Fugitive Emissions Management Program Effectiveness Assessment Proposal – Process Ecology and GreenPath

Project Title: Fugitive Emissions Management Program Effectiveness Assessment Proposal – Process Ecology and GreenPath
Project Lead: Mrs. Laura Chutny Email: [email protected]

Project Lead Organization / Company Information:
Organization: Process Ecology Inc.

1. Statement of Capabilities of Project Team:

The proposed Project Team is a joint effort between Process Ecology Inc. and Greenpath Energy Ltd. The following personnel are proposed (listed with years of experience):
• Alberto Alva-Argaez, Ph.D., MBA, – Process Ecology – 27 years experience
• Laura L. Chutny – M.Eng., P.Eng., – Process Ecology – 27 years experience
• James Holoboff, M.Sc., P.Eng., – Process Ecology – 23 years experience
• Samaneh Hajipour – Ph.D., P.Eng., – Process Ecology – 10 years experience
• Ahad Sarraf-Shirazi – M.Sc., P.Eng., – Process Ecology – 5 years experience
• Joshua Anhalt – Greenpath, – 17 years experience
• Michael D’Antoni – BA, MBA, – Greenpath – 14 years experience
• Abin Eldhose, E.I.T., PMP®, – Greenpath – 4 years experience
• Mike Glackin, E.I.T., – Greenpath – 3 years experience
a) citation list of relevant papers – see List in Appendix A
b) descriptions of relevant projects the team has carried out:
• Alberta Energy Regulatory (AER.) 2016/17. Greenpath – Alberta wide Oil & Gas methane emission detection, quantification, major equipment and pneumatic inventories in support of methane emission reduction modeling and policy/regulatory frame work development
• AER. 2016/17. Greenpath – Subject matter experts in fugitive emissions, pneumatics and compressors seals supporting AER methane regulatory oversight committee
• AER 2016/17 – Process Ecology – Subject matter experts in data collection, validation, analysis and software supporting the AER’s Measurement Monitoring and Reporting Technical committee
• AER Directive 060, Section 8.7 Fugitive Emission Inspections. 2007 to 2017. GreenPath has completed more than 2000+ upstream facility fugitive emission detection and quantification surveys supporting AER regulatory compliance mandates.
• BC WCI GHG & Fugitive Emission Facility Assessments. 2015 to 2017. GreenPath has completed more than 300+ BC facility GHG facility surveys including fugitive emission detection and measurement, compressor seal vent quantification, pneumatic inventory development, scrubber dump valve leak measurements and facility component counts
• B.C Ministry Environment Climate Action Secretariat (CAS). 2014 – Greenpath – Contract to complete the largest known Western Canadian census and direct measurement of methane fuel gas driven pneumatic instruments and chemical injections pumps. Work was completed on behalf of the Prasino Group, Canadian Association of Petroleum Producers (CAPP), and the Ministry of Natural Gas Development.
• BC Ministry of Environment. 2017. GreenPath review of available data in British Columbia to generate an estimate of methane emission sources and magnitudes.
• CETAC – CCEMC 2015 – Process Ecology – dehydration facility emission reduction opportunities analysis – data gathering, field data analysis and cost estimation, resulting in real savings of over 6,000 tonnes CO2e/yr.
• Petroleum Technology Alliance of Canada (PTAC) and AUPRF 2012-2016. Process Ecology – literature review, field data gathering and analysis, model and software development to quantify emissions from condenser tanks in gas dehydrators.
• PTAC / AUPRF 2015 – Process Ecology – literature study and gap analysis on fugitive amine emissions from upstream oil and gas.
• PTAC 2016. – Greenpath – Industry report on gas driven pump alternatives, challenges and opportunities of converting fuel gas driven chemical injection pumps to alternatives technologies in cold weather climates.
• PTAC 2017. Process Ecology conducted a technical analysis of field operation of new technology (GasPro) to reduce benzene, methane and greenhouse gas emissions from dehydrators.
• PTAC. 2017/18. – Greenpath – Alberta wide upstream oil & gas facility level controller study on the static and dynamic vent rates of level controllers in methane fuel gas services. Final report to be used to define an Alberta-specific level controller emission factor and assist in modeling industry methane reductions from the elimination of high vent rate pneumatic level controllers.
• PTAC/NRCan 2017-18. Process Ecology designed field trial to collect data on tank emissions and is analyzing data to determine best fit tank models specific to Alberta/Western Canada. This study allows validation of tank models based on readily available operator data and gas and liquid analyses and thus allows better estimation of actual emissions.
• PTAC 2016/17. – Greenpath – Desktop analysis of Fugitive Emission Plans and data collected by 3rd parties and operators. Development of software tools to parse fugitive emission data from multiple sources.
• US Environmental Protection Agency (EPA). 2016/17/18. – Greenpath – Auditor of tank emission control systems and associated leaks utilizing Optical Gas Imaging technology in support of producer consent decree obligations.
• Canadian Standards Association (CSA). 2016. – Greenpath – Associate member of multi-stakeholder technical committee CSA Z620 standard to reduce fugitive, venting and flaring emissions from the Canadian oil and gas industry. ?
c) CV’s of team members – In Appendix C
d) Other relevant information that gives evidence of the qualifications of the team to carry out this work.
The team of Process Ecology and Greenpath has a proven record of conducting research and field work. We have all worked in air emissions in Alberta and Western Canada for almost 10 years assisting small, medium and large upstream oil and gas producers with measuring, estimating, tracking and reducing emissions – from VOCs and Methane to Benzene and total GHGs. See the above list of projects and papers for more details.

2. Project management and control information:

2) Project management and control information:
a) indication of roles of team members
i) project manager / overall project direction
• Process Ecology – Laura Chutny. Subcontract lead at GreenPath would be Michael D’Antoni.
ii) financial management
• Process Ecology – James Holoboff
• Greenpath – Ryan Park
iii) literature review
• Process Ecology – Samaneh Hajipour and Laura Chutny
iv) field measurement
• Greenpath – Joshua Anhalt, Craig McKenzie, Abin Eldhose
v) data analysis
• Process Ecology – Alberto Alva-Argaez, Samaneh Hajipour, Ahad Sarraf Shirazi
• Greenpath – Joshua Anhalt, Ryan Park, Michael D’Antoni
vi) Reporting
• Process Ecology – Laura Chutny
• Greenpath – Michael D’Antoni
vii) hourly rates / unit rates for field work.
• Tech, Truck, FLIR OGI Camera and Quantification Equipment – $3300/day/1 man crew
• Extra person on crew – $250/day/person
viii) Timeline and budget for Project:
• Phase 1: Dec 1, 2017 – 30 April 2018. Budget: $67,000
• Phase 2: Mar 1, 2018 – Feb 28, 2019: Budget: $231,000
• TOTAL for Phases 1 and 2: $298,000
• Days in field: 47
Proposed milestones:
Week 9 – Interim Literature Study report
Week 14 – Preliminary Literature Study report and Preliminary Gap Analysis
Week 15 – Field Survey Design submitted for approval
Week 16 – Final Literature Study report and Gap Analysis
Week 17 – Field Survey Design approved
Week 20 – Final Field Survey Plan issued
Week 58 – Draft Final Report issued for review
Week 61 – Final Report issued

3. Project Plan (Scope & Deliverables):

3) Project Plan (Scope & Deliverables):
a) Phase 1:
i) Literature Review on Programs for Fugitive Emissions Management, with focus in the following areas:
• Definitions of fugitives, possible differences in design due to different definitions. Regulatory influence on definition.
• List of methods discussed in literature that have been used to fulfill typical Fugitive Emission Management Program (FEMP) requirements: LDAR (types – gas detection, OGI, sensors, etc.), AVO, others. Compare and contrast methods.
• Detection, Measurement, Data Tracking, Repair, MOC processes, re-testing guidelines and processes, timelines for testing and tracking, validation exercises.
• Factors that influence design and success of programs including, but not limited to: type and number of operations, operating conditions, training of operational personnel, organizational structure, FEMP software, FEMP hardware, equipment design and construction standards, age of facilities, maintenance standards, preventive maintenance (type and frequency), third party audit requirements and more.
• Industry wide (US, Canada, Europe, Australia) – Oil and Gas – Upstream, midstream, refining and petrochemicals.
• Relevant literature will include, but will not be limited to: Jurisdictional Regulatory Documents, IPCC reports, Guidelines and Best Practices, API Documents, CAPP documents and Best Practices, WCI documents, ECCC documents, EPA documents, CSA Documents, technical papers from Journals such as “Climatic Change”, “Journal of Earth Science”, “Environmental Science and Engineering”, “International Journal of Greenhouse Gas Control”, “Atmospheric Pollution Research”, “Science of the Total Environment”, “Environmental Science and Technology”, “Geophysical Research Letters” and many more.

Key elements for success of the literature search will be: identifying the leading recommendations for successful FEMPs and listing available resources.

Problems may include access to journal articles or corporate data. To avoid these potential problems, a prompt start to the project and use of industry contacts will be essential to making this literature review successful.

Deliverable is an interim report (approximately Week 9) with results to date.

ii) Literature Study Summary and Gap Analysis
As part of and following the literature study, a summary of relevant research and documents will be prepared as well as a gap analysis to highlight areas where further study is warranted and where this study can contribute to closing the gap. This analysis will focus on (but not be limited to):
• Leak Contribution factors
• Existing quantification methodologies and how they differ
• Data on leaks available, and range of data – are there common factors – are parts missing?
• Research on Methane and GHG – changes in emissions between pre-and post FEMP, do the changes vary with type of FEMP, good/bad design of FEMPs, other factors that influence success and how is success quantified.
• How relevant is the existing literature to Canadian operations (e.g. with respect to types of hydrocarbon processed, types of equipment, latitude, climate, relative education of operations, etc.). What are the gaps – how can they be filled?
• Other industries – Wastewater? Refrigerants? Landfills? Pharma? Pulp and Paper? Power Generation? Manufacturing? Agriculture? Food Processing? Can it be applied to Western Canada Upstream O&G?
Key elements for success will include: Ability to specifically distinguish what has been done from what needs to be done, identifying the significance of the gap(s) and an estimate of the value that would be gained by closing the gaps ($ and tonnes of CH4/CO2e reduced)
Problems and solutions. Problems could include: limited numbers of studies or no repetition of studies making it difficult to draw conclusions. Different definitions and assumptions in literature data could also make comparing literature difficult. Solutions include being able to access large numbers of literature sources in a timely fashion. Additionally, contacting authors of literature to obtain further information on definitions, source data and assumptions can solve some of the issues in this analysis – and starting in a timely fashion (heavier front loading will allow time for this to occur).
Deliverables here are a preliminary Gap Analysis, approximately week 14, then the Final Literature Summary and Gap Analysis with recommendations for the Field Study Design to consider, available approximately Week 16.

Ongoing projects in this space (and related fields) include, but are not limited to:
• “Area Measurements of Methane and Carbon Dioxide” – CNRL & Partners, funded by ERA
• “Calibration and Demonstration of Aerial Methane Imaging for Efficient, Wide-Area Methane
Emissions Detection” – Kairos Aerospace, funded by ERA
• “Imaging and Quantification System for Fixed Site Monitoring” – ATCO Ltd & Partner, funded by ERA
• “Advanced Methane Detection, Analytics and Mitigation Project” – PTAC
• Environment and Climate Change Canada – Mitigation and Adaptation research
• Information from the World Data Centre for Greenhouse Gases
• EPSRC (UK) – Air and Climate Change initiatives
• APPEA/CSIRO (Australia) – Fugitive Emissions from Coal Seam gas, and on-going research in decreasing emissions from the energy sector
• EDF Sponsored Projects

iii) Field Study Design
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 e.g. 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 Phase II.

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 Optical Gas Imaging (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 recommendations from Phase 1, as well as 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
• Sufficiency of data to develop reasonable emission factors
• 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-scheduled to accommodate comments. The objective of the in-person meeting is to achieve sign off from MRPC 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, the 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 ids, date of last inspection, date of last turn around, etc.
• Practical organization of the survey: The operator(s) will then be approached to organize 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 and approval of the Field Survey design (approximately week 20).

Key elements of success of developing the Field Study Plan will include access to timely meetings with the MRPC, timely selection of site partners, and quality data from those partners to assist in site selection.

Problems could include insufficient sites available for testing, or sites that do not meet the criteria identified in the Gap analysis and Field Study Design. Solutions could include multiple operating partners, with different types of sites. Another problem could be insufficient personnel to design study and complete work. Solution to this would be timely award of project in order to guarantee resources for 2018.

Deliverables are Field Survey Design – Approximately week 17, with the final Field Survey Plan available approximately week 20.

b) Phase 2:
Objective of the Task: This task consists of the implementation of field surveys in accordance with the study plan developed in Phase 1. The project will be framed as an “emissions audit” and will follow methods and best practices employed by the auditing industry to ensure that credible data from the field surveys will be produced. The result will be a scientifically credible data set on the effect of different inspection frequencies and operational factors on leak detection and repair and how that can be used to design effective Fugitive Emission Management Plans.

Methodology: The survey will be performed by a team of two experts and will scrupulously 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 to ensure consistency amongst sites.

During the 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 methods will be discussed and decided during Phase 1 and will depend on the type of emission point and the location of the emission point(s).

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 then 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, and repairs confirmed will be provided to the MRPC.

Number of sites to be covered during the survey: The study proposed will be designed to 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 repeat surveys 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. Priorities will be discussed frequently MRPC and other key stakeholders to maximize the value of the surveys performed. If additional field days are required based on MRPC review of the survey design the, a request to MRPC may be brought forward to have the budget modified.

Deliverables for this Phase:
• 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).
• Draft report (Process Ecology with GreenPath) identifying the effectiveness of a Fugitive Emissions Management Plan as carried out in this study, with reference to gaps identified in Phase 1 and how they were addressed in Phase 2. AVO inspection effectiveness will be addressed and leak types and effectiveness of repair will be assessed. Further recommendations for study in a possible Phase 3 will be outlined.
• Draft report peer reviewed and updated with feedback, then issued as final report, approximately Week 61.
• Presentation at PTAC Air Issues Forum (GHG Forum) and MRPC will be included (dependent on Timing).

Key elements required for successful completion of the survey and conclusion of phase 2 are: sufficient surveys to cover the range of sites required in the field survey plan and accurate and efficient data collection and management to allow analysis of data.

Problems and Challenges in this phase are weather, availability of personnel, site access and other logistical challenges. Having an efficient start to the project, early in the year and options on site selection will help mitigate these possible problems.

Survey Equipment Details – See Appendix B

4. Budget & Payment Schedule:

4) Budget & Payment Schedule (if any preferences).
Budget was addressed in Section 2 under project management. A kickoff Payment of 5% of project total is suggested ($14,900 + GST). Further Payments will be defined to coincide with project Milestones once project is awarded in cooperation with client.

5. References:

5) References.
3 client references:
1) Greg Unrau, Repsol Oil and Gas Canada Inc, 403.696.3766, [email protected]
2) Sean Hiebert, Cenovus Energy, 403.532.7518, [email protected]
3) Filiz Onder, Encana Corporation, 403.645.4629, [email protected]

Attachments: https://auprf.ptac.org/wp-content/uploads/formidable/AUPRF-FEMP-Oct-2017-Proposal-R1.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%)