Fugitive Emission Management Program (FEMP) Effectiveness Assessment

Project Title: Fugitive Emission Management Program (FEMP) Effectiveness Assessment
Project Lead: Mr. Yori Jamin Email: [email protected]

Project Lead Organization / Company Information:
Organization: Clearstone Engineering Ltd.

1. Statement of Capabilities of Project Team:

The proposed study team will comprise key individuals from Clearstone Engineering Ltd. (proponent), Carleton University (subcontractor) and GreenPath Energy Ltd (subcontractor) presented in the following table. These team members have successfully collaborated on projects of similar scope and complexity. The capabilities and relevant experience of each organization are presented in Appendix A while resumes for each team member are available in Appendix D of the Annex.

Clearstone Engineering Ltd.
Yori Jamin, M.Sc., P.Eng. Project manager and technical lead. Years of experience = 15
Navid Alavi, M.Sc., E.I.T. Project engineer and field technician . Years of experience = 4
Chris Lusena, Ph.D. Software developer. Years of experience = 20
David Picard, M.Eng., P.Eng.. Expert technical advice on field study design and measurement technologies. Years of experience = 25

Carleton University
Matthew Johnson, M.Sc., Ph.D. Expert technical advice on field study design and uncertainty management. Years of experience = 20
David R. Tyner, M.Sc., Ph.D. Expert data analysis. Years of experience = 10

GreenPath Energy Ltd.
Joshua Anhalt, Field Lead. Years of experience = 17
Mike D’Antoni, MBA. Field Coordinator. Years of experience = 12

No substitutions for the above individuals or changes in their roles will be made without prior written consent of the MRPC. However, it should be noted that certain support personnel (e.g., junior and intermediate roles) may be assigned to the project to help compile information and perform data entry work as required. Moreover, field team members will be confirmed upon finalization of the study design.

2. Project management and control information:

The organizational structure of the proposed study team is presented in Figure 1 while the expected level of effort and hourly rates for each team member are delineated in Table 1 of Appendix A.

3. Project Plan (Scope & Deliverables):

The purpose of project phase 1 is to provide the Methane Research Planning Committee (MRPC) with:
(1) A critical review and summary of key published literature relevant to upstream oil and natural gas (UOG) fugitive emission management practices (FEMP) and their effectiveness. Effectiveness is the ability of FEMP to control and reduce the risk of small leaks becoming large leaks. It’s anticipated that effectiveness will depend on factors such as voluntary versus mandatory surveys; survey frequency; use of internal versus specialized external technicians; sweet versus sour gas service; actual repairs completed and ability to keep FEMP activity records.

The team will conduct a literature review and collate the evidential basis for 2018 field study recommendations. The review will include:
a. Studies already identified as relevant to this project and delineated in Appendix B of the Annex.
b. Results of field surveys conducted by the AER during August/September 2017 (Clearstone, 2018) which can provide valuable insight into the effectiveness of the existing CAPP BMP on management of fugitive emissions. Over 300 locations were surveyed using standardized methods which provides a reliable baseline to evaluate the impact of various factors. To enhance the value of 2017 field work, engage with industry and achieve MRPC objectives, a follow-up questionnaire requesting the following details will be issued by the AER to subject operators. Analysis of survey results will endeavor to identify correlations between questionnaire responses and observed leak frequency and magnitude.
• Was a FEMP implemented in August 2017 for the subject locations? If yes, please provide a copy.
• Are audio, visual, olfactory (AVO) leak detection inspections completed for the subject locations? If yes, at what frequency (daily/monthly/quarterly /annually/every 2 years, etc)? Provide evidence of AVO inspections completed before September 2017 at subject locations (in whatever record keeping format is most convenient).
• Are optical gas imaging (OGI) leak detection inspections completed for the subject locations? If yes, at what frequency (monthly/quarterly/annually/every 2 years, etc)? Provide evidence of OGI inspections completed before September 2017 at subject locations (in whatever record keeping format is most convenient).
• Are alternative leak detection inspections completed for the subject locations (e.g., directed inspection and maintenance (DI&M), remote sensing, continuous monitoring of buildings, etc)? If yes, please describe, indicate inspection frequency and provide evidence of inspections completed before September 2017 at subject locations (in whatever record keeping format is most convenient).
• Were repairs completed for leaks detected by the AER (and communicated 29 October 2017)? If yes, please indicate the repair date and confirmation method (e.g., bubble test) in Greenpath’s online database by clicking this company-specific link.
The number of survey questions is minimized to encourage complete and accurate responses (i.e., it will be difficult for companies to provide repair records). Moreover, the reliability of survey results depends on the honesty of responses. Thus, it’s recommended AER state that no compliance enforcement actions will be taken as a result of survey responses.

(2) A prioritized list of research/data missing from the body of literature that would inform the potential effectiveness of methane reduction regulations drafted by Environment and Climate Change Canada (ECCC) and the Alberta Energy Regulator (AER). Prioritization will be given to factors that are cost efficient and reasonable to regulate and enforce. For example, facilities that are designed with low quality components, poorly operated and not maintained will be more likely to leak. However, it’s very difficult to regulate design, component purchasing, operating and maintenance practices so these factors are assigned a lower priority.

Also, further analysis of data from other studies is not considered a high priority activity because the context (e.g., survey frequency, inspection method, facility type, repair requirements, etc) of individual data points is typically not available so subject data is not suitable for evaluating FEMP effectiveness. Instead the study team will rely on conclusions and recommendations stated by subject authors.

(3) Recommendations on scientifically credible field data collection and leak measurements (completed at Alberta UOG facilities) that would inform decision makers regarding the effectiveness of proposed regulations and resulting FEMPs. Recommendations will consider trade-offs between sample size and measurement rigor; validation of OGI results with independent measurements (e.g., tracer test methods); and approaches for validating risk-based directed inspection & maintenance (DI&M) programs.
(4) Prepare a formal report documenting outcomes of phase 1.

Value added contribution (at no cost): a scan and summary of what North American jurisdictions are doing to assess or reduce UOG fugitive emissions. Relevant publications are delineated in Appendix C of the Annex.

The purpose of the phase 2 field study is to collect evidence that quantitatively assesses the effectiveness of FEMP strategies related to survey methods (e.g., AVO, OGI, remote sensing, continuous monitoring, etc); survey frequency, target sites/components; and leak repairs. Phase 2 is delineated into the following work tasks.

(1) Finalize the field study in consultation with the MRPC and consider: (i) recommendations from Phase 1, (ii) inclusion of sites surveyed by the AER during 2017, (iii) identification and mitigation of biases, and (iv) inclusion of sites implementing alternative FEMP strategies; and the best use of limited resources. An in-person meeting will be held with MRPC to finalize the field study (based on a draft provided to the MRPC one week in advance of meeting).
a. An approach for determining the impact of survey frequency and effectiveness of repairs, is to re-survey baseline locations in April (bi-annual frequency) and July (quarterly frequency) of 2018. This can be completed for a significant number of the 335 locations surveyed in 2017 within the phase 2 budget (if the final field study design selects OGI survey method and no component counts are required).
b. An approach for evaluating the effectiveness of AVO, is to request operators to conduct AVO inspections prior to comprehensive OGI inspections.

(2) Refine data collection and management software to ensure standardized definitions are strictly enforced as well as minimize post-survey QAQC and processing activities. Software developed by Clearstone/Greenpath for 2017 AER surveys will be refined to support the finalized field study.
(3) Conduct Alberta field study campaigns during 2018. The number of sites surveyed and sources measured will depend on finalization of the field study and the effort level permitted by the Section 4 budget. Notwithstanding, field work will be conducted as follows:
a. Performed by a 2-person team familiar with the types of facilities to be surveyed and trained in the work to be performed. Each team shall be equipped with a selection of leak detection and measurement tools including leak-imaging IR cameras, portable gas sensors, a Hi-flow sampler, and a range of velocity probes, temperature sensors and flow-through flow meters.
b. When possible, leak surveys will be completed with the intrinsically safe FLIR GFx320 camera and Hi-flow sampler so that work can proceed under “cold work permit.”
c. Our team will provide all of the equipment necessary to perform the specified field work. This may include, but is not limited to, the leak detection and measurement equipment, data collection tablets, personal monitors and personal protection equipment. All of our teams have the following current safety training: H2S Alive, WHIMS, TDG, First Aid and fall protection. Clearstone has safe operating practices and standards in place, which may be reviewed upon request.
d. All work performed during fugitive emission assessments will follow all applicable :
i. Provincial and Federal Health Safety and Environmental Regulations
ii. Safe Operating Procedures
e. If at any point during an assessment particularly large leaks are identified that may pose a noteworthy safety or financial concern they shall be brought to the immediate attention of the site personnel. The leak detection assessment work by the field team shall only be preformed where it is safe to do so.

(4) Complete data analysis and prepare draft report.

(5) Consider MRPC feedback when finalizing the report and preparing the PTAC presentation.

(6) Subject the study methodology and results to external validation by preparing a summary paper for submission to a peer reviewed journal. This activity will be completed by Carleton University team members.

The reliability of statistics generated from field data is dependent on sample size, complete detection of leaks and biases introduced to achieve pre-determined outcomes. Potential solutions to these challenges include:
• Completing enough samples to obtain normally distributed (or well defined) data sets which is typically constrained by the project budget. The number of sites visited can be increased with in-kind contributions of trained technicians and survey equipment (e.g., truck, IR Camera, Hi-flow Sampler, etc). Clearstone has already approached the AER Climate Policy Assurance Team regarding this possibility. Moreover, additional funding sources that could support this project are being investigated.
• Validation of OGI survey results to confirm all emission sources at a site are detected can be achieved by redundant measurements using tracer test or remote monitoring methods (e.g., truck or airborne plume transect methods). Measurement redundancy can improve confidence in quantified emission rates but introduces significant costs to the project. Coordination with other remote sensing projects or additional funding sources could enable redundant measurement without impacting the number of sites surveyed.
• Establishing a “field sampling plan” that clearly states campaign objectives and sampling methodology enables the identification of biases inherent to the sampling plan. Biases are then included in uncertainty calculations and final result confidence intervals. Evidence of specific site biases (e.g., a leak survey conducted immediately before an AER inspection to reduce leakage observed by the AER) are further managed by correlating site results with a survey frequency reflective of actual practices. Disclosure of factors influencing results (e.g., facility type; service types; typical leak survey method and frequency, etc) in the final report provides context and informs applicable end use. Moreover, communication of the sampling plan, with a request not to complete leak surveys, prior to site inspections should engage operators and minimize biases.

4. Budget & Payment Schedule:

The estimated effort by task and team member is delineated in Table 1 of Appendix A. Invoicing and payment on a monthly basis is preferred.

5. References:

References for Clearstone Engineering:
Company Name: Environment and Climate Change Canada
Address: 200 Sacre Coeur Boulevard
Gatineau, Quebec J8X 4C6
Contact Name: Frank Neitzert, GHG Program Director
Phone Number: 819-997-7511
Email: [email protected]

Company Name: Devon Canada Corporation
Address: 400 3 Avenue SW
Calgary, AB, T2P 4H2
Contact Name: Maude Ramsay, Supervisor Environmental Engineering
Phone Number: 403-663-2708
Email: [email protected]

Company Name: Alberta Energy Regulator
Address: Suite 1000, 250 – 5 Street SW
Calgary, Alberta?T2P 0R4
Contact Name: Gerald Palanca, Manager, Climate Technical Advisory Team
Phone Number: 403-297-3726
Email: [email protected]

Reference for Carleton University:
Company Name: Natural Resources Canada
Address: 580 Booth Street, 13-C2-2
Ottawa ON K1A 0E4
Contact Name: Michael Layer
Phone Number: 343-292-8876
Email: [email protected]

Reference for Greenpath Energy Ltd.:
Company Name: Repsol Oil and Gas Canada Inc
Address: 888 3 St SW #2000,
Calgary, AB T2P 5C5
Contact Name: Greg Unrau, Environmental Specialist
Phone Number: 403-696-3766
Email: [email protected]

Attachments: https://auprf.ptac.org/wp-content/uploads/formidable/Annex-to-FEMP-Proposal.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%)