Section 8.10.6 of Directive 060: Upstream Petroleum Industry Flaring, Incinerating, and Venting states that we will consider innovative and science-based alternative fugitive emissions management programs (alt-FEMP). Alt-FEMP proposals must be submitted to the AER for review, and we must approve them before the applicant may deviate from the directive requirements.
Depending on the technology, an alt-FEMP proposal may be approved as a pilot or full-scale program. The criteria for a proposal to be considered a full-scale program are as follows:
- The program design is informed by previously completed pilot programs. The performance of the pilot program should confirm the emission reduction potential of the full-scale program.
- Extensive technology testing data is available, including publicly available laboratory testing, controlled release, and field-testing data. Technologies will have sufficient testing data to confirm a minimum detection limit and quantification accuracy, if applicable.
Use the information below as a checklist to create a complete proposal. Only complete proposals will progress to a technical review.
Alt-FEMP Program Details
Provide a summary of the program in tabular form that includes the following information:
- submitter contact information and the names of all program participants
- proposal type (pilot, full scale)
- the area of program coverage:
- the number of sites in the program (number of facilities in brackets)
- the number of sites in the control group (number of facilities in brackets)
- the percentage of Alberta operations (by site) included in the program
- a map showing the program area boundaries
- survey technology with minimum detection limit (MDL) @ 90% probability of detection (PoD)
- survey frequency (approximate dates of deployment)
- survey follow-up criteria
- estimated follow-up sites as a percentage of the total sites in the program, according to the model
- assumed repair timeline from the date of initial detection (from screening)
Provide the following information using the site list template:
- a list of all sites and wells in the program and include the following:
- site number
- facility number
- operator of record (the name of the company that operates the sites being surveyed or for multi-operator collaborative initiatives)
- site name
- reporting facility ID (RFID), well ID (UWI)
- site location, well surface location (legal subdivision)
- facility licence number, well licence number
- facility subtype code
- latitude and longitude
- Directive 060 survey frequency
- facility type
- identify any controlled tanks on site
- are there any confidential production strings linked to the facility
- a summary of the pilot program performance (full-scale program proposals only) and confirm the full-scale program design is like the pilot or where it differs and why.
Methane Detection Technology Details
Multiple methane detection technologies may be proposed. Provide the following information for all methane detection technologies to be used:
- Technology overview: Include the technology name and methane sensor type, describe the commercial availability and technical maturity, and list how often the technology will collect methane data (i.e., daily, weekly, monthly, etc.). If the technology quantifies emissions, describe the data analysis and quantification methods.
- Performance data: Summarize the laboratory, controlled, and field-level testing completed to date for each proposed alternative technology. Include performance data such as probability of detection curves:
- Provide the proven MDL @ 90% PoD of the proposed technology and conditions under which the limits were determined.
- For continuous monitors, indicate the thresholds for alarm.
- Compare the topography of the controlled release testing and field-level testing sites to the pilot area.
- Compare the technology MDL to the historical fugitive emissions data. Describe the number and volume of fugitive emissions that may be missed by the technology.
- If the technology quantifies emissions, provide testing data demonstrating its quantification capability.
- Performance limitations: Describe any performance limitations of the selected technologies (e.g., sensitivities to cloud cover, smoke, precipitation, snow cover, wind speed, extreme cold):
- Provide information on the maximum monitoring distance and how distance affects the detectability and quantification abilities of the technology. Include the manufacturer’s recommended distance or range if available.
- Work practices: Describe the work practices and contingency plans or methods to mitigate performance limitations (e.g., limiting implementation to specific temperature ranges or anticipation of smokey days or snow coverage):
- If no work practices have been developed, indicate if they will be and provide a timeline for completion.
- Maintenance and calibration requirements: Describe the instrument maintenance and calibration requirements.
- Operator training details: Describe the training operators will receive to ensure competency.
- Current use cases and approvals: Indicate whether you are using the technology or proposed program elsewhere or have applied to use it in other North American jurisdictions.
Repair Tracking
- Data management tools: List the data collection methodologies and tools to be used.
- Repair tracking process: Describe how sources of fugitive emissions will be tracked for repair.
- Multi-operator collaborative programs: Identify the operator and program coordinator roles and responsibilities. Describe the work practices involved and who is responsible for what aspect of the repair and tracking.
Fugitive Emissions Assessment
For alternative programs that differ from those in the Alternative Methane Detection Technologies Evaluation, the proposal should include the following:
- Key modelling assumptions
- leak production rate
- leak rate source
- percentage of sites expected to be venting in the model simulation
- optical gas imaging and screening technology
- MDT @ 90% PoD
- spatial coverage
- A plot showing the log scale emissions rate assumption against the cumulative distribution frequency.
- The justification for selecting the fugitive emission rate assumption used for the proposal.
- Overlay the MDLs or MDL ranges of the selected screening technologies @ 90% PoD.
The proposed alt-FEMP model must achieve an emissions level at least equal to the emissions achieved by the baseline emissions reduction.
Fugitive Emissions Reduction Assessments
- Standard program emission reduction assessment: Estimate the volume of reduction that would have been achieved by completing surveys using the standard methods in table 4 of Directive 060. Use the following reduction percentage estimates:
- annual surveys: 40% emission reduction
- triannual surveys (three times a year): 70% emission reduction
Alternative emission reduction estimates may be used in the assessment, but they should be justified with supporting data collected or verified by a third party.
- Alternative program emission reduction assessment: Provide an assessment demonstrating the pilot will achieve emission reductions equal to or greater than those expected from the fugitive requirements in section 8.10 of Directive 060.
- Additional control measures: If applicable, include details on any additional control measures incorporated into the proposal (e.g., using continuous or regional monitors to verify/validate emission reductions or implementing preventive maintenance practices to provide greater confidence in ongoing detection and emission reduction).
- For alternative programs that differ from those in the Alternative Methane Detection Technologies Evaluation, compare your work practice using the model inputs from the Alternative Methane Detection Technologies Evaluation. Summarize and explain the differences, justifying the chosen model assumptions.
The proposed alt-FEMP model must achieve an emissions level at least equal to the emissions achieved by the baseline emissions reduction.
