In December of 2023, the Environment and Climate Change Canada (ECCC) proposed Regulations Amending the Regulations Respecting Reduction in the Release of Methane and Certain Volatile Organic Compounds (Upstream Oil and Gas Sector).
Bridger has worked closely with industry, regulators, and scientists to rigorously test and implement our methane sensing technology. We leveraged this experience in our comment letter to provide recommendations for the Proposed Rule to ensure ECCC’s final rule is flexible, practical, and effective. We provided the following main recommendations:
- Base all fugitive emissions inspection requirements on technology performance instead of restricting the types of technologies that can be used so that the rule is technology-neutral and performance-based.
- Require rigorous performance demonstration for fugitive emissions detection solutions used for compliance, including proof that solutions do not have spatial blind spots.
- Update the screening inspection requirements to make sure operators understand what fugitive emissions inspection methods are intended and how often the sites must be screened.
- Remove emission rate quantification as part of determining repair deadlines for detected fugitive emissions.
- Provide suitable response guidelines for fugitive emissions detected by remote sensing technology.
Bridger’s recommendations are intended to give operators access to advanced technologies for regulatory compliance, increase compliance assurance, foster technology innovation, and enable operators to strategically mitigate emissions.
The following is a summary of Bridger Photonics’ comments. Access the full version with additional detail at the bottom of this page.
Use a Technology-Neutral, Performance-Based Fugitive Emissions Inspection Framework
We urge ECCC to allow operators to use any technology with detection performance demonstrated to be equivalent or better than optical gas imaging (OGI) or EPA Method 21 (M21) for the comprehensive inspection for fugitive emissions requirement. This includes periodic screening technology.
Specific Recommendations
Primary:
- Allow operators to use US EPA-approved periodic screening alternative test methods (according to US CFR Title 40, §60.5398b) for the comprehensive inspections for fugitive emissions.
Additional:
- Do not require comprehensive inspections during a quarter (for Type 1 facilities) or year (for Type 2 facilities) when a screening inspection or annual inspections has been performed using a detection method with performance comparable to what is required for comprehensive inspections.
Require Rigorous Technology Performance Demonstration for Fugitive Emissions Detection Solutions
We urge ECCC to require technologies used for fugitive emissions detection to demonstrate their detection sensitivity, localization performance, and spatial coverage with supporting information applicable to every inspection instance or to each site installation.
Specific Recommendations
Primary:
- Audit advanced leak detection methods and individual CMS installations for reliability in detecting emissions through fully-blinded testing and disqualify methods/installation without reliable performance.
Additional:
- Require advanced leak detection methods and CMS technologies to demonstrate their emission source localization performance.
Screening Inspection Requirements Should be Updated to Clearly Specify the Necessary Frequency and Inspection Approach
We urge ECCC to clarify the instances when sites must be inspected under the proposed screening inspection requirement for fugitive emissions, and what emissions detection approaches should be used.
Specific Recommendations
Primary:
- Change the required mass flow rate detection sensitivity for screening inspections to a more appropriate value, clearly state instances when screening inspections should be performed, and provide clear guidance on any handheld technologies and usage protocols for the screening inspection.
Additional:
- If a comprehensive inspection is performed in a month that the screening inspections would otherwise be performed, remove the requirement for a screening inspection to avoid duplicative workloads.
Repair Deadlines Should Not Be Based on Emission Rates Due to Technological Limitations
We urge ECCC not to base repair timelines on emission rate quantification in recognition of the limitations of in-situ quantification technologies and the uncertainty associated with quantifying individual emission events using remote sensing.
Specific Recommendations
- Remove mass flow rate thresholds as a determining factor in repair timelines for detected fugitive emissions.
Practical Response Guidelines are Needed for Emissions Detected by Remote Sensing Technology
We urge ECCC to provide an appropriate response pathway for fugitive emissions detected using remote sensing technology.
Specific Recommendations
Primary:
- Allow a 5-day data delivery window for remote sensing fugitive emissions inspections and initiate repair timelines only once data is delivered by the inspection entity to the end-user.
Additional:
- Allow operators to appropriately triage remote sensing detection to avoid unnecessary or unhelpful onsite investigations.
- If onsite investigations are appropriate, ECCC should allow operators to leverage the emission source localization capabilities of the remote sensing technology.
Additional Recommendations
Consider Additional Information for the Risk-Based Approach to Fugitive Emissions Inspection Requirements
We urge ECCC to ensure facility classifications for fugitive emissions inspection requirements are consistent with measured emissions profiles.
Operators have voiced concern that the risk-based facility classifications that impact fugitive emissions inspection requirements may not correspond correctly to the emissions profiles for those facilities. For example, to Bridger’s knowledge, inactive facilities are subject to the same requirements as active facilities. Bridger is willing to support ECCCs analysis of emissions profiles to ensure that the risk-based approach will achieve intended results.
Allow Methane to Serve as a Surrogate for Hydrocarbon Gas for Fugitive Emissions Detection Requirements
We urge ECCC to ensure that methane-selective fugitive emissions detection technologies can be used for regulatory compliance.
The Proposed Rule is broadly based on hydrocarbon emissions reductions. Owing to the co-occurrence of methane with other alkanes and VOCs, methane is frequently considered a suitable surrogate for hydrocarbon emissions detection for oil and gas infrastructure. We urge ECCC to specify methane selective detection technology and detection sensitivity based on methane emission rate probability of detection as suitable for the fugitive emissions inspection requirements.