Mastering Fugitive Emissions Monitoring Plans: A Comprehensive Guide
Author: Andrew Walsh, VP of Customer Success
Understanding the Stakes
The oil and gas industry faces increasing public pressure to reduce its environmental impact. Consequently, regulators are progressing more stringent regulations for the management of fugitive emissions. Examples of regulations enacted across the United States include the Colorado Air Quality Control Commission Regulation 7, California’s SB 1137, and the US EPA New Source Performance Standards (NSPS) OOOOb & Emissions Guidelines (EG) OOOOc. These regulations mandate stringent monitoring and control measures to reduce greenhouse gas emissions and safeguard public health.
The Importance of a Fugitive Emissions Monitoring Plan
A well-structured fugitive emissions monitoring plan is crucial for several reasons:
Compliance: Complex regulations like Colorado Regulation 7, California’s SB 1137, and NSPS OOOOb/EG OOOOc require adherence to a robust fugitive emission program.
Cost Savings: Early detection and repair of leaks prevent the loss of saleable natural gas products.
Risk Management: A proactive monitoring program identifies potential emissions-related safety hazards to operator personnel and the public.
Tailoring Your Plan to Specific Regulations
While the core elements of a fugitive emissions monitoring plan remain constant, the specific requirements can vary significantly between federal, state, and local regulations. For instance, Colorado Regulation 7, California’s SB 1137, and US EPA NSPS OOOOb/EG OOOOc (figure 1) differ in focus areas and enforcement mechanisms. It is crucial to:
Understand the regulations: Thoroughly familiarize yourself with the specific requirements of each applicable regulation.
Identify equipment and activities: Determine which equipment and activities are covered under the regulations.
Establish monitoring frequency: Align your monitoring schedule with the regulatory mandates.
Choose appropriate methods: Select monitoring techniques that meet the regulatory standards and your operational needs.
Develop a robust data management system: Ensure your system can capture and analyze data according to regulatory requirements.
Figure 1 – High-level requirements for various US continuous emissions monitoring programs
Key Components of a Fugitive Emissions Monitoring Plan
A comprehensive plan will include the following elements:
Site Inventory: A detailed list of all sites subject to monitoring, including single wellhead only sites, multi-wellhead only sites, centralized production facilities, or facilities that contain major production and processing production and processing equipment.
Monitoring Methods: Specification of regulatory-approved monitoring techniques, such as AVO, OGI, and continuous screening technologies like QUBE. Monitoring methods can be site-specific or within a company-defined area.
Monitoring Frequency: A schedule for regular inspections and monitoring activities, considering equipment type, risk level, and regulatory requirements.
Leak Repair Procedures: Clear guidelines for identifying, assessing, and repairing leaks, within required timelines.
Data Management: A system for recording, storing, and analyzing monitoring data to track performance and identify trends.
Training: A comprehensive training program for personnel involved in monitoring, repair, and data management.
Figure 2 illustrates the steps required to implement Qube’s continuous monitoring technology as a monitoring method to address leak detection and repair (LDAR) and adheres to the monitoring frequency under US EPA NSPS OOOOb/EG OOOOc.
Figure 2 – Implementing a continuous screening program with Qube
Best Practices for Fugitive Emissions Monitoring
Leverage Technology: Utilize advanced monitoring technologies like continuous monitoring to enhance detection capabilities and increase operational efficiency.
Focus on Root Cause Analysis: Address the underlying causes of leaks to prevent recurrence.
Engage stakeholders: Foster a culture of environmental responsibility through stakeholder training and involvement.
Continuous Improvement: Regularly review and update your plan based on performance data and regulatory changes.
Implementing a comprehensive fugitive emissions monitoring plan is essential to ensure compliance with regulations like Colorado Regulation 7, California’s SB 1137, and NSPS OOOOb/EG OOOOc while also demonstrating environmental stewardship and social responsibility. By investing in advanced monitoring technologies, training personnel, and establishing effective procedures, you can significantly reduce emissions, improve operational safety, protect your bottom line, and enhance your company's reputation.