Fugitive Emission Management Program (FEMP) Effectiveness Assessment

Project Title: Fugitive Emission Management Program (FEMP) Effectiveness Assessment
Project Lead: Mr. Michael D’Antoni Email: [email protected]

Project Lead Organization / Company Information:
Organization: GreenPath Energy Ltd.

1. Statement of Capabilities of Project Team:

The proposal has been prepared by a project consortium consisting of GreenPath Energy Ltd., a company registered in Canada and Carbon Limits AS, a company registered in Norway which together provide extensive experience and unique know-how on fugitive emission from oil and gas systems.
The consortium brings together the knowledge and experience of two organizations, each of them with a unique set of expertise relevant to the assignment. In summary, the consortium offers:
• Extensive experience in analyzing leak detection and quantification datasets in Europe, USA and Canada, including the preparation of ground-breaking reports on these issues.
• Wide experience in planning, organizing and performing measurement programs in Canada and internationally (more than 2000) including for research purpose
• Detailed knowledge of the (variability of the) upstream oil and gas sector in Canada; Alberta and British Columbia in particular.
• Internationally recognized experts which have been consulted by a number of organizations on the fugitive emissions question: ECCC, AER, BCOGC, IEA, Arctic Council, EPA, BLM, Ministry of Environment in Norway.
• Experience in working on fugitives emissions in 14 different countries globally.
• Important international network with stakeholders involved on methane emissions, not only in North America but in Europe and other relevant parts of the world.
• Successful track record working with all the relevant actors in this area: regulators, operators and NGOs.
• Databases of leak emissions, in Canada and globally. Tools built in a previous PTAC project allow for processing and standardization of new leak detection data.

An advantage of the consortium is the time differential between Oslo and Calgary. In the preparation of this proposal, as well as other past projects we have collaborated on, the time difference has allowed for more hours of work per day to be completed – the project can be handed off between Oslo and Calgary allowing for higher project uptime on the 24-hour clock.
The project leads, Joshua Anhalt, Michael D’Antoni, Stephanie Saunier and Hesam Darani each have over a decade of experience in the oil and gas sector focused on upstream oil and gas greenhouse gas emissions. CVs are provided in Annex 7 to the submission.
All field technicians have engineering degrees or are journeyman instrumenting technicians. Lead technicians each have several hundred inspections and have participated in research based projects such as the recent NRCan survey and the 2016 AER sponsored survey of small facilities in Alberta.
To ensure the credibility of the analysis, it is proposed to use one external peer reviewer. Different peer reviewers can be considered, but the peer reviewer should have a research/academic background and extensive experience on the technical topic. Peer reviewers will be selected in close cooperation with the client. The consortium has had initial discussions with Daniel Zavala-Araiza (Environmental Defense Fund) and David McCabe from the Clean Air Task Force; both are PhDs with published studies on methane emissions within the oil and gas sector.
Additional relevant projects in Annex 1. Résumés are included in Annex 7.

Understanding the effectiveness of leak detection and repair in Europe, a statistical analysis
Report: Available late 2017
Carbon Limits has gathered data from three different measurement services providers in Europe and assembled a unique dataset with more than 800 000 emissions data points from a number of facilities in Europe. This dataset has been used to answer a number of questions including:
• How effective are the repairs performed?
• How often do component fails and how does it impact survey frequency?
• What is the leak distributions per component type?
The public report will be published before the end of 2017 year.
Stephanie Saunier – Project manager, data analysis
Irina Isakova – Project contributor

Statistical Analysis of leak detection and repair in Canada
Report: http://carbonlimits.no/project/statistical-analysis-leak-detection-and-repair-canada/
The Oil, Gas and Alternative Energy Division (OGAED) at Environment and Climate Change Canada (ECCC) has asked Carbon Limits to analyse information from surveys of existing LDAR programs in order to design requirements that will reflect the best possible balance between cost-effectiveness and environmental outcomes. Carbon Limits analysed data from 4,378 LDAR surveys in North America. The analysis shed some light on a number of aspects of repeated LDAR, in particular on the occurrence of super emitters and on the possibility to perform repair without shutting down facilities.
Stephanie Saunier – Project manager, data analysis
Hesam Darani – Data analysis

Canadian Fugitive Emissions Management Program Assessment
Report: http://auprf.ptac.org/wp-content/uploads/2017/02/Report-FUGITIVE-EMISSIONS-16-ARPC-02.pdf
Funded by the Alberta Upstream Petroleum Research Fund, the project analyzed fugitive emissions management plans from 14 operators in Canada, and created a dataset of over 10,000 detected leaks in western Canada. The project resulted in the development of software tools to parse fugitive emission data from multiple sources, allowing for leak data from a wide array of providers to be easily added to the data set. The software system also parsed all leaks into 8 component types used in the National Inventory Report. The key lessons relevant to this project were the need for standardization of reporting and greater processes around repair reporting.
Michael D’Antoni – Literature Review, study design, data analysis

GreenPath 2016 Alberta Fugitive and Vented Emissions Inventory Study GreenPath/ Clearstone 2017 Alberta Fugitive and Vented Emissions Inventory stud
2016 Report: http://www.greenpathenergy.com/wp-content/uploads/2017/03/GreenPath-AER-Field-Survey-Results_March8_Final_JG.pdf
2017 Report: Expected in 2018
Alberta-wide oil and gas methane emission detection, quantification, major equipment and pneumatic inventories in support of methane emission reduction modeling and policy/regulatory frame work development. GreenPath planned, executed, and reported on results in the 2016 study, and carried out planning and data collection for the 2017 report. The key lesson learned from 2016 report was the need for a customized data collection application to improve data capture quality and ease of analysis.
Joshua Anhalt – Field lead, QA/QC
Michael D’Antoni – Study design, data analysis (2016), reporting (2016), QA/QC
Ryan Park – App development (2017)

2. Project management and control information:

A project control matrix is included in Annex 4.

Project Manager(s) Stephanie Saunier, Michael D’Antoni
Literature Review Irina Isakova, Michael D’Antoni, Anders Pederstad
Financial Management Ryan Park
Field Lead Joshua Anhalt
Data Analysis Michael D’Antoni, Irina Isakova, Hesam Darani, Anders Pederstad
Report Lead Author(s) Stephanie Saunier, Hesam Darani
Peer Reviewers (suggested) David McCabe and/or Daniel Zavala

Desktop $175 CDN / hour
Field work $3,300 CDN / crew /day
Peer Review No cost

3. Project Plan (Scope & Deliverables):

Project GANTT charts available in Annex 6.
1.1 Phase 1: Literature Review, Data Analysis & Field Study Design Recommendations Scope
Task 0: Kick-off meeting
It is proposed to organize a kick-off meeting one week after the signature of the contract. The objective of this meeting will be to:
• Discuss key priorities for the project
• Confirm project timeline
• Agree on contacts points and communication routes.

Minutes of the meeting will be prepared by the project team and circulated afterwards
Task A: Conduct a global literature review to gather information on programs to manage fugitive emissions
Objective: Gathering existing information on different approaches and research globally to manage fugitives emissions (defined here as unintended emissions or leaks).
Methodology: The project team will review existing publicly available data including, but not limited to:
• US EPA NSPS Technical Support Documents or other regulatory support documents;
• Data from Upstream Oil & Gas (UOG) operations (including for example the recent guidance from the Norwegian oil and gas association);
• Peer-reviewed scientific and technical studies (including European work e.g. the work from Imperial College); and
• Clearstone Inventory and Emission Factor reports.

Different types of approaches will be covered during the literature review including leak detection and repair (LDAR) campaigns and audio, visual, olfactory (AVO) inspections. When and if relevant, the project team will also contact through its network, experts (researchers, service providers, operators, and NGO representatives) in different parts of the world to ensure coverage of the literature review is maximized.
Based on the different sources of information gathered, the project team will document various factors including:
• Type of technology/equipment used for both detection and quantification
• Type and format of the report
• Operational practices and Repair practices
• Methodology/standards applied including frequency of inspections
• Limitations
• Applicability to the Canadian operations

The project team has extensive experience on fugitive management methods globally, and has worked on these questions in US (including in the regulatory process during the Obama administration), in Canada (directly with and for ECCC, AER and BCOGC), in Europe (focusing specifically on effectiveness of FEMPs in Europe), but also in many developing countries or countries in transition (including Ukraine, Azerbaijan, Kazakhstan, Russia, Iraq, …).

Task B: Preparation of a summary of the literature review
The objective of the task: This task aims at preparing a summary of the literature review findings which will include a gap analysis to document where more information is needed, or research is incomplete.
Methodology: The review will cover two broad topics:
1. Understanding leaks emissions patterns: To address leaks effectively, it is first important to understand the cause and the properties of this very specific source of emissions. Past research work has demonstrated that leaks can be found in all types of facilities, and present specific statistical distribution properties. It is also a very complex source of emissions (compared to other sources of emissions). The report will evaluate how well the existing work answers the following questions and what are the remaining gaps to answers these questions:

• What are the contributing factors to leak development?
• What is the relation between component type/equipment block and source/magnitude of leaks? (e.g. Do PRVs on a VRU leak more frequently?)
• What are the leak magnitude distributions depending on the type of component? Type of facilities? (speciate volumes, concentration or other relevant metrics)
• What are the leak occurrence rates?
• Evaluation of quantification methodologies and methodologies to define emission factors

2. Evaluating the effectiveness of different FEMP approaches: Globally, a number of different practices have been applied to manage fugitive emissions using different detection and quantification methodologies, but also different frequencies and different repair approaches. In this topic, the project team will evaluate the existing documentation and gap to answer the following questions (not exhaustive):

• What is the most relevant inspection frequency depending on the inspection method, the facility size/type or the results of past inspections?
• What should be the coverage of the inspections?
• How the inspection frequency impacts emission reduction?
• How effective are repairs? What are their longevity? Is it dependent on the types of component or/and the type of repair?
• How efficient are existing quantification methodologies? (cost, time, accuracy)
• What are the other variable that can impact the reduction potential? This includes different maintenance practices and past baseline fugitive emissions management.

The project team will in particular focus on the identifying factors for the upstream sectors with its specific characteristics. Oil and gas practices vary significantly internationally; it is thus important to remember that the lessons learned from practices in one part of the world may not always apply to others.
For all analysis, the project team will thus evaluate the relevance of the different conclusions to the Canadian operations.
Finally, the project team will explore how experience from other industries could be leveraged and translated to the upstream oil and gas industry. Other industries to be covered may include biogas facilities (where some work has been performed in Sweden in particular), large manufacturing industries and refineries. It is important to highlight that the project team has worked on some of these questions (leak magnitude distribution, the effectiveness of repair, repair longevity, etc.) in Canada, the USA, and in Europe. The project team has thus a unique insight on the limitation and strength of existing data and can thus properly document what are the gaps and the weaknesses in the existing work performed.
Deliverable: At the end of task A and B, a report will be prepared which will summarizes the findings of task A and B. The results will be documented and the report will include some comparison tables and gap analysis.
It is proposed that the results of Tasks A and B are presented to PTAC before the initiation of task C.

Task C: Recommendations for a scientifically credible field study to further research the effectiveness of FEMPs
Objective: This task aims at preparing concrete recommendations for a field study to fill some of the gaps identified above and to further research the effectiveness of FEMPs.
Methodology: Based on the results of Task B, the project team will discuss closely with PTAC on the priority objectives of the field study and in particular the gaps (some identified in Task B) that the field study aims to fill. This initial subtask will result in the preparation of a short (less than one page) “field study objective and priority” statement which will be used in the design stage.
The upstream oil and gas industry in Canada is extremely variable, with a great variety of facility types, sizes. On the other hand, any such field study is limited by a specific budget which impacts the number of measurements which can be performed. It is thus crucial that the field study be developed systematically to ensure the representativeness of the results and a good understanding of fugitive emission leak profiles and program effectiveness. For this task, the project team will develop a systematic approach, mapping first the upstream oil and gas sector in Canada and using this mapping to prepare a robust design.
Recommendations will include:
• Number and types of sites to be covered
• Number and frequency of repeat surveys (at the same facilities)
• Site selection methodology and criteria
• Technology and methodology proposed for quantification (during the measurement campaign)
• Approach and data collection approach to quantify emissions and develop emission factors (how to extrapolate the results of the measurements performed?)
• List of data to be collected during the measurement campaign (this list may include information such as number of components in the facility, throughput of the facility, type of the facilities, etc.)
• Method and approach to differentiate leaks from vents (in particular targeting components with different emissions points)
• Clear and concise expectations of operators participating in the study
• Data QA/QC procedures

A key question that will need to be resolved at the survey planning stage is to develop the categories of facilities that will be part of the survey. The team is of the view that Petrinex facility types are not suitable site types for this project, but Petrinex facility information will be captured during the project for future reference. A list of “mutually exclusive, collectively exhaustive” site types will be developed in partnership with MRPC. These site types will then be used to describe the number of sites required for each inspection interval.
For this task, the project team will bring together team members with (i) deep experience in the Canadian upstream sector and its variability, (ii) extensive knowledge of the scientific challenges in analyzing dataset to determine representative conclusions for fugitive emissions and (iii) extensive field experience.
Deliverable: The project team will deliver a draft field survey design including the recommendation and their rational. A meeting will be held with PTAC to present the results.
External QC: It is proposed at the end of this task to seek for external QC for the proposed field study design to ensure the success of phase 2.

1.2 Phase 2 Initial Field Study, Data Analysis & Preliminary Reporting Scope
Task A – Finalization of the Field Survey Design and Preparation of the Field Survey plan.
Objective: Field study design developed in Phase 1 will be reviewed by the PTAC Methane Research Planning Committee (MRPC). This task aims at finalizing the field survey design (including, for example, the principles and approach for the site selection) and to prepare a practical field survey plan (including e.g. which sites will be surveyed at what time etc.) which can be implemented during Task B.
Methodology: The survey will be based upon gaps identified in the literature review and be designed to provide a credible method for determining the effectiveness of different mandated inspection regimes via OGI. A key consideration will be processes to remove the potential for biases and to create a scientifically defensible result. This task will include amongst others the following activities:
Finalization of the Field Survey design: Based on the recommendation of Phase 1, the comments and recommendations of the MRPC, the field survey design will be completed. Important considerations during this stage will include:
• How to include sites that are implementing alternative mitigation approaches and how the results of these sites will be compared to the results at other sites
• AVO inspections in advance of comprehensive surveys;
• Comprehensive surveys at pre-determined intervals
Study design will be provided two weeks prior to an MRPC meeting. An in-person meeting will be held with MRPC to finalize the Survey Plan.
If significant revisions are identified by MRPC prior to the in-person meeting, the in-person meeting will be re-schedule to accommodate comments. The objective of the in-person meeting is to achieve sign off from MRPS on study approach.
The field survey plan will then be developed including
• Site selection: The field survey design will define clearly the principles for the sites selection and the mix of sites that will be covered by the survey. Based on these principles sites will be selected. A random selection of different site types defined in the study design will be selected for different OGI survey intervals. The selection algorithm employed will minimize bias across operators, production types etc.
• Detailed measurement protocol: The field survey plan will include specific detailed description of the measurement protocol during the surveys to ensure that the surveys will be performed in a systematic and repeatable manner. Measurement protocol will include the description of the measurement equipment, the time and process for calibration, the duration of each measurement, etc. This information will be important to ensure the credibility of the results of the survey.
• Data collection template: The field survey plan will also include a robust and systematic data collection template for the survey team. The data collection template will ensure that all the relevant information is collected in a systematic and controlled manner during the survey. Lessons learned from past surveys will be applied, such as identification of process blocks, PETRINEX facility ides, date of last inspection, date of last turn around.
• Practical organization of the survey: The operator will then be approached to organize practically the surveys. It is assumed that PTAC and AER will facilitate such communication. Timing of the first survey will be agreed in advance.
The field survey plan will be delivered three weeks after the completion of the Field Survey design.
Deliverable: A finalized field survey design approved by all parties incorporating, among other things:
(i) List of the sites to be covered during the survey
(ii) Measurement protocol for the site visits
(iii) Data collection template for the team members performing the surveys, and
(iv) Timing of the surveys (including number and timing of repeat survey)

Task B – Field Surveys
Objective: This task is included in the implementation of field surveys in accordance with the study plan. The project will be an “emissions audit” and will follow methods and best practices employed by the auditing industry to ensure that creditable data from the field surveys will be produced. The end result will be a scientifically credible data set on the effect of different inspection frequencies on leak detection and repair.
Methodology: The survey will be performed by a team of two experts and will follow the field survey plan developed. GreenPath will deploy senior technicians who have previously participated in major research studies. If operating in tandem with AER or BCOGC inspectors, a senior GreenPath Technician will be paired with the inspector. A component of the study is the effectiveness of Audio Visual Olfactory (AVO) inspection by operators as a means of leak detection. As such, baseline procedures of AVO inspections will be provided to the relevant operators in the “sample plots” for the survey. AVO procedures will be provided to the operators of relevant participant sites including written and video tutorials.
During comprehensive leak inspection surveys, all leaks will be detected via a FLIR GFx320, intrinsically safe camera, eliminating the need for a “hot work permit” for the inspections. All leaks will be recorded in high sensitivity and non-high-sensitive mode for a duration of 30 seconds, the leaking component photographed by the FLIR Camera (in normal mode) and tagged with a serialized weather resistant polymer tag.
Operators will be contacted when a leak is detected and provided with a “work order report” which identifies the leaking component and recommended repair. When possible, a root cause analysis will be performed to document the possible cause of the leak/emission point. Quantification method will be discussed and decided during Phase 1 and Task B and will depend on the type of emission point and the location of the emission points.
GreenPath’s existing online database will be used to provide notice to operators of the leaks detected and operators will use the online database to report on repairs completed. Subsequent surveys will be used to confirm the effectiveness of the repairs undertaken. The project team will clearly differentiate when a leak is “new” and when the leak is the result of a past ineffective repair. Training will be provided to the operators and head office staff of the selected sites on the use of GreenPath’s online database.
GreenPath Energy has completed several broad-based fugitive surveys including the 2016 survey on behalf of the Alberta Energy Regulator and the 2017 Survey for the Clearstone Engineering NRCAN Project.
During the survey, the results will be tracked, and a dashboard of facilities inspected, leaks detected, repairs confirmed will be provided to the MRPC.
• Quarterly Status updates on the project
• For each survey: completed data template
• Data Table on the sample plots, with an anonymous version of the data presented for publication
• Appendices with all supporting information (completed work order reports, IR videos, pictures, etc.).
Sites to be covered during the survey: The study proposed will use a representative sample of sites and to provide robust and credible answers to the different questions raised. However, the number of sites covered and the number of repeats will be limited by the overall budget available for the surveys. The current proposed budget includes 47 days of onsite survey using the measurement equipment already owned by GreenPath and described in Annex 3. Priorities will be discussed frequently with the client to maximize the value of the surveys performed. If additional field days are required based on survey design, a request to MRPC may be brought forward to have the budget modified.

Task C – Draft Analysis Report
Objective: The final report will compile the results of the field survey. The results of this study will be compared against other published studies. Where gaps are identified, recommendations will be made for further research.
Methodology: The following activities will be performed during this task.
• QA/QC of the data: The data complied during the survey will first be QA/QC following the procedure documented during Phase 1. Issues will be flagged and when necessary discussed with the client. The procedure and the results will be clearly documented.
• Report structure: A report structure will be prepared and shared with the client, with comments on the draft report structure to be incorporated.
• Drafting of the report: The project team will then draft the report. The report will aim at covering the following themes (in alignment with the final field survey design)
o Detailed description of the methodology used (including QA/QC)
o Results of the surveys in particular:
? Effectiveness of intentional and targeted AVO inspections
? Incremental emissions reduction depending on the frequency of surveys
? Impact of alternative mitigation approaches
? Rate of occurrence for each likely cause of leaks
? Effectiveness of repairs (statistics on the length of time between repair and recurrence of a leak);
o Comparison to other research (listed and analyzed during phase 1)
o Limitations of the study
o Recommendations
• Peer review by client: The draft report will be shared with the client and comments will be incorporated
• External peer review: Given the importance and the overarching objective of the project, it is proposed to use an external peer reviewer.
• Presentation: Finally a presentation will be delivered to the PTAC Air Research Forum and to the MRPC for evaluation of progress.
• Final report after the internal and external peer review.
• Set of slides of the presentation.
• Potential problems, challenges and reasonable solutions to the plan are identified in Annex 2.

4. Budget & Payment Schedule:

Phase I $69,825 Complete by March 18, 2018
Phase II – Field Work $156,510 Complete by April 21, 2019
Phase II – Desktop $68,680 Complete by June 30, 2019
TOTAL $297,710

5. References:

James C Diamond, Environment and Climate Change Canada, 819-743-6254, [email protected]>
Greg Unrau, Repsol Oil and Gas Canada Inc, 403 696 3766, [email protected]
Sean Hiebert, Cenovus Energy, 403.532.7518, [email protected]
Daniel Zavala-Araiza, Environmental Defense Fund, 1.512.691.3457 [email protected]
David McCabe, Clean Air Task Force, 1.626.71. 6542, [email protected]

Attachments: https://auprf.ptac.org/wp-content/uploads/formidable/GreenPath_CarbonLimits-Proposal_GG_JA.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%)