A Summary of Bridger's Comments on Canada’s Proposed Framework for Reducing Oil and Gas Methane Emissions
Environment and Climate Change Canada (ECCC) recently proposed a regulatory framework for reducing oil and gas methane emissions to achieve the nation’s 2030 emissions reduction target.
Bridger’s experience studying O&G methane emissions at scale allows us to clearly project the impact that monitoring programs can have on emissions reductions. This places us in a unique position to provide recommendations on regulatory provisions that advance Canada’s goal of a “75% reduction in oil and gas methane by 2030 relative to 2012.”
In our comments on this proposed regulatory framework, we provide recommendations in three areas in support of operators being able to use advanced methane measurement technologies for streamlined emissions monitoring. The following is a summary of our comments:
1. Emissions Monitoring for Comprehensive Methane Emission Management at Oil & Gas Facilities
Canada’s Proposed Framework describes stringent numerical emission performance requirements for most emission sources.
Bridger supports the adoption of regulatory provisions that enable alternative leak detection technologies to be used for compliance verification of the low- or zero-emission performance requirements, and we recommend that operators should be able to use their leak detection and repair (LDAR) monitoring programs for this purpose.
Emissions Monitoring for Demonstrating Compliance with Numerical Performance Requirements
Advanced methane measurement technologies provide data that can demonstrate compliance with numerical performance standards. For example, if a source is required to be non-emitting, technologies with sufficient detection sensitivity could demonstrate compliance by no emissions being detected from that source. For equipment with process emissions, technologies with accurate quantification could differentiate between normal and abnormal emissions.
Previously Demonstrated Emissions Reductions Enabled by Comprehensive Monitoring
Through their Alternative Fugitive Emission Management Program (Alt-FEMP), the Alberta Energy Regulator (AER) has previously demonstrated the impact of using advanced methane measurement technologies for comprehensive emissions monitoring. This program has shown that most participating operators see a year over year reductions in their overall methane emissions.
Summary: Bridger recommends that ECCC enables operators to use their LDAR monitoring programs to both mitigate fugitive emissions and as a tool to comprehensively demonstrate compliance with other emissions performance requirements at oil and gas facilities.
2. A Centralized Approval Process for Advanced Methane Measurement Technologies to be Used for Regulatory LDAR Programs
Currently, advanced methane measurement technologies can only be used in alternative LDAR programs specific to individual operators. This presents a significant barrier to the application of advanced technology that can often detect emissions more effectively and efficiently than other methods.
Benefits of Advanced Technologies
The benefits of advanced technology include the potential for a greater volume of emissions to be detected, less opportunity for instrument user error, and a reduced burden on operators by increasing efficiency and safety.
Recommended Process to Approve Advanced Technologies for Regulatory LDAR Programs
Bridger recommends that the ECCC develop provisions for the centralized approval of advanced methane measurement technologies to be used for regulatory LDAR programs. A single application for technology approval would be submitted to regulators and once approved, any operator could simply specify the approved technology in their LDAR monitoring plans.
Recommended Elements in Regulatory Use Approval Applications
Bridger recommends that an application to seek regulatory approval for an advanced methane measurement technology contains the following elements:
- Technology description
- Standard operating procedures
- Quality assurance/control measures
- Allowable operating conditions
- Evidence that the required detection sensitivity is realized under allowable operating conditions
- Description of localization capabilities tied to empirical demonstration
- A description of data types and reporting procedures
Summary: Bridger recommends that the ECCC establishes a centralized approval process for advanced methane measurement technologies so that once approved, operators can simply specify their use in LDAR programs without individually applying. This application for approval should be open to public comment and include concrete evidence that the technology meets a set of performance requirements.
3. A Technology Agnostic Framework for Implementing Advanced Technologies in Regulatory LDAR Programs
For operators to be able to specify advanced methane measurement technologies within their LDAR plans without needing to develop individual alternative programs, it is necessary to establish a framework that ensures the effective application of these technologies.
Recommendations for Technology Sensitivity Requirements and Monitoring Frequencies
Bridger recommends a tiered sensitivity performance requirement based on monitoring frequency. At least the following options are recommended: 3 kg/hr detection sensitivity with a 90% probability of detection (PoD) for quarterly monitoring, or 4 kg/hr with a 90% PoD for monthly monitoring or for a fixed sensor system. Both options are designed to enable 75% emissions reduction. Due to the probabilistic nature of emissions detection, it’s imperative that regulations are built on sensitivity requirements based on probability of detection.
For a given site, the amount of infrastructure that requires screening to localize emissions to specific components should depend on the emission localization precision of the advanced measurement technology. For those that detect emissions at the equipment-scale, only the piece of equipment that is emitting should require onsite follow-up screening. For technologies with more broad-scale localization that cannot specify the emitting equipment, a full site screening may be necessary.
To deal with various environmental challenges for different technologies, Bridger recommends flexibility in the framework to account for adverse environmental conditions. For example, if snow cover reduces the sensitivity of an aerial scan with an advanced technology to the degree that performance requirements are not met, an operator could use an OGI scan in place of the advanced technology for a given infrastructure scan.
Recommended Repair Timeline for Emissions Detected with an Advanced Technology
Advanced technologies can often be deployed more efficiently than onsite screening methods, which means that there is potential for a large workload for follow-up on detected emissions to build up quickly. Therefore, Bridger recommends an extended repair deadline for emissions detected via advanced technology.
Summary: Bridger recommends at least two pathways to be established for compliance with LDAR monitoring program requirements: (1) quarterly monitoring using a technology providing 3 kg/hr 90% PoD detection sensitivity and (2) monthly monitoring or monitoring with fixed sensor systems using a technology providing 4 kg/hr 90% PoD detection sensitivity. Both pathways are anticipated to be consistent with Canada’s methane emissions reduction goals. Bridger also recommends follow-up requirements for detected emissions that involves additional screening of infrastructure according to the localization precision of the advanced technology. An extended repair deadline is recommended when using advanced technologies considering that additional data processing may be required, and efficient deployment can produce a large repair workload.
Read Bridger's full comment letter here.
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