Answering Your Most Pressing Super Emitter Questions from Our Recent Webinar
Wow! Thank you to the hundreds of attendees who joined us for our recent webinar, Super-Emitters: A Rational Approach. We love connecting our experts with industry operators to share information and engage together. In case you missed it, the recording is available linked below:
The session brought up dozens of excellent questions, and while we addressed as many as we could live, we felt that some warranted further discussion. Read on to gain a deeper understanding of some key topics.
Quick Recap of Bridger Photonics’ Recommended Approach to Super-Emitter Management
The approach our team recommends for managing super-emitters boils down to this: use measurement in a thoughtful, guided way to create a super-emitter management program that allocates resources based on actual risk. Super-emitters are generally of very short duration, lasting minutes or hours, instead of weeks or months. The frequency of super-emitter occurrence also varies greatly by site type. Rather than using a one-size-fits all approach that involves constant flyovers and fire drills for ground crews, we recommend using measurement to identify risk and focus your monitoring and mitigation efforts where they’ll have the most impact.
For many of you, super-emitters are top of mind right now. Here are some of the most common questions we received.
Question: What is a super-emitter?
Answer: This is a deceptively simple question. That’s because super-emitters are handled slightly differently depending on the context or regulation in question.
For the Super Emitter Program under EPA’s Methane Rule (OOOOb), a super-emitter is a site-level emission totaling greater than 100 kilograms per hour (kg/hr) of methane. Ultimately, the spatial resolution of the technology used under the Super Emitter Program influences the amount of plume aggregation (that is multiple smaller emissions appearing as a single, larger plume of methane) that may occur when determining whether a detection event qualifies as a super-emitter.
Under the EPA’s Subpart W rule, an Other Large Release Event (the reporting category for super-emitters) sets a similar 100 kg/hr emission rate threshold but specifies that this rate is for an emission or set of emissions tied to a single root cause. This is important because it means that using a monitoring technology that can spatially resolve methane plumes from different root causes can make a big difference in determining whether emissions are reportable as an Other Large Release Event or not. For example, two adjacent emissions with rates of 50 kg/hr and 60 kg/hr, but with different root causes, would not indicate an Other Large Release Event if they can be spatially distinguished. This applies to data from an operator’s own monitoring program. However, it appears that third-party Super Emitter Program notifications from the EPA must be reported as Other Large Release Events regardless of whether the detection events involve emissions coming from multiple root causes. We’re engaged with the EPA to learn more on this matter.
Question: Doesn’t more measurement protect me from massive fines that EPA plans to impose if I can’t establish the duration of a particular super-emitter?
Answer: Although it’s possible to fly assets more frequently, the data is clear: that approach creates additional expense and effort that could be bypassed with a more targeted, data-driven approach.
In most cases, self-disclosure of additional super-emitters detected during high-frequency, voluntary scans are likely to counteract the benefits of time-bounding Super Emitter Program notifications from the EPA.
In a perfect world, operators would measure everything everywhere, would know as soon as an emission event starts, would be ready to make any repair immediately, and wouldn’t have to worry about reporting super-emitters to the EPA. But the reality is that maintenance budgets and crews are stretched thin, and as regulatory and reporting burdens increase, that problem is getting worse. Our approach focuses on making best use of your limited resources to mitigate super-emitters and manage residual risk.
If you found that one site type (or even one specific site) was 10 or 20 times more likely to have a super-emitter, it would make sense to focus your limited resources on measurement and mitigation on that site type. And that’s exactly our recommendation. Bridger Photonics’ data gives you the spatial resolution and quantification to identify not only high-risk sites but even high-risk equipment types across your assets. This data can be leveraged to allocate resources effectively.
Question: Your webinar suggests using SCADA to time-bound super-emitters. What if my SCADA can’t do that, or I don’t have SCADA?
Answer: The best super-emitter defense is a layered defense. Using periodic surveys to understand your risk profiles and identify problem sites is a great first step. Many super-emitter causes can be determined and eliminated from this data alone. However, once risk profiles are understood from high-quality measurement, SCADA coverage, when available, can strategically be increased at high-risk infrastructure.
Some clients tell us they can identify and time-bound super-emitters from their desktops with just Bridger Photonics’ scanning data paired with SCADA data. It’s a great option, but it might not work for all operators. For some facilities, investing in continuous monitoring may help time-bound super-emitter emissions lasting minutes or hours. For select high-risk facilities with difficult-to-mitigate super-emitter causes, and where the previous strategies are impractical, you may benefit from adding in more frequent periodic screenings as well.
Our key takeaway is that rather than trying to invest in everything everywhere, adopt a mindset of using data to drive a layered defense.
We answer questions about self-reporting super-emitters, time-bounding with dynamic emission rates, and more. Download the full resource by filling out the form below: