If you are working for an oil and gas producer in Canada in a role involving ESG or regulatory compliance, you may have heard the acronym “alt-FEMP” and wondered what it meant. The acronym “alt-FEMP” was born in Alberta and it’s short-hand for “alternative Fugitive Emissions Management Program”.
Fugitive emissions are a target opportunity for regulators and stakeholders. Fugitive emissions make up approximately 33% of the total methane inventory in Alberta (Clearstone Engineering, 2018). Colourless and most often odourless, they are unintentional methane releases to the atmosphere, otherwise known as “leaks”. Reducing fugitive methane emissions is a critical step towards reaching the federal government’s target to reduce oil and gas methane emissions by 45% by 2025.
What is an alt-FEMP?
In 2020, provincial and federal governments enforced requirements for the oil and gas industry to undertake regular fugitive emission detection surveys.
Directive 060in Alberta,Section 17 of the Oil and Gas Conservation Act in Saskatchewan, and The Fugitive Emissions Management Guideline by the British Columbia Oil and Gas Commission outline requirements for FEMPs, and all require Leak Detection and Repair (LDAR). LDAR for FEMP involves surveys at a set frequency using either portable Organic Vapour Analyzers (OVA) or hand-held sensors such as Optical Gas Imaging (OGI) cameras.
With thousands of sites and millions of individual equipment components distributed across an oil and gas producing province, detecting leaks when and where they happen is a colossal challenge. Industry is still assessing the best options to manage these new requirements, and service providers are developing new technologies for rapid leak detection and quantification at a lower cost.
Suppose a company wants to deviate from the prescribed FEMP approach. In that case, they can apply for permission to use an “alternative”FEMP, or “alt-FEMP,” which may include the use of new or emerging technologies to detect fugitive emissions, or a change in work practice from what is required in the regulation.
Why Adopt an Alt-FEMP?
The existing regulations are very prescriptive in terms of how companies can detect and measure fugitive emissions. New, or “alternative,” approaches and technologies may offer efficiencies in terms of both cost and the effectiveness.
In the default approach to FEMP, specialized personnel and equipment need to go to each site, sometimes up to three times per year, which is costly and time consuming. Many sites will not end up having detectable fugitives. Additionally, leaks will only be detected when the handheld methane detection device is in close proximity and directly pointed at the leak. New, remote methane detection technology can work at a distance and detect high volume leaks more quickly. Sensors can be truck, UAV, airplane, or satellite-mounted, allowing them to cover greater areas than hand-held equipment. Fixed sensors also can be mounted to collect real-time, high frequency methane data. If designed correctly, alt-FEMPs can allow companies to benefit from the increased detection and economies of scale of these new technologies.
What is the Process?
The first step to realizing the benefits of alternative technologies for fugitives management is to determine which methane detection methods or technologies you should use. Many factors affect the potential technology choice, including:
- The location and distribution of the sites to be monitored
- The effectiveness of detection of the various sensors and survey methods offered by technology and service providers,
- The cost of deploying the technologies at your assets.
All of these factors are unique to each individual operator. Sounds complicated, right? It is. There are numerous factors and scenarios to consider, but the benefits of designing an effective alt-FEMP can be worth it.
That’s where simulation models come in. By simulating methane emissions and costs, models can quickly solve this complex question. Models such as Arolytics’ AROfemp run dozens to hundreds of programs to find the most effective mix of technologies and work practices for a company’s FEMP.
Once a company has determined that they have a
better way to do their FEMP than what is laid out in the regulations, it’s time to move onto the next step: Obtaining permission from the regulator to carry out the proposed alt-FEMP. AER, Environment and Climate Change Canada, and the Saskatchewan Energy Regulator all have a process for approving alt-FEMPs. The BCOGC in British Columbia, are quickly adding similar application processes to support the industry in finding better approaches to monitor fugitives using new technology, and we can expect these guidelines to be published in the coming months.
How Do You Get an Alt-FEMP approved?
In Alberta, there are two types of alt-FEMP proposals: pilot and full-scale. Unlike full-scale proposals, pilot proposals do not require comprehensive emission reduction evaluations. However, all of the pilot proposals approved and published so far have included third-party evaluations of the emission reductions. Pilot programs can be approved for up to 2 years and full-scale programs for up to 5 years.
A full-scale alt-FEMP application in Alberta would have the following elements:
- Technology Details: A description of the technology and work practices proposed, including performance data such as detection curves and technical limitations.
- Baseline Fugitive Emissions Assessment: Theoretical estimates of likely methane emission levels before implementing the alt-FEMP. This is usually based on industry data.
- Fugitive Emissions Reduction Assessment: The anticipated emissions reductions that would be achieved using the standard methods prescribed by AER’s Directive 060.
- Equivalency Modelling: A demonstration, preferably carried out by a third party, using a comprehensive computer simulation model. The results must show that methane emission reductions associated with the alt-FEMP are predicted to be the same or greater than the prescribed approach.
The AER reviews alt-FEMP applications as they receive them. The estimated processing time is 60 days. The Federal government and SK Regulator must be notified and provided with supporting documents prior to conducting an alternative LDAR program. In all cases, if the regulator is not satisfied with the outcomes of the alternative LDAR program, a standard LDAR program may be required.
The Alt-FEMP is Approved – Now What?
During the approval period in Alberta, companies must keep detailed records and submit progress reports of their emission reductions to the regulator. The data required for this reporting may be quite heterogeneous. For example, satellite images versus operator OVA measurements. All data needs to be collected and presented on a per-facility or per-site basis, showing that leaks were repaired promptly, no matter which technology was used for monitoring and measurement. Once the program concludes in Alberta, companies need to submit an additional report with information on the technology’s performance and any challenges experienced.
As experience has taught us, alt-FEMPs pose tremendous opportunities for cost effective methane management.