Best practices and the flexibility of methane emmissions regulation
The National Agency for Industrial Safety and Environmental Protection of the Hydrocarbons Sector (ASEA) requires that companies in the oil sector document the application of best practices in terms of industrial safety and environmental protection in element IX «Best Practices and Standards» , of the Industrial Safety, Operational Safety and Environmental Protection ManagementSystem (SASISOPA). On the other hand, ASEA’s regulation on methane emissions requires the application of specific minimum actions to control and reduce emissions, which has been classified as prescriptive by the industry. In this one pager, we will analyze the implications of these requirements and the alternatives for regulatory compliance.
Technological requirements in the regulation of methane emissions
ASEA’s regulation has become a benchmark for other countries seeking to design regulations to combat methane emissions. One of the reasons is that it promotes the use ofbest technological practices to control and reduce emissions. For example, according to Title Three of their methane regulation, the regulated parties must install a series of minimum actions to reduce methane emissions, among which are: the adaptation of vapor recovery systems, use of pneumatic pumps driven by compressed air or electricity, useof dry seals in reciprocating compressors, replacement of pneumatic controllers by mechanical ones, selection of desiccant dehydrators.
Likewise, article 73 of the regulation calls for the execution of a leak detection and repair program (LDAR) that must be carried out 4 times a year with Optical Gas Imaging (OGI)instruments or an equivalent calibrated for methane, that can display images of gases in concentrations of 10,000 ppm at a flow rate equal to or less than 60 g / h from a 6.35 mmorifice.
The foregoing seems to impose on the regulated the obligation to carry out these measures even in the event that they are not compatible with best operational practices.
Is there really an operational and regulatory compliance risk?
ASEA’s regulation has two mechanisms that provide operational flexibility and regulatory compliance:
The detailed technical justification (Justification) and the equivalent or superior actions (Equivalent Actions).
Justification is the document where the regulated must describe the actions that:
In the end, the important thing is to control and reduce emissions
The minimum actions contained in ASEA’s methane regulation could become obsolete with technological change, which would be solved with a regulatory update. For their part, the regulated parties must always demonstrate to the ASEA that their operations adhere to the best international practices and that the safety of their operations and care for the environment are their priority.
Ultimately, what will matter is compliance with the goals set in the Program for the Prevention and Comprehensive Control of Methane Emissions (PPCIEM). For this, it is essential that regulated companies have certainty and precision in the detection and quantification of their fugitive emissions (for which direct measurement technology is required (e.g. OGI) and not with the application of emission factors). Only in this way, companies will be able to select the best available technologies, evaluate technically and economically the feasibility of their implementation and finally plan mitigation and control measures. (See Key Steps in reducing fugitive methane emissions on the right).
In complying with the methane regulation, operators must consider best practices and document the Justification for using technological alternatives to control methane emissions. Reporting this in SASISOPA will be of great relevance since reference can be made to the consistency of the proposed mitigation measures and the rest of the oil operations.
Key steps in the reduction of methane fugitive emmissions