Fugitive Emission Management Program Effectiveness Assessment; SNC-Lavalin

Project Title: Fugitive Emission Management Program Effectiveness Assessment; SNC-Lavalin
Project Lead: Dr. Piotr Staniaszek Email: [email protected]

Project Lead Organization / Company Information:
Organization: SNC-Lavalin Inc.

1. Statement of Capabilities of Project Team:

An overview of SNC-Lavalin is provided in Appendix C. Qualifications and experience pertinent to the project is presented in the sections below.
1.1 Capabilities of Project Team
Overall, SNC-Lavalin employs over 25 technicians/engineers specialized in fugitive emissions, LDAR, Leak Detection, and Quantification. Many of our personnel have more than 20 years of pertinent experience and took part in various studies and regulation consultations for the provincial and federal governments. The team also possesses more than 20 years of field and monitoring analysis experience and hence have an exceptional understanding of the factors that influence an LDAR’s program efficiency. The proposed project team includes individuals with extensive technical expertise related to:
• Leak Detection and Quantification Data
• Database creation
• Theoretical and practical experience with US EPA Method 21
• Theoretical and practical experience with optical gas imaging
• Theoretical and practical experience of comparative statistical analysis of field results and emissions measurement data
• Strong technical writing skills gained thought over 20 years of annual emissions declaration reporting
Short biographies of the proposed team outlining relevant experience are presented below. In addition to the team composed of SNC-Lavalin employees, Dr. Zaher Hashishi from the University of Alberta will act as Senior Advisor and complement the team by bringing forward a more scientific perspective in the execution of Phase 1 and 2. CVs are presented in Appendix D.
1.1.1 Project Manager
Piotr Staniaszek, Ph.D. Dr. Piotr Staniaszek, located in Calgary, has more than 23 years of experience in air quality consulting. He has extensive Project Management experience, including responsibility for clients’ regulatory compliance during the Front-End Engineering Design and approval stages of major engineering projects, as well as the creation of full-scale monitoring programs, including site assessment, data collection and interpretation. Dr. Staniaszek’s experience in environmental monitoring includes the creation of full-scale fugitive emissions management programs (including Husky Sunrise FEMP), non-routine flare management, greenhouse gas emissions inventories, along with ambient air quality monitoring, reporting and permitting. Dr. Staniaszek has completed several source testing projects for power plants, Oil & Gas, chemical industry, pulp mills and oil sands. He has participated in Fort Air Partnership/Strathcona Industrial Area (FAP/SIA) emission database development for FAP, North Capital Industrial Association (NCIA), Cumulative Environmental Management Association (CEMA) and Alberta Environment and Parks (AEP). He has written numerous air quality management plans including the design of an air quality monitoring stations network. Dr. Staniaszek participated in fugitive emissions measurements projects, using Flux monitoring, of VOC emissions of SUNCOR ponds by Fort McMurray. His role for the current project as project manager includes coordinating and overseeing all technical and financial aspects of the project and being the main liaison with the project steering committee. He will also act as senior reviewer of data analysis results and reports.
1.1.2 Project Team
Simon Piché, P. Eng. Ph.D. Dr. Piché has over 15 years experience in research and air quality engineering having contributed to several air emissions assessments for inventories and environment impact studies. Dr. Piché has also contributed in the development and realization of several technical surveys for government agencies related to air pollutant and GHG emissions and management for several industrial sectors including the oil & gas sector. He notably participated in the systematic review of technologies and methods capable of detecting the presence VOCs and methane from process component leaks, leading to the preparation of a leak detection protocol for ECCC. With its scientific background and strong analytical and writing skills, his role for the current project will consist in being the lead member responsible for the literature review, data analysis and field study preliminary design requirements of Phase 1.

Eric Dupuis, P. Eng. Mr. Dupuis’ experience over the last 10 years relates mainly to pollutant fugitive emission controls and infrared gas leak detection for the petroleum and petrochemical industries. Mr. Dupuis has implemented and managed numerous LDAR programs in Canada (AB, SA, BC, QC, and NL) as well as overseas for upstream, midstream, downstream, and marketing facilities. Notably, Mr. Dupuis served as a technical leader for LDAR program implementation for 4 different Husky sites in BC, AB, and SA. Mr. Dupuis has an industry-leading expertise and experience in infrared leak detection on refinery process equipment. His role for the current project will consist in being the lead member responsible for the field study design and data analysis for Phase 2.

François Thibodeau, P. Eng. Mr. Thibodeau has 21 years of experience in fugitive emissions program implementation for refineries, petrochemical plants and chemical producers. He also actively worked on assisting the European Council of Vinyl Manufacturers (ECVM) in establishing PVC industry specific emission correlation equations. He was constantly in touch with several monitoring technologies such as PIDs, FIDs, gas chromatographs, high volume samplers, infrared gas imaging, acoustical monitors and CEMS. He participated to the creation and development of the fugitive emissions software DÉFI and the ambient air remote monitoring system and software SAM. Mr. Thibodeau has also participated in the writing of various LDAR related regulations and papers. His role for the current project will consist mainly in an active participation in the literature review, data analysis and field study design.

Anya Gawor, MSc, E.I.T., EPt. Ms. Gawor has 7 years of experience working in the environmental sector, specializing in air quality, and research and development. Ms. Gawor is currently leading fugitive emissions work in Alberta, B.C., Saskatchewan, and Manitoba, including managing large-scale, annual downstream Oil & Gas fugitive emissions program at various plant and refinery facilities. Ms. Gawor has conducted field studies using acoustic and/or gas emission equipment to monitor and categorize background air quality data, Ms. Gawor has extensive experience in literature review; most recently she developed and published a review on heavy oil management technology and best practices on the control of odours, and evaluated wide range of emerging technologies for oxygen production and identified some that might be applicable to oil sands operation. Her role for the current project will consist in an active participating in the literature review, data analysis and be involved with the execution of the field study.

Zaher Hashisho, PhD. Dr. Hashisho is a Professor at the University of Alberta in the Environmental Engineering department. His research interests lie within air pollution control and air quality characterization. Pertinent research areas that Dr. Hashisho is currently working on include the characterization and development of emission factors for air pollutants emitted from oil sands tailings ponds. His role for the current project will consist in acting as a Senior Advisor so that the project team can benefit from his experience and provide input from a more scientific perspective to the work to be completed in Phases 1 and 2.

In addition to the team members listed above, additional resources, such as experienced field technicians, will be involved with the field work required in Phase 2.
1.2 Relevant Experience
SNC-Lavalin has been implementing LDAR programs for over 20 years in numerous facilities all around the world and has developed leading-edge expertise in the control of fugitive emissions to meet the needs of its clients.

SNC-Lavalin has a strong expertise and a vast experience in both leak detection with optical gas imaging (OGI) devices and with portable analyzers (US EPA Method 21). Over the last 20 years, SNC-Lavalin has developed over 80 LDAR databases and management programs for its various clients, for both petrochemincal and chemical facilities, including Husky (AB), Suncor (QC), North Atlantic (NL), Solvay (Europe and South America), to name a few, cumulating over 1 million components (process equipment) entries. These databases vary greatly in content, ranging from basic leak detection data to extensive detailed population including process compositions, equipment manufacturer, process temperature and pressure, etc. Advanced database information enables SNC-Lavalin to provide key insight to its clients on comparative review between various parameters (equipment types, equipment sizes, etc.) and annual emission estimates.

SNC-Lavalin has also prepared several fugitive emissions related studies for governments and organizations, including the Analysis of leak detection methods for CO2 pipelines for the Alberta government, LDAR technology and methods comparison and the development of a protocol for leak detection for Environment Canada, LDAR management recommendations in the steel industry for the Ontario Ministry of the Environment, an Air quality impact assessment on shale gas exploration and production in Quebec for the Quebec government and the development of specific correlation equations for fugitive emissions quantification for the European Council of Vinyl Manufacturers, among others. The technical reports generated from these studies are prepared comprehensively and concisely to communicate efficiently the information, independent of the level of technical complexity. All reports prepared by SNC-Lavalin pass thought a rigorous process of QA/QC and peer reviews to ensure the upmost quality and precision of the report.

Appendix E presents a partial list of relevant studies and projects performed by SNC-Lavalin highlighting the lead for each mandate (when a member of the proposed project team) and selected project fact sheets are presented in Appendix F which include more detailed information: duration, sector, cost, objectives and services rendered. More details on these projects can be provided on request.

As part of its business activities and project execution, SNC-Lavalin has accomplished and provided well over 90 presentations to multiple audiences, ranging from environmental professionals, government representatives to general public. SNC-Lavalin has had the opportunity to present in several congresses, seminars and industry associations (e.g. AWMA, Inframation (OGI), Réseau Environnement, etc.). A list of pertinent publications and presentations prepared by the proposed team members is presented in Appendix G.

2. Project management and control information:

The roles of each of the team members are defined below. The expected level of effort and hourly rates are presented in Appendix H. Unit rates for the for field work are also presented in Appendix H.
› Piotr Staniaszek, PhD.: Mr. Staniaszek will act as project manager. His responsibilities include coordinating and overseeing all technical and financial aspects of the project and being the main liaison with the project steering committee. He will also act as senior reviewer of data analysis results and reports.
› Simon Piché, P.Eng., Ph.D.: Mr. Piché’s role will consist in being the lead member responsible for the literature review, data analysis and field study preliminary design requirements of Phase 1
› Éric Dupuis, P. Eng.: Mr. Dupuis’ role will consist in being the lead member responsible for the field study design and data analysis for Phase 2.
› François Thibodeau, P. Eng.: François Thibodeau’s role will consist mainly in an active participation in the literature review, data analysis and field study design.
› Anya Gawor, MSc, E.I.T., EPt: Ms. Gawor’s role will consist in an active participating in the literature review, data analysis and be involved with the execution of the field study
› Zaher Hashisho, Ph.D.: Dr. Hashisho’s role will consist in acting as a Senior Advisor so that the project team can benefit from his experience and provide input from a more scientific perspective to the work to be completed in Phases 1 and 2.

In addition to the team members listed above, additional resources, such as experienced field technicians, will be involved with the field work required in Phase 2.

3. Project Plan (Scope & Deliverables):

The Petroleum Technology Alliance Canada (PTAC), on behalf of the Methane Research Planning Committee (MRPC), is seeking a qualified research organization or consulting firm with demonstrated experience related to fugitive emissions from the petroleum industry in order to assess the effectiveness of Fugitive Emission Management Programs (FEMP). A multi-stakeholder advisory panel for project oversight will be comprised of representatives from British Columbia Ministry of Natural Gas and Saskatchewan Ministry of Economy in addition to the representatives of the MRPC. This project will be funded by the Alberta Upstream Petroleum Research Fund (AUPRF). The following expertise is sought:
• Theoretical and practical experience with factors that influence the effectiveness of fugitive emissions management programs (leak detection and repair (LDAR); audio, visual, olfactory (AVO) inspections; optical gas imaging (OGI); high flow sampling; others);
• Theoretical and practical experience with leak quantification and associated practices and procedures, particularly high flow sampling to quantify volatile organic compound leaks;
• Theoretical and practical experience with data analysis in identifying gaps, dependencies, trends, etc.;
• Design of scientifically credible field studies.
The following sections detail the proposed approach, as well as qualifications and experience of SNC-Lavalin. These sections demonstrate the high level of expertise within the proposed team. SNC-Lavalin strives to deliver scientifically robust assessments of the highest quality within budget and on schedule.

The following section describes our approach to meet the requirements of the MRPC with regard to the management of fugitive emissions for the upstream oil and gas industry. This mandate will only focus on process fugitive emissions.

3.2.1 Phase 1: Literature Review, Data Analysis & Field Study Design
Before starting the review, a gap analysis template will be designed to investigate topics relevant to the management of fugitive emissions for the upstream oil & gas industry, including but not limited to:
› leak sources, contribution and occurrence rate (i.e. pressure, fluid service, fluctuations, design and aging);
› leak monitoring techniques (direct, AVO) and practices (i.e. sampling plan, inspection frequency, difficult-to-monitor sources);
› leak corrective actions (i.e. acceptable repair delays, repair approach, re-inspection, maintenance and prevention);
› LDAR performance issues (i.e. planning and frequency, QA/QC, leak definition, background contribution, experience, field performance issues, ambient conditions influencing measurement accuracy, age of measuring equipment, repair and reduction potentials);
› fugitive emissions quantification.
Each topic will be subjected to a series of items formulated into questions or requirements with a level of priority setting up the importance of obtaining a clear and concise answer, or if only generalities are sufficient. General examples of such inquiries are:
› What is the impact of pump seal age on leak occurrence?
› What is the leak detection limit of audible, visual, and olfactory inspections?
› What is the repair effectiveness and duration on valves, connectors, compressor seals?
The gap analysis template containing the items to be investigated, together with their level of priority and the rationale on their importance for optimal fugitive emissions management will be submitted to the MRPC for review and commenting. SNC-Lavalin proposes to review the gap analysis template with the MRPC via teleconference and gather opinions on that matter.

Following approval, several tens of documents dealing with at least one of the investigated items will be systematically reviewed. A list of six examples of relevant information sources is provided below. Appendix A provides a preliminary detailed list of additional information sources consisting of technical studies, handbooks, scientific papers, guidelines, survey reports, and policies. Qualitative and/or quantitative information will be extracted and will be added to the results section of the gap analysis template. The apparent trends will then be analyzed with respect, among others, to their completeness, level of certainty, and level of corroboration between sources and will be rated based on a pre-defined scale (numerical or descriptive (i.e. poor, average, good); to be determined during the gap analysis template review). An example of a gap analysis table prepared for another project is presented in Appendix B.

Preview – List of Information Sources
1. EnviroTech Engineering, Review and Update of Methods Used for Air Emissions Leak Detection and Quantification, for PTAC; Topics include: close range detection and remote sensing monitoring methods; point source quantification methods; area source leak detection;
2. GreenPath Energy, Alberta Energy Regulator (AER) Survey data, as of March 2017; Topics include: Database of fugitive emissions direct quantification associated to different equipment components in the Alberta oil & gas industry;
3. CAPP, Best Management Practice for Fugitive Emissions Management at Upstream Oil and Gas Facilities; Topics include: Best Management Practice document focusing on fugitive emission leaks, and considers emerging technologies that have potential to improve efficiency and effectiveness of leak detection. Provides practical guidance to operators to manage and reduce emissions;
4. URS Corporation; for California Climate Action Reserve; Operations and Maintenance of Natural Gas Transmission and Distribution Systems Emission Reductions Projects; Topics include: Potential approaches to GHG emissions quantifications, options for defining project activities, development standards and baselines. Highlights potential methods to reduce emissions (including fugitive) in transmission and distribution systems – information may be transferable to upstream oil and gas facilities;
5. GreenPath Energy, Historical Canadian Fugitive Emissions Management Program Assessment, for PTAC; Topics include: A review on current industry’s: LDAR practices, measurement methodologies, reporting mechanisms, leak and vent categorizations, and repair rates. Closely evaluates program performances and methodically analyzes data to determine primary source of leaks and vents from upstream operations;
6. Carbon Limits, Quantifying Cost-effectiveness of Systematic LDAR Programs Using Infrared Cameras; Topics include: Analysis of over 4,000 surveys of oil and gas facilities in the USA and Canada and calculating costs and benefits of having a LDAR program.

The rating of the investigated item combined with its priority level defined previously will help establish a list of priorities to tackle in order to optimize fugitive emissions management programs in the upstream field. These R&D priorities will be the basis of our recommendations on the design of a scientifically credible field study that will be presented into a report. It will present the objective(s) behind each investigation and the favored approach to obtain suitable results on the matter. It will provide, among others, the extent of the measurements, the type of sites, process, and equipment to be considered, general considerations (i.e. repeatability, timing, type of surveys, etc.), the general methodological approach, and the data processing approach. At this point, the Recommendation Report will not contain all the specifics associated with the realization of the field study but will rather be a proposal on the favored methodological approach. Once this field survey proposal is reviewed and accepted by the client, a formal field study plan will be prepared (Phase 2). SNC-Lavalin proposes to carry out a workshop in person for local members of the team and, via teleconference for members of the team in Quebec, with the steering committee to review the findings and recommendations of the Recommendation Report and gather opinions on gap prioritization for the field study.

3.2.2 Phase 2: Initial Field Study, Data Analysis & Preliminary Reporting
Once the field survey proposal is accepted and sites are selected (with support of the steering committee and the AER), SNC-Lavalin will prepare a draft field study plan that will include among others:
› investigation objectives;
› field study participants (SNC-Lavalin and others);
› selected sites operational description;
› description of sites and sources to be monitored (i.e. ID number, location coordinates and height, equipment type, age, fluid service, pressure, temperature, flow rate and other key process features);
› description of fugitive emissions monitoring and mitigations currently implemented at selected sites;
› fugitive emissions monitoring method including, but not limited to, equipment description, instrument specifications, expected manoeuvring (i.e. monitoring, duration, frequency, etc.), data acquisition, QA/QC features, etc.
› monitoring schedule and services required from the site;
› field survey data acquisition requirements and reporting.
Considering that Phase 2 will be carried out over several months and that elements from the initial field study plan may evolve, amended field study plans will be submitted to the stakeholders, whenever necessary, for approval.

SNC-Lavalin experienced technicians will then start carrying out the field surveys according to the plan and accepted timeline. The final report will contain all the elements from the field survey plan plus the results. Elements of discussions including the effectiveness of leak monitoring techniques, leak history, field work limitations, effectiveness of repairs, etc. will be covered, but most importantly the results will be put in contrast with the initial objectives and per extension to the findings of the gap analysis within the Recommendation report.

As suggested in the RFP, peer-review feedbacks, to be determined by PTAC, on the draft field survey report will be provided. Hence, SNC-Lavalin proposes to carry out a workshop in person and via teleconference with the steering committee to discuss this feedback and how it can be integrated in the final report and the final presentation to be delivered to the PTAC Air Research Forum. This second workshop would also be the occasion to discuss significant gaps and whether a subsequent field study (Phase 3) is required.

3.2.3 Phase 3: Subsequent Field Study, Analysis, Peer Review & Report
Following Phase 2 final workshop, the MRPC will decide if further investigations are required. It is expected that a similar approach as described in Phase 2 will be applied with the preparation of a field survey plan approved by the MRPC and other stakeholders, the execution of the field survey, preparation of the field survey report and a final presentation.

3.3 Potential problems and solutions
› Literature survey gaps: Although the exact rationale behind this mandate is to identify gaps in literature, depending on the topic, it can be beneficial to interview manufacturers or specialized service providers in order to have their input. Upon their agreement and for transparency, questions would be formulated in order to keep track of their opinions;
› Choice of field study equipment: SNC-Lavalin will not carry out field studies with every monitoring equipment models existing on the market (i.e. newer vs. older FLIR). Limitations and/or benefits of using the proposed equipment in field study plan will be acknowledged for transparency;
› Inappropriate field study conditions: Unless it is part of the investigation, optimal conditions to carry out specific items of the field study (i.e. weather-related, HSE-related, lighting, noise environment) will be clearly identified in the field survey plan and applied accordingly;
› Field study plan uncertainties: While preparing the field survey plan, uncertainties on whether the intended results will be obtained due to potential technical difficulties is a possibility. SNC-Lavalin will suggest, whenever possible, one or two alternatives that could be considered during the current field survey or, if impossible, during the next field survey;
› Data oversight: Although preparedness can prevent an oversight, it may happen from time to time. SNC-Lavalin with its experience in LDAR owns data management tools (ex. DÉFI software) used to visually label and characterize monitored equipment, create monitoring routes and manage the repair and maintenance process. Such tools will be used during the field surveys.

4. Budget & Payment Schedule:

Deliverables to be submitted to the MRPC according to our proposed approach are listed below. Exact scheduling will be discussed and set up during the kick-off meeting with the steering committee.
› gap analysis template / teleconference call review with the MRPC;
› draft Recommendations report with filled out gap analysis template / workshop with the steering committee / final report;
› draft field study plan / workshop with stakeholders / final field study plan and amendments if required;
› draft Field study report / workshop with the steering committee / final report / final presentation.
The level of effort, charge out rates and totals per phase and tasks are detailed in Appendix H. The total cost is set to $ 65,461 and $ 232 877 for Phase 1 & 2, respectively (applicable taxes not included) for a total of $ 298,338 (applicable taxes not included). Please note that the field study plan will be developed in accordance with the level of effort proposed as detailed in Appendix H for field technicians (1 000 h) and expenses related to the field work up to $ 58,000. Should more field work time be needed, these will be discussed with PTAC and if approved, the rates specified in Appendix H will be used.

The project time frame for Phases 1 and 2 will correspond to what is expected by PTAC: Phase 1 to end in May 2018 and Phase 2 to take place between March 2018 and March 2019.

Attached in Appendix I are SNC-Lavalin’s standard terms and conditions for the proposed work. Given SNC-Lavalin has completed work for PTAC before, we are confident that we can meet a mutually agreeable set of Terms and Conditions

Professional fees and disbursements are payable in the thirty (30) days following issuance of the invoices.

5. References:

Client references that may be contacted are provided below. Additional references may be provided upon request.
1. Ontario Ministry of the Environment and Climate Change
Mandate: Expert review and recommendations for future LDAR programs in Ontario; Classroom LDAR training
Contact: Larry Smet
Telephone: 416-327-7714
E-mail: [email protected]

2. Husky Energy
Mandate : LDAR program at Prince George Refinery
Contact : Darcy Blocka
Telephone : 250-960-2503
E-mail: [email protected]

3. North Atlantic Refining Limited
Mandate: LDAR program at Come-by-Chance Refinery
Contact : Julia Peddle
Telephone: 709-463-5161
E-mail: [email protected]

4. Environment Canada
Mandate: Protocol for the detection of fugitive equipment leaks of volatile organic compounds and methane
Contact: Roopa Ganapathy
Telephone: 819-956-7609
E-mail: [email protected]

Attachments: https://auprf.ptac.org/wp-content/uploads/formidable/625351-106-APPENDICES_FINAL.pdf

FEMP Rating

Capability of the team in terms of relevance to this project – sections #1, #3, #5 of the proposal apply (35%)

Ability to produce a scientifically credible project design, which will ultimately provide meaningful data and will assist with the informed-decision making/policy framework development process. (45%)

Quality of the proposal (20%)