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Oil & Gas Producer - CARB Mandatory Rule (MRR) Verification

Business Objective

ALG was contracted to perform verification services to one of the largest crude oil producers in the state of California, encompassing seventeen (17) leases and over eighty (80) steam generating units. Due to the complexity of their operations, this crude oil producer was subject to multiple MRR regulations including Subpart C (General Stationary Fuel Combustion), Subpart W (Petroleum and Natural Gas Systems), and Subpart NN (Suppliers of Natural Gas and Natural Gas Liquids). Verification of an operation of this scope required innovative planning, prudent use of resources, and clear communication with the client in order to meet the third-party verification objectives.

Technical Approach

ALG’s expert verification team developed a systematic verification plan to ensure comprehensive review of project data as required to demonstrate conformance with the regulation. Expert and client-focused verifiers ensured early recognition of key issues and effective implementation of the verification strategy with minimal disruption to the client’s daily operations. Site visits across the multiple leases were strategically performed to be able to capture the most complex and largest sources of emissions while effectively utilizing client resources during the onsite portion of the verification.


ALG successfully assisted the client by providing a full verification, within budget, and with a positive verification statement to the California Air Resource Board. The technical report provided at the completion of services included all data and analysis necessary to support the analysis. Successful execution of this verification resulted in client satisfaction and a multi-year verification contract.

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