Talanza Energy Consulting

julio, 2021

Best practices and the flexibility of methane emmissions regulation

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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:

1.Have already been implemented;
2.Cannot be implemented for technical reasons; and will be carried out in the next 6 years, included in the Third Title or the Equivalent Actions.
3.Equivalent Actions are actions that have effects equal to or greater (in reducing emissions) than those defined in Title Three.  Thanks to these two concepts, the regulated can implementalternative practices or technologies to those included in the methane regulation, mitigating the risk of regulatory compliance and operational independence, as long as they demonstrate to the ASEA the suitability of their proposal.
 

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 conclusion

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

Benefits of controlling methane emmissions

Economic: Maximize  income by  improving the use of hydrocarbons.
Operational and industrial safety:  Improves the risk profile of the facilities  and thus diminishes the probability of  accidents.
Environmental: Reduces methane  emmissions to the atmosphere,  greenhouse gas emmissions, and global  warming .
Como firma internacional con presencia en Estados Unidos, México y Colombia, encaminamos empresas del sector energético hacia un correcto cumplimiento normativo y asesoramos gobiernos a diseñar e implementar regulaciones que impulsen la sostenibilidad en el largo plazo para dicha industria.
Resultado de la sinergia entre líderes Canadienses y Mexicanos, en Eminent nos especializamos en la cuantificación, control y reducción de emisiones de metano. Como pioneros en México en aplicar la tecnología OGI, potenciamos la sostenibilidad de la industria petrolera internacional.