites guide includes:

• Article, published in Hart Energy Magazine, discussing instrument air conversions, OOOO(b) planning and best practices, achieving operational efficiencies, and moving forward with compliance
• Matrix highlighting OOOO(b) requirements of key devices found in compressor stations: dry seal compressors, controllers, pumps, vessels, and fugitive emissions
• Decision-making flow diagrams to help you determine which OOOO(b) sub-parts pertain to your operation

Summary

For operators tasked with reducing emissions from pneumatic devices, the ‘best’ instrument gas alternative isn’t always clear cut. With so many factors to consider (power availability, emissions goals, retrofit complexity) comparing your options, side by-side, can help! Our matrix summarizes key characteristics of each pneumatic signal alternative.

While no single solution fits every application, this overview can help narrow your focus and guide internal discussions about what’s realistically achievable at your facility. Determining the right solution means striking a balance of cost, complexity, and regulatory compliance.

This instrument gas alternatives comparison guide includes:

• Brief Description
• Typical Site Applicability
• Estimated Cost Profile
• Emissions Reduction Efficacy
• Sizing and Utility Requirements