The Future of LDAR Programs: what you need to know
LDAR, or leak detection and repair, is the process oil and gas firms use to find and repair emissions leaks at their facilities. The LDAR mechanism unfolds in three main phases: firstly, leaks, often invisible, are detected using specialized tools. Secondly, the severity of these leaks is assessed based on emission rates and associated hazards. Lastly, leaks are repaired and then documented. This information goes to the EPA as part of its annual Greenhouse Gas Reporting Program (GHGRP).
Different jurisdictions have varying LDAR standards and criteria. With responsibly sourced gas gaining traction, numerous upstream oil and gas enterprises voluntarily adopt LDAR to bolster workforce safety and offer more eco-friendly commodities, such as what California is doing with its Low Carbon Fuels Standard.
Why is LDAR Crucial?
With the global urgency to address climate change, governments worldwide are deploying numerous strategies, mainly focusing on diminishing greenhouse gas emissions such as methane and volatile organic compounds (VOCs). For context, the energy sector accounts for nearly a quarter of global methane emissions.
Creating a safer work environment for employees at upstream oil and gas sites is essential, as these locations are often riddled with hazards. By curbing harmful emissions, companies can enhance worker satisfaction and retention while shielding neighboring communities from prolonged exposure to toxic emissions.
Implementing LDAR also makes financial '‘cents,” minimizing potential lawsuits, fines, and faulty equipment risks. The EPA calculates that, on average, equipment leaks lead to a product loss valued at $730,000 annually for each facility. This is lost money that a business can quickly recover with an effective LDAR program, especially when using new technologies.
Regulations Surrounding LDAR
Many regulatory bodies impose mandatory LDAR protocols for the upstream oil and gas sector. For instance, in Canada, the Alberta Energy Regulator (AER) has delineated its LDAR stipulations in Directive 060, which outlines the specifics of emission screening repairs and mandates companies to draft fugitive emissions management plans (FEMPs). Similarly, in the U.S., LDAR norms are enumerated in the EPA's 40 CFR Subpart OOOOa, which offers two main LDAR methodologies and accommodates requests for alternate technological solutions.
Setting Up an LDAR System
Today's methods, such as Method 21 or OGI, are manual, complex approaches to leak detection. The principle concept revolves around sending a person to a site to check for leaks, and if one is detected, document and repair it. The problem with this approach is it could be more efficient. Most of the time, leaks are not discovered, and when they are, they could have been leaking for months or longer, given the infrequent site visits. However, all LDAR programs operate around these three principles:
Leak Spotting: At chemical or oil/gas establishments, the first step in any LDAR program is discerning where methane leaks might occur. Technologies like optical gas imaging (OGI) are commonly employed, although evolving techniques also include continuous monitoring via gas sensors.
Leak Surveillance: The methodologies and duration for monitoring hinge on the adopted technology. Some jurisdictions have fixed mandates, like Alberta's AER, which prescribes one to three site visits annually. While some operators may still rely on human senses for leak detection, such methods have limitations and are often coupled with advanced technologies.
Leak Rectification and Documentation: Upon identifying a leak, regulatory standards provide a roadmap for its rectification. The ultimate goal is safe identification and repair to preempt similar leaks in the future. Comprehensive record-keeping is crucial to trace leak patterns and discern the components that frequently pose risks.
The Future of LDAR Programs
Part of the upcoming changes introduced in the EPA's Methane Emissions Reduction Program will be the ability for operators to take advantage of innovations in the industry for continuous monitoring, what they're calling the adoption and implementation of advanced technologies.
EPA Pushes for Advanced Technology in Detecting Methane
The EPA recognizes the overwhelming industry feedback that supports more flexibility in employing cutting-edge methane detection techniques to trace leaks, often termed "fugitive emissions."
The proposition favors using diverse advanced tools over traditional methods like optical gas imaging (OGI) or EPA Method 21. It recommends adjusting monitoring frequency based on the efficiency of the chosen technology and mandates timely leak repairs.
Continuous monitoring options will be allowed, providing real-time, round-the-clock surveillance for methane breaches.
All well sites will be methodically screened for leaks and tailored to the specific equipment in the proposed changes. The updated proposal advocates using continuous monitoring systems by setting benchmarks accommodating a more comprehensive range of technologies.
Owners or operators leveraging continuous monitoring must address and rectify any leak caused if emissions breach a set limit. This strategy mirrors the boundary monitoring protocols followed in EPA's air toxin regulations for petroleum refineries.
Streamlining Approval for Advanced Methane Monitoring Techniques
The EPA underscores its commitment to innovation by outlining a straightforward method for innovators to gain clearance for advanced methane monitoring systems. Once greenlit, these technologies are accessible to all stakeholders without repetitive permissions.
Owners or operators looking to employ yet-to-be-sanctioned techniques must obtain approval following the EPA's alternative testing procedures, bypassing the conventional site-specific monitoring strategies.
Upon endorsement of a universally applicable method, it will be available on the EPA's Emission Measurement Center portal, aiding owners or operators in defining their leak screening plans.
The proposal elucidates approval prerequisites, such as primary application qualifications and essential tech details, aiming to affirm or reject a tech application within 270 days.
The EPA might grant conditional consent if no verdict is reached within the stipulated time. All decisions and associated information would be publicly accessible on an EPA-backed online platform.
These exciting changes, while not finalized yet, will enable a pathway for firms to leverage our advanced sensor and monitoring solution, helping companies cut costs, reduce emissions, and react faster to leaks. There are still hurdles to overcome, and the industry is pushing back on some proposed rules. Still, the overall direction is positive and will help the industry move into the digital era of LDAR and, more effectively, reduce emissions.
