Emission Measurement Center
Oil and Natural Gas Advanced Methane Technology
Program
Guideline Document
For
Alternative Test Method Requests
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Emission Measurement Center
and Natural Gas Advanced Methane Technology Progra
Guideline Document
For
Alternative Test Method Requests
U.S. Environmental Protection Agency
Office of Air Quality Planning and Standards
Research Triangle Park, NC
Version 01: May 2024
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Executive Summary of Guideline Document
This guideline document is a resource for applicants and end users of 40 CFR subpart
OOOO, 0000a, 0000b, and 0000c Advanced Methane Technology Alternative Test Method
(ATM) program and for federal, state, local, and tribal authorities in understanding the
methane ATM request and review process. The EPA has designed this document to describe the
aims of the program, guide applicants through the methane Alternative Test Method (ATM)
Request process, outline what EPA expects to see in the methane ATM Request, and provide
material to assist in the creation of your methane ATM Request.
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Table of Contents
1.0 Introduction to this Compliance Guide 1
2.0 Acronyms and Abbreviations 3
3.0 Background 4
4.0 Overview of Process, Timeline, and Requirements 5
4.1 Methane ATM Request Overview 5
4.2 Summary of Review Process and Timeline 5
4.3 Brief Overview of Periodic Requirements 5
4.4 Brief Overview of Continuous Requirements 6
5.0 How to Create and Submit a Methane ATM Request 8
5.1 Creating a login.gov account and New ATM Request 8
5.2 Important ATM Request Website Features 8
6.0 Specific Content of the Methane ATM Request 12
6.1 Overview of Required Content 12
6.2 Regulatory Language for Methane ATM Request 13
6.3 Header Information on the Methane ATM Request 14
6.4 The Submission Buckets 15
6.5 Confidential Business Information 19
6.6 Submitting Additional Requested Information 20
6.7 Withdrawing a Methane ATM Request 20
6.8 Submissions with multiple emission detection thresholds (tentative placement) 20
6.9 Major Revision to Existing Methane ATM Requests 21
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6.10 Personal Identifiable Information 21
6.11 Checklist for applicants 22
6.12 Frequently asked questions 22
7.0 The Methane ATM Review Approval Process 31
7.1 Timeframe for Methane ATM Review Approval 31
7.2 Determination/Submittal of a new Methane ATM Review 31
7.3 Post-submission Methane ATM Review Process 31
7.4 Request Approval or Disapproval 33
7.5 Sunsetting Approved Technologies 33
7.6 Solution Provider or Solution Name Change 34
8.0 Super Emitter Program Applications 34
8.1 Overview of Super Emitter Application 34
8.2 How the Documentation requirements differ from the Methane ATM Request 34
8.3 Review Process and notification Differences from the Methane ATM Request 34
8.4 Frequently Asked Questions 34
Appendix A - Methane ATM Request Portal Procedures 1
A.l Home 2
A.2 Login.gov Account 2
A.3 New ATM Request 5
A.4 Browse ATM Requests 14
A.5 Approved ATM Requests 16
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A.6 Frequently Asked Questions 17
A.7 Contact Us 19
Appendix B - Executive Form Letter 1
Appendix C - Environmental Monitoring Management Council (EMMC) Methods Format (GD
45) 1
Appendix D - 60.5398b(d) Rule Language for the MATM Program 1
List of Tables
Table 1. Acronyms and Abbreviations 3
Table 2. Table 1 to Subpart OOOOb of Part 60—Alternative Technology Periodic Screening
Frequency at Well Sites, Centralized Production Facilities, and Compressor Stations Subject to
AVO Inspections with Quarterly OGI or EPA Method 21 Monitoring 6
Table 3. Table 2 to Subpart OOOOb of Part 60—Alternative Technology Periodic Screening
Frequency at Well Sites and Centralized Production Facilities Subject to AVO Inspections and/or
Semiannual OGI or EPA Method 21 Monitoring 6
Table 4. Check list for Applicants 22
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List of Figures
Figure 1. New ATM Request Input Form - Point of Contact/Company/Product Info 8
Figure 2. New ATM Request Input Form - Documentation 9
Figure 3. New ATM Request Input Form - Supporting Documentation 9
Figure 4. Portal - Home Page 2
Figure 5. Portal - Log-in.gov Account 3
Figure 6. Portal - Log-in.gov Create Account 3
Figure 7. Portal - EPA Gateway 4
Figure 8. Portal - Login.gov Sign-In 4
Figure 9. Portal - Login.gov One-time Code 5
Figure 10. Portal - New ATM Request 6
Figure 11. Portal - New ATM Request Input Form (Point of Contact/Company/Product Info) 7
Figure 12. Portal - New ATM Request Input Form (Documentation) 8
Figure 13. Portal - New ATM Request Input Form (Supporting Documentation) 9
Figure 14. Portal - New ATM Request Communication Window 12
Figure 15. Portal - New ATM Request Update/Withdraw Table 13
Figure 16. Portal - New ATM Request Update/Withdraw ATM Request 14
Figure 17. Portal - Browse ATM Requests List 15
Figure 18. Portal - Browse ATM Requests Details 15
Figure 19. Portal - Browse ATM Requests Details View Documentation 16
Figure 20. Portal - Approved ATM Requests 17
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Figure 21. Portal - Approved ATM Requests Details 17
Figure 22. Portal - Frequently Asked Questions List 18
Figure 23. Portal - Frequently Asked Questions Example Question 18
Figure 24. Portal - Contact Us 19
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1.0 Introduction to this Compliance Guide
This guideline document addresses (1) the Environmental Protection Agency's (EPA)
methane alternative test method approval/disapproval authority under Section 60.5398b(d) of
40 CFR part 60 and (2) describes the EPA processes and procedures for requesting and
responding to requests for approval of ATMs. This alternative test method
approval/disapproval is unique to methane detection technology for use for fugitive
monitoring, inspection, and monitoring of covers and closed vents systems, and remote
detection technology used in the super emitter under 40 CFR part 60, subpart OOOOb; and is
separate to other alternative test method authorities identified the general provisions to parts
59, 60, 61, 63, and 65 of Title 40.
This guideline document specifically addresses how technology developers and other
entities (owners and operators) should seek approval for alternative test methods to
demonstrate the performance of advanced methane detection technologies. This guideline
document provides details on what needs to be submitted in an alternative test method
request and the process for submitting ATM Requests via methane detection portal at
www.epa.eov/emc/oil-and-eas-alternative-test-methods. Once approved, these advanced
technologies could be used as defined in § 60.5498b(b) and (c) of part 60 in lieu of, or in
addition to, the required fugitive monitoring and inspection and monitoring of covers and
closed vent systems under 40 CFR part 60 subparts OOOOa, OOOOb and OOOOc to identify
emissions. Likewise, these technologies could also be used to identify super-emitter events
under 40 CFR part 60 subparts OOOO, OOOOa, OOOOb and OOOOc as defined in § 60.5471b of
part 60.
The statements in this guideline document are intended solely to aid regulated entities
in complying with the published national regulation "Standards of Performance for New,
Reconstructed, and Modified Sources and Emissions Guidelines for Existing Sources: Oil and
Natural Gas Sector."1
The U.S. EPA may decide to revise this guideline document without public notice to
reflect changes in the EPA's approach to implementing the rule's requirements or to clarify the
regulatory text. To determine whether the EPA has revised this guideline document and/or to
obtain copies, contact the EPA review team at MethaneATIVI@epa.gov.
1 89 FR 16820 (March 8, 2024).
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The full text of the rule is available online at:
https://www.federalreeister.eov/documents/2024/03/08/2024-00366/standards-of-
performance-for-new-reconstructed-and-modified-sources-and-emissions-euidelines-for.
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2.0 Acronyms and Abbreviations
Table 2-1 provides a list of acronyms and abbreviations that are used in this guide along
with their "long name".
Table 1. Acronyms and Abbreviations
Acronym
Long Name
ATM
Alternative Test Method
AVO
Audible, Visual and Olfactory
BMPs
Best Management Practices
BSER
Best Systems of Emission Reduction
BTU
British Thermal Units
CAA
Clean Air Act
CBI
Confidential Business Information
CDX
Central Data Exchange
CVS
Closed Vent System
DQI
Data Quality Indicator
DQO
Data Quality Objective
CEDRI
Compliance and Emissions Data reporting Interface
CFR
Code of Federal Regulations
C02
Carbon Dioxide
CMS
Continuous Monitoring System
eCFR
Electronic Code of Federal Regulations
EMC
Emission Measurement Center
EPA
Environmental Protection Agency
FAQ
Frequently Asked Questions
ft
Feet
hr/yr
Hour per Year
kg/hr
Kilogram per Hour
LDAR
Leak Detection and Repair
MATM
Methane Alternative Test Method
MTG
Measurement Technology Group
m
Meter(s)
NSPS
New Source Performance Standards
OAQPS
Office of Air Quality Planning and Standards
OAR
Office of Air and Radiation
OECA
Office of Enforcement and Compliance Assurance
OGI
Optical Gas Imaging
Pll
Personal Identifiable Information
POC
Point of Contact
ppm
Parts per Million
ppmv
Parts per Million Volume
QA/QC
Quality Assurance/Quality Control
SEP
Super Emitter Program
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3.0 Background
On December 6, 2023, EPA issued the final rule for "Standards of Performance for New
Reconstructed, and Modified Sources and Emissions Guidelines for Existing Sources: Oil and
Natural Gas Sector Climate Review," which can be accessed at
https://www.epa.gov/controlling~air~pollution~oil~and~natural~gas~operations/epas~final~rule~
oil-and-natural-eas. The final rule is expected to sharply reduce emissions of methane and other
harmful air pollution from oil and natural gas operations. The final rule recognizes and
encourages innovation in advanced methane detection technology which establishes a
streamlined pathway allowing alternative options for compliance through the use of advanced
methane detection technologies, like satellite monitoring, aerial surveys, and continuous
monitors, to find leaks. Owners and operators are allowed to use new technologies as they
continue to develop, effectively allowing alternative methods of compliance in lieu of
traditional ground-based methods such as AVO, OGI and EPA Method 21. This guideline
document describes the alternative test method submittal requests and procedures for seeking
approval under 40 CFR §60.5398b(d).
The authority to approve and disapprove alternative test methods fugitive monitoring;
inspection and monitoring of covers and closed vents systems; and remote sensing of super
emitters in NSPS 0000b is held by the Administrator. The authority to make this determination
may be delegated to the Office of Air and Radiation, when this were to occur, this document
will be revised to identify the delegation number in EPA's Internal Delegation Manual to further
clarify the authority.
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4.0 Overview of Process, Timeline, and Requirements
4.1 Methane ATM Request Overview
You are making an ATM Request to be used for either fugitive monitoring and inspection
and monitoring of closed vent systems or for use in identifying super emitter events. Your ATM
Request has three primary pieces: 1) a document describing how your technology works, from
first principles through solution; 2) a set of supporting documents demonstrating the
technology works as stated and showing applicability; 3) the formal ATM. These three ATM
Request pieces will be discussed in section 6 of this guideline. Your request will be submitted as
either a periodic screening method or a continuous screening method, and will be evaluated
under that framework. The basic requirements for each type of screening method are outlined
below in sections 4.3 and 4.4.
4.2 Summary of Review Process and Timeline
The ATM Request must be submitted to the ATM portal and will be reviewed by an EPA
technical review team. A completeness check will be performed in the initial 90 days following
submission, and a final acceptance or denial will be returned by 270 days from the submission
date. If the EPA technical review team determines the completeness check fails within the
initial 90 days, the ATM Request may be withdrawn and later resubmitted. In the unlikely case
that EPA fails to meet the 270-day decision deadline, the ATM Request will be conditionally
approved until the review is complete.
The ATM Request will be reviewed by completeness and the review timeline will depend
upon the complexity of the proposed approach. There is no approval timeline benefit for early
ATM Requests if the request is incomplete. Please review the required documentation
thoroughly during your ATM Request development. Questions for the review team can be
submitted through the communication window in the application portal. The EPA has designed
this review process to be iterative between the applicant and the reviewers, and the review
team may reach out with questions, requests for additional information, or requests to meet
and discuss your ATM Request during the review process.
Please review the required documentation thoroughly during your ATM Request
development. Questions for the review team can be submitted through the communication
window in the ATM Request portal.
4.3 Brief Overview of Periodic Requirements
The methane detection solutions approved through the ATM request and review
process will be used as alternatives to the current Best System of Emission Reductions (BSER),
which is quarterly OGI surveys. The frequency of deployment of the approved solution is based
on the minimum detection threshold of the technology, shown in the following tables. The
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frequency of the surveys will be based on the deployed solution with the highest aggregate
detection threshold.
Table 2. Table 1 to Subpart OOOOb of Part 60—Alternative Technology Periodic Screening
Frequency at Well Sites, Centralized Production Facilities, and Compressor Stations Subject to
AVO Inspections with Quarterly OGI or EPA Method 21 Monitoring
Minimum Screening Frequency
Minimum Detection Threshold of Screening Technology
Quarterly
<1 kg/hr2
Bimonthly
<2 kg/hr
Bimonthly + OGI
<10 kg/hr
Monthly
<5 kg/hr
Monthly + OGI
<15 kg/hr
Table 3. Table 2 to Subpart OOOOb of Part 60—Alternative Technology Periodic Screening
Frequency at Well Sites and Centralized Production Facilities Subject to AVO Inspections
and/or Semiannual OGI or EPA Method 21 Monitoring
Minimum Screening Frequency
Minimum Detection Threshold of Screening Technology
Semiannual
<1 kg/hr.
Triannual
<2 kg/hr.
Triannual + OGI
<10 kg/hr.
Quarterly
<5 kg/hr.
Quarterly + OGI
<15 kg/hr.
Bimonthly
<15 kg/hr.
Events need to be captured at the 90% probability of detection limit; i,e., the solution
will catch 90% of the events that occur above the minimum detection threshold of the
screening technology. Your method and ATM Request document should detail how the 90%
probability of detection was determined.
4.4 Brief Overview of Continuous Requirements
For a continuous monitoring method, the network must operate with no greater than
10% downtime (at least 90% uptime). This is determined on a rolling annual basis each month,
meaning at the end of each calendar month, the downtime is calculated for the previous 12
months. Downtime means any of the following:
2 3 kg/hr for a period of 2-years from effective date of the rule.
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• A period where the system fails to record methane data at least once every 12-hour
block period,
• A period following a failed quality assurance check until the system passes a new quality
assurance check, or a replacement monitor is installed, or
• A period when a monitor is outside of its range.
Note that the uptime requirements are separate from the data transmission
requirements (once every 24 hours), which are intended to account for sites that have low
connectivity. Additionally, note that the requirements simplify to a minimum requirement of
one valid emission calculation for the site, with no more than 12 hours between that valid
measurement and the next. This is minimum acceptable behavior, to allow for some flexibility
in adapting to poor environmental conditions.
Continuous monitoring solutions must be able to determine a minimum leak threshold
of 0.4 kg/hr over the site background. The site background should be determined using a 30-
day rolling average of the emissions from the site, with all allowed maintenance events
removed. This will allow the solution to characterize the baseline methane emissions for the
site when it is operating as expected, and fugitive emissions will be quantified as measurements
above that background.
Once the system has completed the 30-day background determination, the fugitive
events will be calculated as emissions above the site-specific background, action events are
determined from a calculated 7-day and 90-day rolling average. When the site exceeds the 7-
day rolling average, an investigation must be completed with 5 days of the action level
exceedance; for exceedances on the 90-day average the investigation must be completed
within 30 days of the exceedance.
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5.0 How to Create and Submit a Methane ATM Request
5.1 Creating a login.gov account and New ATM Request
In order to submit methane ATM Request to EPA, a login.gov account is required. Visit
www.iogin.gov for information on account creation. One you have created the account,
navigate back to the submission portal, click the Login link and enter your credentials. You will
be prompted to enter a one-time code to access the system. Once you are logged into the
system, click the New ATM Request link to create a new submittal.
5.2 Important ATM Request Website Features
A detailed discussion of how to navigate the website is included in Appendix A. Below is
a brief overview of several important ATM Request features.
Figure 1. New ATM Request Input Form - Point of Contact/Company/Product Info
| New ATM Request
Approved A1M Requests
Contact us
Note About CBI
submitted
pubUwftho
Please fill out the form below, vou can i^ve you' p'OgftAS a? joy time and ?etu< to
later. When you ire finished, you can submit it tor ffview Your appucabon ntU becotr
publicly visible ? days afu* you submit it (or sooner if it's approved. I
If you have questions, get h
otil Get Help
Communication Window
0 Avoid personal information
Contact information will be hidden from the public but you are
encouraged to provide business ( non-personal i email and phone.
1. Point of Contact
2. Company and Product
Header Information
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Figure 2. Mew ATM Request Input Form - Documentation
CBI Checkbox
3. Documentation | | CBI also submitted
. r —. . Executive Summary (recommended) ©
Information Elsewhere k
Q This information is provided in another file or not relevant
Add one or more files
Upload file
Drag files here or choose from folder
Bucket 1
Description of Technology ©
J This information is provided in another file or not relevant
Add one or more files
Drag files here or choose from folder
Bucket 2
Figure 3. New ATM Request Input Form - Supporting Documentation
Supporting Documentation ©
~ This information is provided in another file or not relevant
Add one or more files
Drag files here or choose from folder
Bucket 3
Formal Alternative Test Method ©
~ This information is provided in another file or not relevant
Add one or more files
Drag files here or choose from fotder
Bucket 4
Save
Submit
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5.2.1 Communication Window
The Communication Window is provided to facilitate communication between submitter
and reviewer. The Communication Window can be used as soon as you save your application
for the first time. Clicking this link will pop open a text box where you can ask or respond to
questions. While the communication window does not allow real time communication, the
correspondence will be saved with the records of the review. Please use the communication
window for any question you have about the Methane ATM Request materials and process.
5.2.2 Header Information
This information is required to be filled out by the submitter prior to submitting.
Additional details regarding the Header Information can be found in Section 6.3 of this
guideline document.
5.2.3 Submission Buckets for Methane ATM Request Materials
This is where the bulk of the required materials will be submitted. Specifics regarding
what needs to be submitted in each bucket can be found in Section 6.0 of this guideline
document. Please try to follow the submission guidelines outlined in Section 6.0 of this
guideline document. The more organized your submission is, the more streamlined the review
process will be.
5.2.4 Upload File
Click the "Choose file" button to upload a new file. You can upload multiple files into
each bucket by clicking the "+" button located across from the "Choose File" button.
5.2.5 Information Elsewhere checkbox
Click this checkbox if the information requested for the bucket is included elsewhere. If
this checkbox is clicked, a text box will pop up and you will be prompted to inform us why the
information is not included or where exactly it is located.
And example of when this checkbox should be used. The EPA requests standard
operating procedures to be submitted in bucket 3 (Supporting Information), however, you
submitted some documents through the EPA confidential business information (CBI) system.
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5.2.6 CBI checkbox
Click this checkbox to inform the EPA that you have also submitted documents through
our CBI system (details in Section 6.5 of this guideline document). If you submit documents
through our CBI system, but fail to check this checkbox, the review process will likely be
delayed.
5.2.7 Save button
Save your work often. You have the ability to save and close out of your ATM Request.
You may continue to work on your ATM Request by logging back in to your login.gov account.
Save:
The ATM request can be saved at any time while populating fields and providing
information. The draft Request ID associated with the request will be generated and you
can return to the input form at a later time to complete the request.
5.2.8 Submit Button
When your ATM Request is complete, click the Submit button. The EPA review team will
be notified of new submissions on a weekly basis. After submission, your files will be public-
facing and you will no longer be able to edit or delete any documents that have been
submitted. You will still have the ability to log in to your account and add additional documents
per the review team's request (Section 6.6 of this guideline document). The submitter will have
the ability to withdraw the ATM Request throughout the review process (Section 6.7 of this
guideline document).
5.2.9 Modify a Submitted ATM Request
If you have a solution that is getting a Major Revision (See Section 6.9 of this guideline
document), open your original ATM Request and use the "Create Revision" button. This will
create a new ATM Request with a unique request ID, but maintain a reference to your original
request ID.
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6.0 Specific Content of the Methane ATM Request
6.1 Overview of Required Content
The EPA is asking for a complete overview of your solution. The ATM Request must
explain how your technology works and demonstrate that the method you have developed
works under the range of physical and environmental conditions that you expect to encounter
in a real-world deployment.
Your ATM Request will consist of three primary pieces: 1. The Description of Technology
Document, a document that explains how your methane detection solution works in detail,
from first principles all the way through the determination of leak rate. 2. Supplementary
information that provides proof of performance and any documentation that provides
additional insight into your solution and develops confidence in your method. 3. a formal
Methane Alternative Test Method (ATM), which will document the method protocol for when
the solution is deployed for measurement. The ATM is what will ultimately be approved for
access by end users.
Only the formal alternative test method has a prescriptive format. For the description of
technology and the supplementary materials the EPA is allowing flexibility for individual
submitters to determine the best formats and materials to fully and clearly explain your
solution. However, the more organized and clearly written your ATM Request materials are, the
more quickly the review team will be able to work through your ATM Request. A well organized
methane ATM Request is the best strategy for expediating your request through the review
process.
As you develop your methane ATM Request, please keep in mind that your request will
need to cover the operation and method of your solution in highly technical detail and will need
to include details that you would not normally distribute publicly. To protect your Intellectual
Property (IP), material in your ATM Request that you consider CBI can be submitted to the
review team through the EPA CBI system described below.
Confidential Business Information (CBI):
The EPA may make all the information submitted through the portal available to the public
without further notice to you. Do not use the portal to submit information you claim as
confidential business information (CBI). See section 4.4 of this guideline document for
instructions on how to submit CBI.
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6.2 Regulatory Language for Methane ATM Request
The rule specifies the ATM Requests requirements at 40 CFR §60.5398b(d) and the
regulatory text is provided here as a resource for applicants. For the full Language of
§60.5398b(d), please see Appendix D.
1. The submitter's name, mailing address, phone number and email address.
2. The desired applicability of the technology (i.e., site-specific, basin-specific, or
broadly applicable across the sector, super-emitter detection).
3. Description of the measurement technology, including the physical components, the
scientific theory, and the known limitations. At a minimum, this description must
contain the information specified in 40 CFR 60.5398b(d)(3)(iii)(A) through (D).
4. Description of how the measurement technology is converted to a methane mass
emission rate (i.e., kg/hr of methane) or equivalent. At a minimum this description
must contain the information in paragraphs 40 CFR 60.5398b(d)(3)(iv)(A) through
(F).
5. Description of how all data collected and generated by the measurement system are
handled and stored. At a minimum this description must contain the information in
paragraphs 40 CFR 60.5398b(d)(3)(v)(A) through (C).
6. Supporting information verifying that the technology meets the aggregate detection
threshold(s) defined in paragraphs 40 CFR 60.5398b(b) and/or (c) or in §60.5371b,
including supporting data to demonstrate the aggregate detection threshold of the
measurement technology as applied in the field and if applicable, how probability of
detection is determined. At a minimum, the information specified in 40 CFR
60.5398b(d)(vi)(A) through (D) must be provided.
7. If the technology will be used to monitor the collection of fugitive emissions
components, covers, and closed vent systems at a well site, centralized production
facility, or compressor station, you must submit supporting information verifying the
spatial resolution of technology, as defined in 40 CFR 60.5398b(d)(3)(vii)(A) through
(C). This supporting information must be in the form of a published reports (e.g.,
scientific papers) produced by either the submitting entity or an outside entity
evaluating the submitted measurement technology that has been independently
evaluated. The report must include sufficient supporting data to evaluate whether
the performance metrics of the alternative testing procedures in paragraph 40 CFR
60.5398b(d)(3)(vi)(C) are adequate and the data was collected consistent with those
alternative testing procedures.
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Definitions:
The average aggregate detection threshold is the average of all site-level detection
thresholds from a single deployment (e.g., a singular flight that surveys multiple well sites,
centralized production facility, and/or compressor stations) of a technology, unless this
technology is to be applied to 40 CFR §60.5371b.
When the technology is applied to §60.5371b, then the aggregate detection threshold is
the average of all site-level detection thresholds from a single deployment in the same
basin and field.
Definitions:
Facility-level spatial resolution means a technology with the ability to identify emissions
within the boundary of a well site, centralized production facility, or compressor station.
Area-level spatial resolution means a technology with the ability to identify emissions
within a radius of 2 meters of the emission source.
Component-level spatial resolution means a technology with the ability to identify
emissions within a radius of 0.5 meter of the emission source.
6.3 Header Information on the Methane ATM Request
Every methane ATM Request is initiated by filling out the header information that will
provide the context for the request. This information will be used to provide a quick check on
your solution. A subset of this information will be pinned in the public-facing tables, linked on
the left side of the webpage ("Review ATM Requests"). End-users of this web portal will have
the ability to sort technology solutions based on this information and identify appropriate
solutions for their ATM Requests. The following required information will be entered by the
applicant:
• Company Name: Enter the name of the company represented by this submission
(Required Field).
• Company Website: Enter a valid company website URL for the company represented
by this submission (Required Field).
• Product Name: Enter the product name of the advanced detection technology you
are seeking approval for (Required Field).
• Desired Applicability: Click on the down arrow to unhide menu and select one of the
following dropdown list options: (Required Selection).
o Site-specific,
o Basin-specific,
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o Broadly applicable across the sector,
o Super-emitter detection, or
o Other.
• Leak Detection Resolution: Enter the leak detection resolution rate in kg/hr of the
advanced methane detection technology you are seeking approval for (Required
Field).
• Technology Type: Click on the down arrow to unhide menu and select one of the
following dropdown list options: (Required Selection).
o Satellite,
o Stationary in-situ sensor,
o Stationary remote sensor,
o Ground based mobile in-situ sensor,
o Ground based mobile remote sensor,
o Airborne mobile in-situ sensor (aircraft or drone),
o Airborne mobile remote sensor, or
o Other.
• Additional information: Enter any additional information, as needed. (Optional
Field).
Request ID:
The Request ID is an auto-generated identification number that will be generated and
associated with the request after submitter saves form - e.g., ALTTIECH-01.
A note on in-situ vs. remote technologies: in-situ technologies are measurements of the
ambient matrix at the point of interest, by contact with the medium. In the case of methane,
this would be any chemical monitoring that directly samples air into the measurement
instrument. In contrast remote sensors are systems that measure from a distance. LIDAR
systems, video monitoring, and other non-interactive monitoring systems would be classified as
a remote system.
6.4 The Submission Buckets
The regulatory requirements detailed in section 6.2 must be covered in the documents
submitted in the four submission buckets described in sections that follow.
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Documentation Checkboxes:
If information is provided in another file or is not relevant, check the box for "This
information is provided in another file or not relevant" for each documentation area.
If CBI is associated with the advanced methane technology request, check the box for "CBI
also submitted."
6.4.1 Bucket 1 - Executive summary
This is an optional submission that will assist in expediating your request through the review
process. Please provide a brief overview of the submitted methane solution and a list of your
submitted documents with an optional short (1-2 sentence) description of the file content. Any
documentation submitted to CBI should be included in the list of documents, and should
indicate that the document was submitted to the CBI system. Please do not include any CBI in
the submitted file names or the optional executive summary file descriptions.
An example formatting of the executive summary can be found in Appendix B. The EPA
provides flexibility on the formatting of this document, so feel empowered to adjust this
formatting to your needs.
6.4.2 Bucket 2 - Description of Technology
The Description of Technology document is a document that explains how your solution
works, from initial detection of concentrations all the way through the determination of leak
rate. This document should be written for a technical audience, and must address the following
elements (but it not limited to these subjects):
• A description of the candidate measurement technology system, including:
o A description of the scientific theory and appropriate references outlining the
underlying technology
o A description of the physical instrument;
o Type of measurement and desired application (airborne, in-situ, etc.);
o Potential limitations of the candidate measurement system, including
application limitations
• The request must also include information on how the system converts results to a mass
emission rate or equivalent and include the following:
o Workflow and description covering all steps and processes from measure
technology signal output to final, validated mass emission rate (kg/hr) or
equivalent
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o Description of how any meteorological data are used, including how they are
collected and/or sourced
o Identification of any model(s) used, including how inputs are determined or
derived
o All calculations used, including the defined variables for any calculations
o A-priori methods and datasets used
o Explanation of any algorithms/machine learning procedures used in the data
processing, if applicable
• The request must also include:
o A description of how data is collected, generated, maintained, and stored
o How these data streams are processed and manipulated, including how the
resultant data processing is documented;
o A description of which data streams are provided to the end-user of the data and
how that information is delivered or supplied
Additionally, The EPA requests a visual workflow of the solution for guiding the
reviewers through your technology. A plain language discussion of the workflow can be found
below in Section 6.4.3.
There is no required format for this document. The EPA is also not prescriptive about
how the information within this document is split between the publicly facing portal and the
CBI system. Please make an effort to make it easy for the review team to track where
information has been submitted; strategies could be using a redacted version of the document
on the publicly facing portal, using a map document submitted to the CBI portal that outlines
what is on the CBI system, or making a reference in the publicly facing document to specific
documents and document sections that can be found in the CBI system.
6.4.3 Bucket 2 - Workflow Guidance
The workflow is intended to be a complimentary tool in the Description of Technology
documentation that allows a reviewer to track how data moves through your solution, and
documents processing, There is no required format for the visual workflow included with the
Description of Technology document that is requested for submission bucket 2. The workflow
should include the following:
• How data move through the system;
• Data sources, transformation and calculation steps;
• Quality control steps; and
• Storage and retrieval processes.
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The EPA also requests that automated vs. manually operated steps are clearly indicated
within the workflow.
Unless it's critical for understanding the data flow, the internal software architecture of
your processing and storage systems is not necessary to include.
The EPA understands that these workflows may need to be broken into pieces
depending on your formatting of the Description of Technology document and the complexity
of your solution. If you take this approach, please make sure that it is easy to follow and
understand how your subsidiary workflows work together. The workflows may be included in
either the publicly facing portal or in the CBI system, and as their own document within the
Description of Technology submission bucket or as part of the Description of Technology
document.
6.4.4 Bucket 3 - Supporting Information
The supporting Information submission bucket is an opportunity for you to attach
context documents that will assist the review teams in understanding your solution. These
documents can be split between the publicly facing portal and the CBI portal. What follows is an
incomplete list of the types of documents that can be included in your request:
Peer reviewed publications - any published peer reviewed literature that details the
underlying tech, the methodology, and the application. This type of documentation is highly
encouraged for inclusion with your request.
Publicly facing documentation - anything that explains your technology that is publicly
available, including white papers, technical slide decks, and informational brochures.
Quality control and internal guidance documents for deploying and applying your
technology - Quality assurance/quality control (QA/QC) plans and guidance documents, siting
guidelines, best practice documents, and How-to documents that are used by your internal
teams are encouraged. Documents that are distributed to your clients for helping interpret and
understand your product are also encouraged.
Datasets and validation information - Data that demonstrates the operation,
applicability, and resilience of your solution in operation. Documentation or data that shows
the spatial resolution. Data showing proof of the aggregate detection threshold of the
technology.
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6.4.5 Bucket 4 - The Formal ATM
This piece is the most critical document included in your request: The formal ATM is
what is officially approved during the ATM process and is the document that will describe the
method protocol. This document is the only piece of the submission that has a requested
format and contents, and the formating details can be found in the EMC Guideline Document
45: https://www.epa.eov/sites/default/files/2020-08/documents/gd-045.pdf. The text of this
document is attached in Appendix C.
This document will explicitly be publicly facing and should not include any material
that would be considered confidential business information. These ATM documents should
also cover material that will constrain how the solution is applied, and should cover any
considerations for the protocol that may not be covered in the Description of Technology
document; ie, how sensor siting decisions are made. If there is a section that is not applicable to
your solution, you can use "[Reserved]" to indicate that the section will remain blank.
The ATMs are modeled on the EPA's Reference Methods and Other Test Methods (OTM)
formatting, and examples of this format can be found in the EPA EMC web site. These
documents are for use by clients, regulators, and the general public to understand how the
technologies are deployed.
6.5 Confidential Business Information
If you wish to assert a CBI claim for some of the information in your submittal, submit
the portion of the information claimed as CBI to the Office of Air Quality Planning and
Standards (OAQPS) CBI office. Clearly mark the information that you claim to be CBI.
Information not marked as CBI may be authorized for public release without prior notice.
Information marked as CBI will not be disclosed except in accordance with procedures set forth
in 40 CFR part 2. All CBI claims must be asserted at the time of submission. Anything submitted
using the portal cannot later be claimed CBI.
The preferred method to receive CBI is for it to be transmitted electronically using email
attachments, File Transfer Protocol, or other online file sharing services. Electronic submissions
must be transmitted directly to the OAQPS CBI Office at the email address oaqpscbi@epa.gov
and should include clear CBI markings and be flagged to the attention of the Leader,
Measurement Technology Group. If assistance is needed with submitting large electronic files
that exceed the file size limit for email attachments, and if you do not have your own file
sharing service, please email oaqpscbi@epa.gov to request a file transfer link. When
communicating with the CBI office via email, do not include any additional EPA personnel on
those communications.
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If you cannot transmit the file electronically, you may send CBI information through the
postal service to the following address: U.S. EPA, Attn: OAQPS Document Control Officer and
Measurement Technology Group Leader, Mail Drop: C404-02, 109 T.W. Alexander Drive, P.O.
Box 12055, RTP, North Carolina 27711. The mailed CBI material should be double wrapped and
clearly marked. Any CBI markings should not show through the outer envelope.
When submitting CBI, it is paramount that you include your request ID (MATM-xxx) in
the title as well as the body of your email or letter. Not including your request ID when
submitting CBI will likely cause delays in the review process.
6.6 Submitting Additional Requested Information
The review team may require additional documents as part of their review of your ATM
Request. To attach additional documents, select your submitted ATM Request and click the
"Update". This will open a separate window and allow you to add documents to the ATM
Request. No documents can be edited or deleted from a submitted request, including
documents added post-submission at the request of the review team. If the additional
requested information is considered CBI, submit accordingly and inform the reviewer through
the communication window.
When new documents are added to the portal or through CBI, the EPA encourages
applicants to add an updated executive summary to Bucket 1. The updated portion of the
executive summary should be highlighted and detail what documents have been added
(document name and extension), where they were submitted (publicly facing portal or CBI
system), and a 1 - 2 sentence summary of the document contents.
6.7 Withdrawing a Methane ATM Request
You can withdraw an ATM Request before the review process is completed; when this
happens, your material will be saved on the portal but will no longer be publicly facing. Your
ability to withdraw is no longer available after the final decision has been reached by the review
team. The withdrawal process is available to you through the web portal and is detailed in
Appendix A in this document.
6.8 Submissions with multiple emission detection thresholds (tentative placement)
Each alternative method write up should have its own ATM Request. If a submitter
would like their solution to be used in multiple different ways (utilizing different operational
modes to access multiple measurement thresholds, for example) that could require multiple
alternative methods. Therefore, multiple ATM Requests should be submitted. If the submitter is
submitting multiple similar ATM Requests, they should add language to the executive summary
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that details what the differences are between your related requests and where those
differences are recorded in the request. Materials may be duplicated between different
detection threshold requests for the same technologies.
6.9 Major Revision to Existing Methane ATM Requests
A method change is considered a major revision when either of the following are true:
• The update causes a relative change in quantified methane emissions of greater than or
equal to 5% when compared to the originally submitted product.
• The update changes the scientific theory behind the technology.
• A change in the applicability of the method (basin specific to generally applicable, or
from periodic screening to continuous screening)
Implementation of a major revision requires the applicant to revise an approved
Methane ATM Request; see Section 5.0 for an example of the revision process. To expediate
the review process of the major revision, the submitter should inform the EPA of any previously
submitted methane ATM Requests, include a description of the changes and why the changes
were made as a part of the executive summary, and identify all locations in the submitted
text/documents where new information is provided regarding the major revision.
Please note that a major revision will be approved as its own, separate method with its
own request ID, and this approval will be in addition to the originally approved solution, not in
substitution of it. A solution provider may work with the review team in case by base scenarios
to sunset previously approved solutions, see Section 7.5 for more detail.
6.10 Personal Identifiable Information
To stay in compliance with federal rules, any information that could be considered
Personal Identifiable Information (PII) should be purged from your documentation. Pll is
defined as:
Any representation of information that permits the identity of an individual to whom
the information applies to be reasonably inferred by either direct or indirect means. Further, Pll
is defined as information: (i) that directly identifies an individual (e.g., name, address, social
security number or other identifying number or code, telephone number, email address, etc.)
or (ii) by which an agency intends to identify specific individuals in conjunction with other data
elements, i.e., indirect identification. (These data elements may include a combination of
gender, race, birth date, geographic indicator, and other descriptors). Additionally, information
permitting the physical or online contacting of a specific individual is the same as personally
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identifiable information. This information can be maintained in either paper, electronic or other
media.
For this Methane ATM Request process, this would be a combination of contact name,
address, phone number, and email address. This information will be collected as part of the
Methane ATM Request header information but will be redacted off the publicly facing Methane
ATM Request. Please ensure that this information is not included in your executive summary
or Description of Technology documentations. Any other documents that you submit will not
be reviewed for Pll and is understood to be voluntarily submitted.
6.11 Checklist for applicants
Table 4. Check list for Applicants
Check Box
Description
-
Does your Description of Technology document fully explain your solution following the
guidelines outlined in section 6.4?
-
If you have split some your materials between the publicly facing portal and the CBI system, is
it easy for a new reader to navigate which materials are found where?
-
Do the documents you have assembled for the Supporting Information provide adequate
additional information to validate your technologies performance?
-
Is your formal ATM laid out to the prescribed formatting?
-
Does your executive summary of your solution succinctly summarize your technology for a
general technical audience?
-
Does your executive summary document list all of the submitted documents with location and
a brief summary?
-
Double check your header information on the Methane ATM Request, paying particular
attention to the detection threshold, the applicability, and the technology type
-
Double check that the Executive summary and Description of Technology documentation do
not include Pll
6.12 Frequently asked questions
These are questions that have been frequently asked to the Measurement Technology
Group.
What is a minor change and what does the EPA require when a minor change is made?
A minor change could be considered quality of life improvements to the software, hardware
changes that are considered "replacement in kind", or any software changes that would result
in quantified methane emissions of less than 5% when compared to the originally submitted
product.
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Are we looking for method data or validation data in these submissions? The EPA is
looking for any relevant data used as part of the validation process to define the data quality
indicators and data quality objectives (DQI and DQOs) in your method. Proof-of concept or
controlled-release data is important for us to see, but it is not sufficient. The reviewers also
need to see data that shows how your solution performs in the field where you intend to
deploy, under the range of physical and environmental conditions you expect to deploy. In
order to be useful to the review team, the data needs to be collected following the exact ATM
request protocol you are submitting for approval.
How should a solution provider deal with allowed process emissions or emissions
from regulated sources (e.g., stationary engine) The submitted alternative method should
detail how known allowed sources are identified and managed within the detection framework,
including procedures for determining/identifying sources of allowed emissions and procedures
for verifying the emission source.
For the formal ATM, does quantification need to be included? The formal ATM Request
should define the detection limit at the leak point and what methods are used to confirm that
value. Additional quantification details should be included in the supporting documentation
and/or method description submitted to the review team, but unless critical to the method
itself does not need to be included in the formatted method. Alternative test methods for
continuous monitoring systems must include information on determination of methane mass
emissions rates (or equivalent).
For continuous monitoring, does the baseline period need to be a continuous 30-day
period? Baseline development is detailed in §60.5398b(c)(5) 40 CFR part 60 subpart OOOOb,
which requires that baseline development be performed during a 30-day operating period after
conducting inspections and repairing any leaks to the fugitive components, covers, and closed
vent systems; ensuring all control devices are in working order; and ensuring all other methane
emission sources are operating consistent with any applicable regulations. The intent is that the
30-day period be continuous, depending on the operation of the site, and you must remove any
maintenance activities which have occurred from the baseline calculated using the 30-day
operating period.
Does OGI Monitoring with drone platforms need to be approved through the ATM
process? Not necessarily. In the 2016 response to comments for NSPS OOOOa, the EPA clarified
the following: We have also revised the requirements for walking path to observation path. This
should alleviate the need for an alternative monitoring plan or alternative means of emission
limitation for the use of drone based OGI instruments as long as the drone based OGI system
still meets all the requirements of the rule (See 40 CFR 60.5397b). Other drone based
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technologies that for example produce results such as a path averaged concentration must
apply for a methane alternative test method.
However, to meet the requirements outlined for OGI systems in NSPS OOOOa or
0000b, it is also important that the person who understands and is trained in OGI is out in the
field with the drone to ensure that the inspection is done in a meaningful way, including dealing
with adverse conditions and viewing from appropriate angles. The video footage cannot be
taken by someone and then sent to a thermographer after the fact. If all of the requirements
for OGI systems in NSPS OOOOa or 0000b cannot be met for the drone-based OGI camera,
then an alternative test approval would be necessary.
Does OGI Monitoring with helicopter platforms need to be approved through the ATM
process? The EPA is concerned whether deployment of OGI in this manner can meet the OGI
survey requirements in 60.5397b, as it is unclear if deployment in such a manner would allow
an operator to have adequate backgrounds in order to achieve necessary delta Ts, how an
operator would deal with interferences (or be aware of them), how an operator would change
angles to get better delta Ts and avoid interferences when appropriate, and whether the
helicopter blades may affect the detection capability of the OGI camera by creating wind
dispersion effects which could reduce the concentration of the emissions below the detection
capabilities of the OGI camera. The EPA believes that this type of OGI application is best
handled under the alternative technology provisions in NSPS 0000b.
Who can submit an application for alternative technologies for NSPS 0000b? Is it just
the technology providers or can operators also submit applications? Owner or operators who
have developed proprietary technology or adapted existing technology specific to their needs,
can submit applications.
Once a measurement technology is approved, will oil and gas companies be able to
use the technology automatically? The rule provides details on how an owner or operator
should incorporate the use of an approved alternative technology into their monitoring plans
prior to conducting monitoring using an approved alternative test method. For NSPS 0000b,
there is not an additional approval process for the monitoring plan. Remember that in some
cases technologies will only be approved for specific basins or sites.
How will data be reported, and does US EPA already have a template for data
reported from Advanced Methane Technologies? Owners and operators of NSPS 0000b and
EG 0000c sources that use advanced methane detection technologies are required to report
certain information in their annual reports. Annual reports will be required to be submitted
through the compliance and emissions data reporting interface, or CEDRI, using a spreadsheet
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template that will be posted on the CEDRI website. A draft version of the reporting form was
included in the docket for the proposed rule, and the final version should be available soon.
Will reporting requirements vary by advanced technology type? There are standard
reporting requirements for technologies doing periodic screening that vary from the standard
reporting requirements for technologies doing continuous monitoring. Depending on the
technology and application, alt approval methods may specify reporting requirements specific
to the alternative that must be included in the annual report in addition to the standard
reporting requirements.
What are the standard data reporting requirements? The requirements are outlined in
40 CFR 60.5424b and are captured in the CEDRI reporting template, so we recommend looking
at those for a full list of the requirements. But in general, for periodic screenings, owners and
operators would be required to report information on periodic screening events, such as dates,
results, method and technology used, information related to follow-up inspections after a
confirmed detection, and information on annual OGI inspections, if applicable. For continuous
monitoring, owners and operators would be required to report information on exceedances of
action levels, or highest rolling averages if there were no exceedances, actions taken in
response to an exceedance, and monitor downtime.
If an owner/operator chooses to replace a periodic screening event with an OGI
survey, would that survey count as the required annual OGI survey, if an annual OGI survey is
required? Per Section 5398b(b)(4)(iii) If you replace a periodic screening event with an OGI
survey and you are using screening threshold which requires annual OGI, the replacement OGI
survey will fulfill the annual OGI requirement in the matrix. Additionally, if you are required to
conduct an OGI survey of the full site in response to a confirmed detection from a periodic
screening event, that will also fulfill the annual OGI requirement in the matrix. The next annual
OGI survey is required to be conducted no later than 12 calendar months after the date of the
replacement OGI survey or the follow-up OGI survey.
How would the emissions monitoring plan, recordkeeping, and reporting
requirements be different for fugitive emissions monitoring using alternative test methods at
sites subject to NSPS OOOOa versus NSPS OOOOb? NSPS 0000a directly references the
requirements in NSPS OOOOb, so the alternative technology requirements, including
recordkeeping and reporting, are the same for both subparts. We are in the process of updating
the NSPS OOOOa annual report form to include the reporting tabs for the alternative
technology reporting requirements.
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Can you clarify the requirements for using periodic screening alternative test methods
to determine if a pilot light is present for flares and enclosed combustion devices? The
alternative technology standards apply to fugitive components, covers, and closed vent
systems. As such, there is no requirement to look at equipment that is not covered by the
fugitive component, cover, or closed vent system requirements during a periodic screening
event. However, if during a periodic screening event or in response to a periodic screening
event, an owner or operator discovers an unlit flare or enclosed combustion device, the control
device must be brought back into compliance with the requirement to have a lit pilot light.
If a continuous monitoring system has a reading above an action level and the
company identifies the emission source, does EPA need to get a report? Information on
continuous monitoring events above an action level are part of the annual report. They don't
need to be reported separately.
Is the EPA considering requests for technology that can measure the duration of an
emissions leak? For the periodic screening approach, the focus is on detection and EPA will be
reviewing, evaluating, and approving that technology based on those metrics. For the
continuous approach, EPA will be reviewing, evaluating, and approving technology based on the
ability to quantify site level emissions.
Can an alternative measurement protocol be approved as "proven in use" based on
existing installations performing the required measurement? EPA finds it critical to evaluate
technology and the underlying protocol for their use as applied in the field.
What level of accuracy must the technology have to obtain approval from the EPA?
For the periodic screening and super emitter program, EPA is focused on the ability of a
technology/solution to detect an emission event. As such, we are more focused on metrics like
the probability of detection and proven detection threshold of the technology when it is
deployed. For the continuous monitoring paradigm, accuracy of the quantification is important
since action is triggered at a specific emission rate. EPA typically uses +/-10% for its accuracy
goals for continuous monitoring systems. Given the long-term application of these systems, the
accuracy metrics will be based on the long-term rolling average.
Are there any specific requirements for continuous monitors in terms of performance,
such as probability of detection for a given emission rate, false positive/negative fraction,
and localization precision/accuracy? If yes, do these requirements need to be verified by an
independent party? The rule details the performance of these continuous systems, including
up-time requirements and procedures for ensuring the health of these systems. Other metrics
are taken together as a whole in the alternative test method application, to determine whether
the system can meet the requirements in the rule. Additionally, EPA has provided flexibility for
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determining detection limits for continuous monitoring systems. It is critical for any verification
to be subject to independent evaluation.
Where does fixed OGI fit into the regulation? It has been discussed as fitting into the
periodic screening events but since fixed OGI will be continuous in operation, there is some
confusion about why it would fit into the periodic screening category. EPA has set the
continuous monitoring approach as a site-level emission standard in which the entire site
emission rate is determined, if an OGI systems can reliably quantify site-level emissions of
methane, it could be considered for that application. EPA believes that these systems could also
be used as a periodic screening under a more detection specific approach.
What would be the periodic screening frequency for fixed, continuous OGI? The
screening frequency would be based on the detection threshold of the continuous OGI system
and the matrix that the site is subject to. EPA does not limit the run time of a screening,
meaning more continuous systems could be operated for long periods of times.
Will there be a universal calculation all like sensors will be required to use for kg/hour
values, or will individual math (or algorithms) be allowed? No, EPA has not made any
prescriptive requirements for technology providers. EPA's approach to technology is to allow
providers to determine the best approach for their technology and its application.
§60.5398b(d)(3)(ii) is where the applicant defines the applicability of the technology.
Will specific requirements be required for "broadly applicable" vs. "site or basin-specific"?
"Broadly Applicable" is used to mean "can be applied in any US location", while the "site
specific" or "basin specific" solutions are technologies that have only been tested and validated
in specific regions or sites. In order to have a technology get approval as broadly applicable, the
requestor will need to prove that the technology can work at any location.
Can I just submit the whole application as Confidential Business Information? No.
Everything that is not CBI must be submitted through the website portal. This policy is in place
to encourage transparency for these technologies, and allow end users of the technologies
(clients, regulators, and the general public) to have information available about how the
approved technologies work and are deployed. If a submitter does not submit non-confidential
information through the website portal, we may ask for the application to be re-submitted.
Can more than one methane detection solution be combined in a single application?
No. Each Application should cover one complete methane detection solution. Each application
will be reviewed and approved separately. This helps us and end-users be able to differentiate
the supporting information and requirements for each individual alternative test method that is
approved.
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If our solution is capable of multiple thresholds by modifying the operation conditions,
do we need to submit multiple applications, one for each leak rate threshold? Yes, each leak
threshold must be submitted as a separate application because each will be approved as an
individual alternative test method that end users will then be able to reference. However, if
your technology has this capability, you may duplicate your material across the applications,
and there is a mechanism to link related applications. As part of your application materials, you
should describe how the thresholds are changed, discuss any operational changes that are
made to meet a new threshold, and provide validation data that supports your results. We also
recommend that you add a note to your executive summary noting that you have a single
solution capable of multiple thresh holds, list the related applications (by Request ID), and note
any changes in the documentation between the related applications.
There is potential overlap between different applications requirements in the rule,
such as calculations vs algorithms and machine learning procedures used. How do we know
what fits into each category? It's fine if there is overlap between different categories. The main
thing to remember is that everything that is relevant to the method and that explains how the
method works needs to be in the application.
How much testing and field data is required in the application? At a minimum each
technology should provide data for each basin and environment that they are planning to
operate in. Controlled release studies are encouraged but not required, however in their
absence the application should have some type of validation data showing performance.
Testing conditions should also encompass the expected operational conditions for
deployment.
Where should field testing take place - do we need to do testing directly with EPA or at an
EPA-certified test center? There is no EPA-certified test center for the methane alternative test
methods, and EPA will not be conducting or participating in testing of alternative technologies.
Applicants can perform field testing at available test sites or by working with owners and
operators of regulated sites.
Are there formatting requirements for the description of technology document and
the visual workflow? If so, where can these guidelines be found? There are no prescribed
formatting guidelines for the description of technology document or the visual workflow. We
are also not prescribing how material in these documents is divided between the publicly facing
portal and the CBI system. We made this decision to provide flexibility for individual companies
to determine the formatting that works the best for clearly documenting their technologies.
However, a clearly organized application that allows for a technical reviewer to quickly find
data, track information between the public portal and the CBI system, and understand the
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technology will expediate the review process. The review team also reserves the right to
request edits to these documents if necessary.
Can EPA provide a template or examples of applications for alternative test methods
for methane detection technology? The Formal Alterative Test Method must follow the EMMC
Methods Format. The formatting guidelines are linked on the submission portal landing page
and shown in the Alt Tech guidance document appendices, also linked from the submission
portal. Examples of test methods written with this level of required detail can be found in the
EPA Other Test Methods (OTMs) on the EMC website.
Once an application is approved, what types of changes would trigger a major
modification? There are three situations where a major modification of an approved method
should be submitted: 1. when the quantification changes by 5% or more; 2. when an update
changes the scientific theory behind the technology; and 3. when there is a change in the
applicability of the method (i.e., adding a basin to the applicability). Small changes that improve
quality of life (i.e., updating battery packs or minor changes to the processing algorithm that do
not change the quantification) do not trigger a modification.
Spatial coverage is only mentioned in the Periodic Screening Requirements
(§60.5398b(b). For a continuous monitoring application, is the Spatial Coverage section of the
application required? No. Because the actions taken in response to a periodic screening event
detection are specific to the spatial coverage of the technology, it is important for this to be
included in the application for technologies used for periodic screenings. Continuous
monitoring systems are considered to be facility-level spatial resolution, and the application
should describe how the full site is monitored by the system.
Can an alternative technology be type-approved or is acceptance only granted case-
by-case for each specific flow measurement application? Approvals for alternative test
methods are specific to the technology in the request - other technologies, even if they are the
same type of technology, must be approved in a separate application.
How is confidential business information handled by the EPA - is the public able to see
this data? The EPA review team is trained to handle confidential business information, with
controlled access through internal federal systems. No information submitted to the EPA CBI
system will be shared with the public, and it will only be accessible by trained reviewers who
are explicitly given access to the methane alternative technology applications as part of their
review responsibilities.
Where can I find a list of approved alternative technologies? A list of the approved
methane alternative technologies will be hosted on the EPA Air Emissions Measurement Center
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(EMC) website. A link to the list of approved technologies is provided on the landing page for
the application portal. Additionally, the full applications for approved technologies (excepting
any CBI content) will continue to be hosted on the web portal.
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7,0 The Methane ATM Review Approval Process
7.1 Timeframe for Methane ATM Review Approval
The Administrator will complete an initial review for completeness within 90 days of
receipt. If the entity submitting the request for an alternative test method does not meet the
qualifications specified in Section 6.4 of this guideline document or if the request does not
contain the information in Section 6.2 of this guideline document, the submitter will be notified
by EPA. The submitter may choose to revise the information and submit a new request for an
alternative test method.
Within 270 days of receipt of an alternative test method request that was determined to
be complete, the Administrator will determine whether the requested alternative test method
is adequate for indicating compliance with the requirements for monitoring fugitive emissions
components affected facilities in 40 CFR §60.5397b and continuous inspection and monitoring
of covers and closed vent systems in 40 CFR §60.5416b and/or for identifying super-emitter
events in 40 CFR §60.5371b. Note that the 90 days of initial review is included in the total 270
days period for EPA to make a determination.
7.2 Determination/Submittal of a new Methane ATM Review
The Administrator will issue either an approval or disapproval in writing to the
submitter. Approvals may be considered site-specific or more broadly applicable. Broadly
applicable methane ATM and approval letters will be posted at https://www.epa.gov/emc/oil~
and-gas-approved-alternative-test-methods-approvals.
If the Administrator fails to provide the submitter a decision on approval or disapproval
within 270 days, the alternative test method will be given conditional approval status and
posted on this same webpage. If the Administrator finds any deficiencies in the request and
disapproves the request in writing, the owner or operator may choose to revise the information
and submit a new request for an alternative test method.
7.3 Post-submission Methane ATM Review Process
This is how the review process will proceed, from submission to decision.
• Company submits a methane ATM request with a stated emission rate threshold:
o If a solution can do multiple emission rate thresholds, The EPA requests that
they are put in as separate methane ATM Requests that reference to the initial
request via request ID.
o The information submitted through the portal (the non-CBI portion of the
methane ATM request) will become viewable to the public within 7 days.
31
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Review Team reads the executive summary (if provided) and assigns the request to a
primary and secondary reviewer who are well-suited to handle the solution and method
outlined in the request.
The primary and secondary reviewers may set up a kick-off meeting through the
communication window.
o Kick-off meetings will be no longer than 60 minutes with the goal of providing
the review team with a broad overview of what they can expect to find in the
submitted request and where they can find it.
o The following may be discussed during these kick-off meetings:
¦ A broad description of the methane detection solutions,
¦ A broad description of the method,
¦ An overview of the data collected as evidence the method works,
¦ How that data was collected, and
¦ How to navigate the request.
The primary and secondary reviewers will conduct the completeness check.
o If important information is missing from the request, the review team will ask
the submitting entity to add the necessary data or documentation,
o If it is clear that the submitting entity will not be able to provide the additional
data or documentation in a timely manner, the review team may suggest that
the entity withdraw their request and resubmit once it is complete (withdrawn
requests will no longer be public),
o If, after 90 days, the additional data or documentation have not been provided
to the review team, and the submitting entity has chosen not to withdraw their
incomplete request, the review team may choose to deny the request (denied
request will be public),
o If the review team determines that the ATM request appears complete, the
review team will move on to the more detailed review of the request.
Methane ATM Request are reviewed.
o As the request is reviewed in more detail, the review team may continue to ask
for additional data and documentation, which can be submitted through the
request portal or as CBI.
o The primary and secondary reviewers conduct this review to fully understand
the solution, applicability, weaknesses, etc.
o The submitted documents and all data included with the ATM Request will be
reviewed.
o The communication window will be used as the primary method of
communication between the reviewers and the submitting entity,
o Additional meetings to discuss details of the request will be scheduled as needed
by the reviewers.
o Throughout this process, the primary and secondary reviewers may bring in
additional reviewers depending on the subject matter being discussed.
32
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o After the primary and secondary reviewers are satisfied with the information
they have received, the two reviewers will discuss their findings with the entire
review team.
7.4 Request Approval or Disapproval
If a methane detection solution is approved, the request status will be changed to
"Approved" and will be searchable under the "Approved ATM Requests" link on the left side of
the webpage. Information and documents submitted as a part of this request will remain public
facing. The approved ATM outlining the protocol will receive an official MATM-XXX
identification number. The solution provider will have the ability to make a major revision to
the approved request (see Sections 5.2.9 and 6.9 of this guideline document). The solution
provider will not have the ability to withdraw an approved request. Under some circumstances
an approved request may eventually be sunsetted by the solution provider, see Section 7.5 of
this guideline document.
If a methane ATM request is declined by the review team, the request status will be
changed to "Declined" and will be removed from the webpage. Information and documents
submitted as a part of this request will remain public facing.
If subsequent testing of an approved solution produces evidence that the approved
solution does not work, the Administrator has the authority revoke the approval, upon receipt
of such evidence, the EPA will review the evidence and discuss the evidence with the solution
provider prior to making a final determination. Any monitoring performed with the solution
prior to the revocation date will be considered valid. After the revocation date of a solution,
owners or operators of using that solution must find another solution or choose to use OGI and
must revise their monitoring plan as necessary.
7.5 Sunsetting Approved Technologies
In Section 6.9 of this guideline document this document discussed how major revisions
to a solution are handled. The approval of a methane ATM Request means that the approved
solution is always approved, and as major revisions are done to the tech those approvals of the
major revision exist as their own, separate approved method. Because of this, a solution
provider may end up with several near identical methods approved in tandem.
To manage this, the EPA will eventually allow a solution provider to sunset an approved
solution that has been replaced with a new, approved version. This sunsetting will be
undertaken on a case-by-case basis. If a solution provider is interested in sunsetting an
approved solution, please contact the review team to begin the process.
33
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7.6 Solution Provider or Solution Name Change
If the solution provider or solution name changes due to a buy out, you can update your
methane ATM Request to reflect the updated name and/or company. Reach out to the review
team and this will be handled on a case-by-case basis.
8.0 Super Emitter Program Applications
8.1 Overview of Super Emitter Application
Technology that is allowed to be used within the Super Emitter Program (SEP) must be
approved through the methane ATM program. The 3rd Party Notifiers that will leverage these
approved technologies and submit events to the SEP portal will be approved separately with a
different process that is not covered by this document. The methane detection solutions
submitted for the SEP will be evaluated using the same process outlined for all methane ATM
requests. Within the SEP ATM review, the "Desired Applicability" dropdown menu should be set
to "Super-emitter Detection." (See Section 6.3 of this document).
8.2 How the Documentation requirements differ from the Methane ATM Request
The only significant difference between a SEP technology and a typical methane ATM
technology is that the review team will not be evaluating any satellite sensors; instead, if you
have a satellite retrieval solution, your request should focus on the processing steps that occur
after you have the data in hand.
8.3 Review Process and notification Differences from the Methane ATM Request
The SEP solutions submitted as ATM requests s will be reviewed following the processes
outlined in Section 7.0 of this guideline document. Results obtained using an approved SEP
methane detection solutions can only be submitted to the SEP program notification portal by
an approved third-party notifier. Third-party notifiers will be required to use an approved SEP
methane detection solution, meaning the third-party notifier review process will not begin until
after SEP ATM requestss have already been approved.
8.4 Frequently Asked Questions
Where do you submit a request to be certified as a third-party notifier for the Super
Emitter Program? SEP third-party notifier requests will NOT be submitted to the ATMportal
covered in this guideline document. They will be submitted to a separate portal for review.
Additional information regarding third-party notifiers will be covered in a separate document.
34
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Who is the certification team? Who is the data management team? SEP ATM requests
and third-party notifier requests will be reviewed by the Measurement Technology Group
within OAQPS. The SEP notification portal, data management, and notification system will be
run by the Office of Enforcement and Compliance Assurance (OECA).
What are the uncertainty limits on the accuracy of the GPS location? 11 m target, 50 m
uncertainty bin (to provide flexibility).
Will the EPA be purchasing data as part of the Super Emitter Program? There is no plan
or mechanism for the EPA to directly purchase data.
What is the confidence requirement on the detection limits? The EPA leaves it up to
the third-party to perform data review, and for the 3rd party to determine if edge cases should
be submitted. The certification is to confirm that you have an adequate and documented data
review and evaluation process for an approved SEP ATM request.
What sources fall under the Super Emitter Program? New and existing sources covered
by NSPS OOOOb and EG 0000c are all covered by this program. This program does not cover
emissions from other sectors i.e., refinery processes and landfills.
Will 3rd party notifier's credentials be made public along with their unique ID? Unlike
the alternative program, we do not currently have a publicly facing system for the public to
review a third-party notifiers credentials. However, the information provided by the third-party
notifier, including who they are, what technology they are using will be available through the
Super Emitter Program.
35
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Appendix A - Methane ATM Request Portal Procedures
A-l
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A.l Home
A request for an alternative test method for advanced methane detection technology,
along with the required supporting information, must be submitted to the EPA through the
alternative methane detection technology portal at https://www.epa.gov/emc/oil-and-gas-
alternative-test-methods. The EPA may make all the information submitted through the portal
available to the public without further notice to you. Do not use the portal to submit
information you claim as CBI. If you wish to assert a CBI claim for some of the information in
your submittal, submit the portion of the information claimed as CBI to the OAQ.PS CBI office
(see Section 6.5 of this guideline document).
Figure 4. Portal - Home Page
A r-rkA United Statei
1 1 Environmental Protection ' >
Agency
Environmental Topki law* 4 Refutation! Report a Violation About EPA lofin
Q.
Oil and Natural Gas
Advanced Methane Technology
Alternative Test Method
Alternative Test Method (ATM) Request
Alternative Test Methods (ATMt) can be submitted to the Administrate* for approval under the alternative ten method provtuons, specific u> advanced methane detection in40CFR «).M98b(d) Thh provision
incorporates ipeclfk criteria for the review. evaluation, unit potential use of advanced methane detection technology lot use in periodic screening, continuous monitoring, and/or suporomitter detection and it is
designed to facilitate state ot the-jrt detection methods for (minion sources. Provider* that have developed new technology lor detection may sjbrnit documentation and testimonials for consideration. To
cr«fltc a new request, please visit the New ATM Beouitt page and fill out the form. Note that you are required to provide the appropriate contact information as a submitter
For more information. please refer to the Guideline Document, the final rule and EPA's Oil and Gas Regulatory sne.
Approved alternative lest methods that are broadly applicable wiU be posted on the EPA's fmmlon Measurement Center webiMye.
Section 5.0 of this guideline document provide step-by-step instructions on how to
utilize the website in order to gain access, create, revise, and submit ATM Requests for EPA
approval, along with other useful tools such as the ability to browse submitted and and
approved ATM requests, view frequently asked questions, and learn who to contact to obtain
additional assistance.
A.2 Login.gov Account
In order to submit a request for ATM approval to EPA, a login.gov account is required.
Visit www.login.gov for information on account creation as shown in Figure 5.
| Home
New ATM Reoi
Frequently Asked Questions
A-2
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Figure 5. Portal - Log-in.gov Account
I New ATM Request
Browse ATM Requests
Approved ATM Requests
Frequently Asked Questions
Contact us
oEPA
United States
Environmental Protection
Agency
Environmental Topics Laws & Refutations Report a Violation About EPA Login
Oil and Natural Gas
Advanced Methane Technology
Alternative Test Method
New ATM Request
In order to make an ATM request, please login using your login.gov account.
VisitlfigiiLgcyTt* more information about account creation and policies.
From www.login.gov. click Create an account with login.gov, as shown in Figure 6.
Figure 6. Portal - Log-in.gov Create Account
G 5 login.gov
An official website of the United States government Here's how vou know '
~ Dai
Language v Sign in with Ologin.gov
Qlogin.gov
What is Logiagov? Who uses Login.gov? (Create an account) Help center
The public's one account
for government.
Use one account and password for secure, private
access to participating government agencies.
One you have created the account, navigate back to the submission portal and click
login.gov. This will route you to the page illustrated below and will prompt you to log in with
your login.gov credentials as shown in Figure 7.
A-3
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Figure 7. Portal - EPA Gateway
mA United States _ . .....
Environmental Protection EPA GATEWAY
Select a Login Method
Login.gov
Q LOGIN.GOV
EPA Gateway is using a credential provider to allow
you to sign in to your account safely and securely.
If you do not have an existing Login.gov account, you
will be able to create one before you log in.
Figure 8. Portal - Login.gov Sign-In
C idp.int.identitysandbox.gov
a, ~
~
TEST SITE-Do not use real personal information (demo purposes only)-TEST SITE
IB A DEMO wetsteof the United State* government H
PLOGIN.GOV ®.
(g) Q 0
Advanced Methane Detection
Technology is using Login.gov to
allow you to sign in to your account
safely and securely.
Create an account
Sign in for existing users
~ Show password
4
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Once you have logged in, you will be prompted to enter a one-time code to access the
system, as illustrated in the image as shown in Figure 9. Note that the one-time code expires
after 10 minutes of receiving. If you don't access the system within 10 minutes, you will be
required to repeat the login procedures.
Figure 9. Portal - Login.gov One-time Code
G
idp.int.identitysandbox.gov/login/two_factor/sms
Q, ~
Olocin.gov
Enter your one-time code
We sent a text (SMS) with a one-time code to (***) ***-5668
This code will expire in 10 minutes.
One-time code
~ Remember this browser
Having trouble? Here's what you can do:
Choose another authentication method
I didn't receive my one-time code 3
Leam more about authentication options B
A.3 New ATM Request
Once you are logged into the system, click the New ATM Request link to create a new
submitta
5
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Figure 10. Portal - Mew ATM Request
(t% rn* United Stales
Environmental Protection
I—I #*A
Environmental Topics laws I. Refutations Report a Violation About f PA logout
Oil and Natural Gas
Advanced Methane Technology
Alternative Test Method
Company
Product
Leak Resolution
(kf/hr)
Technology Type
Applicability
Status
M>
SCtA. Inc.
SCASat
XOOlO
Satellite
Supc«-«niitter detection
Approved on Mar 01.2024
CfMttrffrtwn
AlTTECH-73
SCAAJnc
SkyView
Airborne mobile remote sensor
Broadly applicable across the sector
Submitted on Apr 04.2024
ALTTECK-81
SC&AJnc
Mathane ONG Aerial
10.0
Airborne mobile remote tensor
Site-specific
Withdrawn on Feb 02.2024
AlTTECH-69
The New ATM Request input form wiil be displayed as shown in Figure 11 through 13.
6
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Figure 11. Portal - Mew ATM Request Input Form (Point of Contact/Company/Product Info)
Home
| New ATM Request
Review ATM Requests
Approved ATM Requests
Frequently Asked Questions
Contact us
Ptease fill out the form below. You can save your progress at any time and return to it
later. When you are finished, you can submit it for review. Your application will become
publicly visible 7 days after you submit it (or sooner if it's approved.}
If you have questions, get help from the message portal. Get Help
Request ID
Not saved yet
Note About CBI
Do not submit information you
claim as confidential business
information (CBI) to EPA via this
website. All information
submitted through this website
will be made available to the
public without further notice to
Please visit Handling CBI to learn
more about CBI and the
procedures for submitting and
associating it with your request.
Q Avoid personal information
Contact information will be hidden from the public, but you are
encouraged to provide business (non-personal) email and phone.
1. Point of Contact
Full Name Email Phone
Jane Doe
jane@abcsolutions.com
2. Company and Product
Company Name
Company Website
ABC Solutions Inc.
http;//abcso!utions.com
Product Name
Desired Applicability
My Detection Product
Site-specific Z
Leak Detection Resolution
kg/hr
Technology Type
~ Continuous solution
Additional Information (optional)
7
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Figure 12. Portal - New ATM Request Input Form (Documentation)
3. Documentation Q CBI also submitted
Executive Summary (recommended) ©
~ This information is provided in anotherfile or not relevant
Add one or more files
Drag files here or choose from folder
Description of Technology ©
^ This information is provided in anotherfile or not relevant
Add one or more files
Drag files here or choose from folder
8
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Figure 13. Portal - New ATM Request Input Form (Supporting Documentation)
Supporting Documentation ©
] This information is provided in another file or not relevant
Add one or more files
Drag files here or choose from folder
Formal Alternative Test Method ©
] This information is provided in another file or not relevant
Add one or more files
Drag files here or choose from folder
Complete the New ATM Request input form as described in Section 5.2 of this guideline
document:
A.3.1 Input Form
Section 1. Point of Contact
• Full Name: Enter first name, followed by last name, e.g., Jane Doe (Required Field).
• Email: Enter a valid email address for point of contact, e.g., iane@abcsolutions.com
(Required Field).
• Phone: Enter phone number for point of contact, with area code, in the following
format: 555-555-5555 (Required Field).
Request ID:
The Request ID is an auto-generated identification number that will be generated and
associated with the request after submitter saves form - e.g., ALTTECH-01.
9
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Section 2. Company and Product
• Company Name: Enter the name of the company represented by this submission
(Required Field).
• Company Website: Enter a valid company website URL for the company represented
by this submission (Required Field).
• Product Name: Enter the product name of the advanced detection technology you
are seeking approval for (Required Field).
• Desired Applicability: Click on the down arrow to unhide menu and select one of the
following dropdown list options: (Required Selection).
o Site-specific,
o Basin-specific,
o Broadly applicable across the sector,
o Super-emitter detection or
o Other.
• Leak Detection Resolution: Enter the leak detection resolution rate in kg/hr. of the
advanced methane detection technology you are seeking approval for (Required
Field). Check the Continuous solution checkbox if your ATM Request is for a
continuous solution (the system will then bypass this otherwise required field).
• Technology Type: Click on the down arrow to unhide menu and select one of the
following dropdown list options: (Required Selection).
o Satellite,
o Stationary in-situ sensor,
o Stationary remote sensor,
o Ground based mobile in-situ sensor,
o Ground based mobile remote sensor,
o Airborne mobile in-situ sensor (aircraft or drone),
o Airborne mobile remote sensor, or
o Other.
• Additional information: Enter any additional information, as needed. (Optional
Field).
Save:
The ATM request can be saved at any time while populating fields and providing
information. The draft Request ID associated with the request will be generated and you
can return to the input form at a later time to complete the request.
10
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Section 3. Documentation
• Executive Summary: Provide a document with a summary of the advanced methane
detection solution you are seeking approval for. To learn more what EPA is
recommending for this item, hover over the "?" icon to lean more. To attach the
document, click Drag files here or choose from folder and select the file you wish to
attach. You can attach multiple files or delete files, as needed. (Recommended
Field). Note if the information requested in this section is provided in another file or
does not apply, click the checkbox for This information is provided in another file or
not relevant (the system will then bypass this otherwise required field).
• Description of Technology: Provide a document describing the advanced methane
detection solution you are seeking approval for. To learn more what EPA is requiring
for this item, hover over the "?" icon to lean more. To attach the document, click
Drag files here or choose from folder and select the file you wish to attach. You can
attach multiple files or delete files, as needed. (Required Field). Note if the
information requested in this section is provided in another file or does not apply,
click the checkbox for This information is provided in another file or not relevant
(the system will then bypass this otherwise required field).
• Supporting Information: Provide a document with supporting information for the
advanced methane detection solution you are seeking approval for. To learn more
what EPA is requiring for this item, hover over the "?" icon to lean more To attach
the document, click Drag files here or choose from folder and select the file you
wish to attach. You can attach multiple files or delete files, as needed. (Required
Field).
• Supporting Information for Measurement Technology: Provide a document with
supporting information for measurement technology for the advanced methane
detection solution you are seeking approval for. To learn more what EPA is requiring
for this item, hover over the "?" icon to lean more. To attach the document, click
Drag files here or choose from folder and select the file you wish to attach. You can
attach multiple files or delete files, as needed. (Required Field). Note if the
information requested in this section is provided in another file or does not apply,
click the checkbox for This information is provided in another file or not relevant
(the system will then bypass this otherwise required field).
• Formal Alternative Test Method: Provide a document with your formal ATM
Request following the format and contents, and the guidelines for the method can
be found at: https://www.epa.gov/sites/default/files/2020-08/documents/gd-
045.pdf. To attach the document, click Drag files here or choose from folder and
select the file you wish to attach. You can attach multiple files or delete files, as
needed. (Required Field). Note if the information requested in this section is
provided in another file or does not apply, click the checkbox for This information is
11
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provided in another file or not relevant (the system will then bypass this otherwise
required field).
Documentation Checkboxes:
If information is provided in another file or is not relevant, check the box for "This
information is provided in another file or not relevant" for each documentation area.
If CBI is associated with the advanced methane technology request, check the box for "CBI
also submitted."
Once all required fields are complete and appropriate supporting documents have been
uploaded, click the blue "Submit" button located at the bottom, right-hand corner of the page
to finalize and formally submit your request.
Once clicked, a confirmation pop-up window will open to confirm the submission. Users
can close the window by clicking on the "Close" button located on the bottom right-hand
corner or by clicking on the "X" located on the top, right-hand corner of the window.
A.3.2 Communication Window
At any time during a saved or submitted ATM request, you can communicate with EPA
by clicking the Get Help button on the New ATM Request input form. A separate pop-up
window will appear as displayed in Figure A-ll.
Figure 14. Portal - New ATM Request Communication Window
12
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The communication window is designed for the submitter to ask clarifying questions
related to the specific ATM Request that is being submitted to the EPA, The EPA will reply as
time allows to these messages. Please note messages sent in this portal are NOT a part of your
request and will remain private.
A.3.3 Update/Withdraw ATM Request
After your ATM Request has been saved, you can return to the request to edit it at any
time. Once you are logged in, from the home page, click the name of your existing request as
shown in Figure 15.
Figure 15. Portal - Mew ATM Request Update/Withdraw Table
|-na United States
Environmental Protection
VU #» Agency
Environmental Topics Laws <¦ Refutations Raport a Violation About EM Logout
Oil and Natural Gas
Advanced Methane Technology
Alternative Test Method
It looks like you have 7 existing requests. Click on the links below to review'edit
Review ATM Requests You can start a new request at any lime.
Company
Product
Leak Resolution
(kg/hr)
Technology Type
Applicability
Status
ID
SC&A, Int.
SCASat
100 JJ
Satellite
Super-emitter detection
Approved on Mar 01.2024
Create revision
ALTTECH-73
SC&A, Inc
SkyView
80.0
Airborne mobile remote sensor
Broadly applicable across the sector
Submitted on Apr 04,2024
ALTTECH-81
SC4A, inc
Methane ONG Aerial
10.0
Airborne mobile remote sensor
Site-specific
Withdrawn on Feb 02,2024
ALTTECH-69
A page will be displayed where you can edit your ATM Request, save, and submit. Once
the ATM Request has been submitted, you have the option to update or withdraw the request
before it is approved, as shown in Figure 16.
13
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Figure 16. Portal - New ATM Request Update/Withdraw ATM Request
Home
New ATM Request
Review ATM Requests
Approved ATM Requests
Frequently Asked Questions
Contact us
Status: Submitted on Apr 04, 2024 10:49AM
Point of Contact
Full Name
Tanya Parise
Request ID
ALTTECH-81
Email
tanyaparise@gmail.com
Phone
555-555-5555
Review Messages
Company and Product
Company Name
SC&A, Inc.
Product Name
SkyView
Leak Detection Resolution
80.0 kg/hr
Additional Information (optional)
Company Website
http://www.scainc.com
Desired Applicability
Broadly applicable across the sector
Technology Type
Airborne mobile remote sensor
Once you withdraw an ATM Request, you will no longer be able to modify it.
A.3.4 CBI Material
As stated, CBI cannot be included in your submission because it will be made publicly
available. If your submittal includes information claimed to be CBI, refer to Section 6.5 of this
guideline document.
A.4 Browse ATM Requests
To view existing ATM requests currently in the system, click the Browse ATM Requests
link from the main menu. A list of active requests will be displayed as shown in Figure 17.
14
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Figure 17, Portal - Browse ATM Requests List
Active Requests
Frequently Asked Quest
Contact us
Company
Product a
Leak Resolution
(kg/hr)
Technology Type
Applicability
Statu,
cm
all seeing
None
Other
Broadly applicable across the sector
Approved on Mar 20.2024
Cool City M«hane Reductions
Killer Queen Methane Solutions
10.0
Stationary in-situ sensor
Site-specific
Submitted on Apr U, 2024
Jones Sensors
Methane Detect 200*
2.0
Airborne mobile remote sensor
Super-emitter detection
Submitted on Feb 05,2024
Methane Products, inc.
MethaneGuard Plus
200.0
Airborne mobile remote sensor
Basin-specific
Approved on Jan 26.2024
The Phoenix Foundation
Paperclip
1.0
Stationary remote senior
Broadly applicable across the sector
Approved on Mar 19.2024
The Phooni* Foundation
Paperclip » Duct Tape
None
Stationary remote sensor
Site-specific
Submitted on Mar 19.2024
Atmospheric Solutions
Satellite Detect 4000
500.0
Ground based mobile in-srtu sensor
Super-emitter detection
Submitted on Jan 25.2024
SC&A, Inc.
SCASat
100.0
Satellite
Super-emitter detection
Approved on Mar 01.2024
SC&A, Inc.
SkyVkw
80.0
Airborne mobile remote sensor
Broadly applicable across the sector
Submitted on Apr 04.2024
Franklin Technology Ltd.
Stationary AtmosUte
1000.0
Stationary in-situ sensor
Basin-specific
Submitted on Jan 25,2024
Click any data item the table of active requests for more information. A new page
displaying information related to the request will be displayed with personal information
redacted, as shown in in Figure A-15.
Figure 18. Portal - Browse ATM Requests Details
Home
New ATM Request
| Browse ATM Requests
Approved ATM Requests
Frequently Asked Questions
Contact us
Status: Approved by EPA staff on Jan 26,2024
Point of Contact (redacted for public)
Full Name Email
Request ID
ALTTECH-63
Company and Product
Company Name
Methane Products, Inc.
Product Name
MethaneGuard Plus
Leak Detection Resolution
200.0 kg/hr
Additional Information (optional)
Company Website
https://methprod.com/about
Desired Applicability
| Basin-specific
Technology Type
Airborne mobile remote sensor
15
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Individual documents associated with the request can be viewed by clicking the
document name, or you can download all documents associated with the request by clicking
the download all link, as shown in Figure 19.
Figure 19. Portal - Browse ATM Requests Details View Documentation
Documentation
CBI alsc^ubmittecl
JjUMMffRBIfflm^ifc^cominended) ©
y«ecutive-sumrnarv.jpf>/
Description of Technology ©
description.png
Supporting Documentation ©
supporting-!.png
Formal Alternative Test Method ©
methoci-2,svg
method-3.jpg
A.5 Approved ATM Requests
To view ATM Requests for advanced methane detection technology that have been
approved by EPA, click the Approved ATM Requests link from the main menu, A list of
approved requests will be displayed as shown in Figure 20.
16
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Home
New ATM Request
Browse ATM Requests
| Approved ATM Requests
Frequently Asked Questions
Contact us
Figure 20. Portal - Approved ATM Requests
Approved Requests
Search companies, products etc.
Company
Product a
Leak Resolution
(kg/hr)
Technology Type
/
CH4
all seeing
None
Other
Broadly app
Methane Products, Inc.
MethaneGuard Plus
200.0
Airborne mobile remote sensor
Basin-specil
The Phoenix Foundation
Paperclip
1.0
Stationary remote sensor
Broadly app
SC&A, Inc.
SCASat
100.0
Satellite
Super-emitt
SC&A, Inc.
X-OGI
5.0
Other
Basin-specil
Use the horizontal scroll bar to view information related to approved requests as shown
in Figure 21.
Figure 21. Portal - Approved ATM Requests Details
Home Approved Requests
New ATM Request
Browse ATM Requests
| Approved ATM Requests
Frequently Asked Questions
Contact us
Search companies, products etc.
Technology Type
Applicability
Status
ID
Other
Broadly applicable across the sector
Approved on Mar 20,2024
ALTTECH-77
Airborne mobile remote sensor
Basin-specific
Approved on Jan 26,2024
ALTTECH-63
Stationary remote sensor
Broadly applicable across the sector
Approved on Mar 19,2024
ALTTECH-74
Satellite
Super-emitter detection
Approved on Mar 01,2024
ALTTECH-73
Other
Basin-specific
Approved on Mar 21,2024
ALTTECH-78
A.6 Frequently Asked Questions
To review frequently asked questions relating to the ATM request procedure for seeking
approval for advanced methane detection technology, click the Frequently Asked Questions
link from the main menu. A new page will be displayed as shown in Figure 22.
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Figure 22. Portal - Frequently Asked Questions List
| Frequently Asked Questions
Oil and Natural Gas
Advanced Methane Technology
Alternative Test Method
Is the information submitted to this site publicly available?
How should I submit CBI?
Will there be an opportunity to ask questions during the submission process?
Are there guidelines (or the testing a company needs to do to confirm their technology?
Are we required to submit an EPA formatted Quality Assurance Project Plan (QAPP) as part of our submission?
Can additional data be added to the application once it is submitted?
Is there any material that should NOT be included In an application?
To view answers to Frequently Asked Questions (FAQ) - a series of commonly asked
questions and topics expand its response by clicking the plus sign (+) icon. Minimize the
response by clicking the minus sign (-) icon. An example FAQ is shown in Figure 23.
Figure 23. Portal - Frequently Asked Questions Example Question
Home
New ATM Request
Browse ATM Requests
Approved ATM Requests
| Frequently Asked Questions
Oil and Natural Gas
Advanced Methane Technology
Alternative Test Method
re require the following information which encompasses the
What information is required for an Alternative Technology Method (ATM) request?
A comprehensive description of the submission requirements is provided in the plain la
information detailed in 40 CFR 60.5398b(d):
• A comprehensive description of 1) the technology. 2) conversion methodology, and 3) data handling procedures
• A formatted alternative technology method (hyperlink to the formatting guidelines)
• Any supporting documentation that verifies the technology meets defined aggregate emission thresholds. We highly encourage you to include any peer reviewed papers that describe and characterize
your technology.
When will the EPA contact me about their decision? +
Is the information submitted to this site publicly available? +
How should I submit CBI? +
Will there be an opportunity to ask questions during the submission process? +
Are there guidelines for the testing a company needs to do to confirm their technology? +
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A.7 Contact Us
To learn who to contact to obtain additional assistance for the advanced methane
detection technology ATM program, click the Contact Us link from the main menu. A new page
will be displayed as shown in Figure 24.
Figure 24. Portal - Contact Us
Oil and Natural Gas
Advanced Methane Technology
Alternative Test Method
Ned Shappley | USEPA. OAQPS | AQAD | Measurement Technology Croup
109 TW Alexander Drive (E143-02) | Research Triangle Park, NC 27711
Email: shapplcy.ned@iepa.gov | Phone 1919)541-7903 j Mobile 1919(665-9903
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Appendix B - Executive Form Letter
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Company Name Methane Alternative Test Method Request - Executive
Summary
Request Number - ALTTECH-###
Submission Date -
Company Name
Submission Point of contact Name
Product Name
Technology Type
Target Applicability
Target Emission Leak Rate Threshold
Request Numbers of any connected submitted
requests
Technical Summary of Technology:
Please provide a high-level summary on your solution, technique, and applicability.
Notes of the MATM Review Team:
Helpful notes contextualizing your application for the review team. For example, if you were putting in
multiple applications for a solution that can have multiple thresholds, this is where you would list those
related applications and add a brief description of how this application differs.
Updates to the Application:
YYYY-MM-DD - If you update your application during the review, please add a description of what
documents were added or changed, and why. Please date mark the additions and edits in this document.
Add any files to the summary of documents submitted, and mark them in some way - Adding a table with
"added on Date" or coloring the text, for example.
Summary of Documents Submitted:
A list of all documents submitted, separated by website submission bucket, with a 1-2 sentence summary
for each document.
Description Document Submission Category:
Document Name(s) with extension
Document Description
Company Name LDAR Measurement
Document.pdf
The Measurement technology summary document.
Company_Name_Visual_Workflow.pptx
A visual workflow for Company Name MATM
submission
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Supporting Documents:
Document Name(s) with extension
Document Description
ProductBrochure .pdf
Informational brochure used in sales pitches
Siteing_guidelines .pdf
Site set up guidelines that are used by the installation crew
T echnical_summary_presentation .pptx
Executive summary slides for outside shareholders
Alt Test Method:
Document Name(s) with extension
Document Description
Company Name Alt Test Method.pdf
Alt Tech Formatted Method
CBI Submitted Documents:
Document Name(s) with extension
Document Description
CM_standard_operating_procedures.docx
The SOP for the method that is turned over to end users
QA_Baseline_values.csv
Minimum quality assurance values
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Appendix C - Environmental Monitoring Management Council (EMMC) Methods
Format (GD 45)
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Environmental Monitoring Management
Council (EMMC) Methods Format
1.0 Scope and Application
Use a tabular format whenever possible for:
Analyte list(s)
Chemical Abstract Service (CAS) numbers
Matrices
Method Sensitivity (expressed as mass and as concentration with a specific sample
size)
Include a list of analytes (by common name) and their CAS registry numbers, the matrices
to which the method applies, a generic description of method sensitivity (expressed both as the
mass of analyte that can be quantified and as the concentration for a specific sample volume or
size), and the data quality objectives which the method is designed to meet. Much of this material
may be presented in a tabular format.
2.0 Summary of Method
Sample volume requirements
• Extraction
Digestion
Concentration, and other preparation steps employed
Analytical instrumentation and detector system(s), and
Techniques used for quantitative determinations
Summarize the method in a few paragraphs. The purpose of the summary is to provide a
succinct overview of the technique to aid the reviewer or data user in evaluating the method and
the data. List sample volume, extraction, digestion, concentration, other preparation steps
employed, the analytical instrumentation and detector system(s), and the techniques used for
quantitative determinations.
3.0 Definitions of Method
Include the definitions of all method-specific terms here. For extensive lists of definitions,
this section may simply refer to a glossary attached at the end of the method document.
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4.0 Interferences
This section should discuss any known interferences, especially those that are specific to
the performance-based method. If know interferences in the reference method are not interferences
in the performance-based method, this should be clearly stated.
5.0 Safety
Above and beyond good laboratory practices
Disclaimer statement (look at ASTM disclaimer)
Special precautions
Specific toxicity of target analytes or reagents
Not appropriate for general safety statements
This section should discuss only those safety issues specific to the method and beyond the
scope of routine laboratory practices. Target analytes or reagents that pose specific toxicity or
safety issues should be addressed in this section.
6.0 Equipment and Supplies
Use generic language wherever possible. However, for specific equipment such as GC
(gas chromatograph) columns, do not assume equivalency of equipment that was not specifically
evaluated, and clearly state what equipment and supplies were tested.
7.0 Reagents and Standards
Provide sufficient details on the concentration and preparation of reagents and standards to
allow the work to be duplicated, but avoid lengthy discussions of common procedures.
8.0 Sample Collection, Preservation and Storage
Provide information on sample collection, preservation, shipment, and storage
conditions
Holding times, if evaluated
If effects of holding time were specifically evaluated, provide reference to relevant data,
otherwise, do not establish specific holding times.
9.0 Quality Control
Describe specific quality control steps, including such procedures as method blanks,
laboratory control samples, QC check samples, instrument checks, etc., defining all terms in
Sectio3.0. Include frequencies for each such QC operation.
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10.0 Calibration and Standardization
Discuss initial calibration procedures here. Indicate frequency of such calibrations,
refer to performance specifications, and indicate corrective actions that must be taken when
performance specifications are not met. This Section may also include procedures for
calibration verification or continuing calibration, or these steps may be included in Section
11.0.
11.0 Procedure
Provide a general description of the sample processing and instrumental analysis steps.
Discuss those steps that are essential to the process, and avoid unnecessarily restrictive
instructions.
12.0 Data Analysis and Calculations
Describe qualitative and quantitative aspects of the method. List identification criteria
used. Provide equations used to derive final sample results from typical instrument data. Provide
discussion of estimating detection limits, if appropriate.
13.0 Method Performance
A precision/bias statement should be incorporated in the Section, including:
detection limits
source/limitations of data
Provide detailed description of method performance, including data on precision, bias,
detection limits (including the method by which they were determined and matrices to which
they apply), statistical procedures used to develop performance specification, etc. Where
performance is tested relative to the reference method, provide a side-by-side comparison of
performance versus reference method specifications.
14.0 Pollution Prevention
Describe aspects of this method that minimize or prevent pollution that may be
attributable to the reference method.
15.0 Waste Management
Cite how waste and samples are minimized and properly disposed.
16.0 References
Source documents
Publications
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17.0 Tables, Diagrams, Flowcharts and Validation Data
Additional information may be presented at the end of the method. Lengthy tables may
be included here and referred to elsewhere in the text by number. Diagrams should only include
new or unusual equipment or aspects of the method.
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Appendix D - 60.5398b(d) Rule Language for the MATM Program
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60.5398b(d) (b) Alternative Test Method for Methane Detection Technology. Any alternative
test method for methane detection technology used to meet the requirements specified in
paragraphs (b) or (c) of this section or § 60.5371b must be approved by the Administrator as
specified in this paragraph (d). Approval of an alternative test method for methane detection
technology will include consideration of the combination of the measurement technology and
the standard protocol for its operation. Any entity meeting the requirements in paragraph
(d)(2) of this section may submit a request for an alternative test method for methane
detection technology. At a minimum, the request must follow the requirements outlined in
paragraph (d)(3) of this section. Approved alternative test methods for methane detection
technology that are broadly applicable will be posted on the EPA's Emission Measurement
Center web page (https://www.epa.gov/emc/oil-and-gasalternative-test-methods). Any owner
or operator that meets the specific applicability for the alternative test method, as outlined in
the alternative test method for methane detection technology, may use the alternative test
method to comply with the requirements of paragraph (b) or (c) of this section, as applicable, in
lieu of the requirements for fugitive emissions components affected facilities in § 60.5397b and
covers and closed vent systems in § 60.5416b(a)(l)(ii) and (iii), (a)(2)(ii) through (iv), and
(a)(3)(iii) and (iv). Certified third-party notifiers may use the alternative test method to identify
super-emitter events in § 60.5371b(b)(l)(ii).
(1) A request for an alternative test method for methane detection technology, along with the
required supporting information, must be submitted to the EPA through the alternative
methane detection technology portal at https:// www.epa.gov/emc/oil-and-gasalternative-test-
methods. The EPA may make all the information submitted through the portal available to the
public without further notice to you. Do not use the portal to submit information you claim as
confidential business information (CBI). If you wish to assert a CBI claim for some of the
information in your submittal, submit the portion of the information claimed as CBI to the
OAQPS CBI office. Clearly mark the information that you claim to be CBI. Information not
marked as CBI may be authorized for public release without prior notice. Information marked as
CBI will not be disclosed except in accordance with procedures set forth in 40 CFR part 2. All CBI
claims must be asserted at the time of submission. Anything submitted using the portal cannot
later be claimed CBI. The preferred method to receive CBI is for it to be transmitted
electronically using email attachments, File Transfer Protocol, or other online file sharing
services. Electronic submissions must be transmitted directly to the OAQPS CBI Office at the
email address oaqpscbi@epa.gov and should include clear CBI markings and be flagged to the
attention of the Leader, Measurement Technology Group. If assistance is needed with
submitting large electronic files that exceed the file size limit for email attachments, and if you
do not have your own file sharing service, please email oaqpscbi@epa.gov to request a file
transfer link. If you cannot transmit the file electronically, you may send CBI information
through the postal service to the following address: U.S. EPA, Attn: OAQPS Document Control
Officer and Measurement Technology Group Leader, Mail Drop: C404-02,109 T.W. Alexander
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Drive, P.O. Box 12055, RTP, North Carolina 27711. The mailed CBI material should be double
wrapped and clearly marked. Any CBI markings should not show through the outer envelope.
(1) The Administrator will complete an initial review for completeness within 90 days of receipt
and notify the submitter of the results of the review.
(ii) If the entity submitting the request does not meet the requirements in paragraph (d)(2) of
this section or the request does not contain the information in paragraph (d)(3) of this section,
the submitter will be notified. The submitter may choose to revise the information and submit a
new request for an alternative test method.
(iii) Within 270 days of receipt of an alternative test method request that was determined to be
complete, the Administrator will determine whether the requested alternative test method is
adequate for indicating compliance with the requirements for monitoring fugitive emissions
components affected facilities in § 60.5397b and continuous inspection and monitoring of
covers and closed vent systems in § 60.5416b and/or for identifying super-emitter events in §
60.5371b. The Administrator will issue either an approval or disapproval in writing to the
submitter. Approvals may be considered site-specific or more broadly applicable. Broadly
applicable alternative test methods and approval letters will be posted at https://
www.epa.gov/emc/oil-and-gasapproved-alternative-test-methodsapprovals. If the
Administrator fails to provide the submitter a decision on approval or disapproval within 270
days, the alternative test method will be given conditional approval status and posted on this
same web page. If the Administrator finds any deficiencies in the request and disapproves the
request in writing, the owner or operator may choose to revise the information and submit a
new request for an alternative test method.
(iv) If the Administrator finds reasonable grounds to dispute the results obtained by any
alternative test method for the purposes of demonstrating compliance with a relevant
standard, the Administrator may require you to demonstrate compliance according to §
60.5397b for fugitive emissions components affected facilities and § 60.5416b for covers and
closed vent systems.
(2) Any entity may submit an alternative test method for consideration, so long as you meet the
requirements in paragraphs (d)(2)(i) through (iv) of this section.
(i) An entity is limited to any individual or organization located in or that has representation in
the United States.
(ii) If an entity is not considered an owner or operator of an affected facility regulated under
this subpart or subpart OOOOa of this part or is not the owner or operator of a designated
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facility regulated under subpart 0000c of this part, the provisions of paragraphs (d)(2)(ii)(A)
and (B) of this section apply. (
A) The entity must directly represent the provider of the measurement system using advanced
methane detection technology.
(B) The measurement system must have been applied to methane measurements or monitoring
in the oiland gas sector either domestically or internationally.
(iii) The underlying technology or technologies must be readily available for use, meaning that
the measurement system using these technologies has either been:
(A) Sold, leased, or licensed, or offered for sale, lease, or license to the general public or;
(B) Developed by an owner or operator for internal use and/or use by external partners.
(iv) The entity must be able to provide and submit to the Administrator the information
required in paragraph (d)(3) of this section.
(3) The request must contain the information specified in paragraphs (d)(3)(i) through (vii) of
this section.
(i) The submitter's name, mailing address, phone number and email address.
(ii) The desired applicability of the technology (i.e., site-specific, basin specific, or broadly
applicable across the sector, super-emitter detection).
(iii) Description of the measurement technology, including the physical components, the
scientific theory, and the known limitations. At a minimum, this description must contain the
information in paragraphs (d)(3)(iii)(A) through (D) of this section.
(A) Description of scientific theory and appropriate references outlining the underlying g
technology (e.g., reference material, literature review).
(B) Description of the physical instrumentation.
(C) Type of measurement and application (e.g., remote or in-situ measurements, mobile,
airborne).
(D) Known limitation of the technology, including application limitations and weather
limitations.
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(iv) Description of how the measurement technology is converted to a methane mass emission
rate (i.e., kg/ hr of methane) or equivalent. At a minimum this description must contain the
information in paragraphs (d)(3)(iv)(A) through (F) of this section.
(A) Detailed workflow and description covering all steps and processes from measurement
technology signal output to final, validated mass emission rate or equivalent. These workflows
must cover the material in paragraph (d)(3)(v) of this section and put all technical components
into context. The workflow must also cover the technology from data collection to generation
of the final product and identify any raw data processing procedures; identification of whether
processing steps are manual or automated, and when and what quality assurance checks are
made to the data, including raw data, processed data, and output data.
(B) Description of how any meteorological data used are collected or sourced, including a
description how the data are used.
(C) Description of any model(s) (e.g., AERMOD) used, including how inputs are determined or
derived.
(D) All calculations used, including the defined variables for any of these calculations and a
description of their purposes.
(E) Descriptions of a-priori methods and datasets used, including source and version numbers
when applicable.
(F) Description of algorithms/machine learning procedures used in the data processing, if
applicable.
(v) Description of how all data collected and generated by the measurement system are
handled and stored. At a minimum this description must contain the information in paragraphs
(d)(3)(v)(A) through (C) of this section.
(A) How the data, including metadata, are collected, maintained, and stored.
(B) A description of how raw data streams are processed and manipulated, including how the
resultant data processing is documented and how version controlled is maintained.
(C) A description of what data streams are provided to the end-user of the data and how the
data are delivered to the end-user.
(vi) Supporting information verifying that the technology meets the aggregate detection
threshold(s) defined in paragraphs (b) and/or (c) of this section or in § 60.5371b, including
supporting data to demonstrate the aggregata^detection threshold of the measurement
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technology as applied in the field and if applicable, how probability of detection is determined.
For the purpose of this subpart the average aggregate detection threshold is the average of all
site-level detection thresholds from a single deployment (e.g., a singular flight that surveys
multiple well sites, centralized production facility, and/or compressor stations) of a technology,
unless this technology is to be applied to § 60.5371b. When the technology is applied to §
60.5371b, then the aggregate detection threshold is the average of all site-level detection
thresholds from a single deployment in the same basin and field. At a minimum, you provide
the information identified in paragraphs (d)(3)(vi)(A) through (D) of this section.
(A) Published reports (e.g., scientific papers) produced by either the submitting entity or an
outside entity evaluating the submitted measurement technology that has been independently
evaluated. The published reports must identify either a site-level or aggregate detection
threshold and be accompanied with sufficient supporting data to evaluate whether the
performance metrics of the alternative testing procedures in paragraph (d)(3)(vi)(C) of this
section are adequate and the data was collected consistent with those alternative testing
procedures. The supporting data may be included in the published report or may be submitted
separately.
(B) Standard operating procedures including safety considerations, measurement limitations,
personnel qualification/responsibilities, equipment and supplies, data and record management,
and quality assurance/quality control (i.e., initial and ongoing calibration procedures, data
quality indicators, and data quality objectives).
(C) Detailed description of the alternative testing procedure(s), preferably in the format
described in Guideline Document 45 on the Emission Measurement Center's website (available
at https://www.epa.gov/sites/ default/files/2020-08/documents/gd045.pdf). The detailed
description must address all key elements of the requested method(s) and must include
objectives to ensure the detection threshold(s) required in paragraph (d)(3)(vi) of this section
are maintained, including procedures for verifying the detection threshold and/or or probability
of detection is maintained under field conditions.
(D) Any documents provided to end users of the data generated by the measurement system,
including but not limited to client products, manuals, and frequently asked questions
documents.
(vii) If the technology will be used to monitor the collection of fugitive emissions components,
covers, and closed vent systems at a well site, centralized production facility, or compressor
station, you must submit supporting information verifying the spatial resolution of technology,
as defined in paragraphs (d)(3)(vii)(A) through (C) of this section. This supporting information
must be in the form of a published reports (e.g., scientific papers) produced by either the
submitting entity or an outside entity evaluating the submitted measurement technology that
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has been independently evaluated. The report must include sufficient supporting data to
evaluate whether the performance metrics of the alternative testing procedures in paragraph
(d)(3)(vi)(C) of this section are adequate and the data was collected consistent with those
alternative testing procedures.
(A) Facility-level spatial resolution means a technology with the ability to identify emissions
within the boundary of a well site, centralized production facility, or compressor station.
(B) Area-level spatial resolution means a technology with the ability to identify emissions within
a radius of 2 meters of the emission source.
(C) Component-level spatial resolution means a technology with the ability to identify emissions
within a radius of 0.5 meter of the emission source.
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