Frequently asked questions in the elaboration and implementation of the PPCIEM
More than three years after the publication of the Guidelines for the Prevention and Integral Control of Methane Emissions from the Hydrocarbon Sector (Guidelines), the elaboration of the Program for the Prevention and Integral Control of Methane Emissions (PPCIEM) continues to be a challenge for most of the regulated parties. There are several reasons for this, among which two stand out:
- Methane emission reduction is a recent practice for the global oil and gas industry and our country was a pioneer in its regulation.
- There are situations not explicitly foreseen in the Guidelines.
The industry has thousands of projects covered by contracts, entitlements and permits that require the submission of a PPCIEM, but ASEA has only 12 Authorized Third Parties (four for Segment A, two for Segment B and six for Segment C), which are key in the regulatory compliance process for methane emissions.
The insufficient capacity of the Third Parties to process thousands of PPCIEMs and an equal number of annual reports, plus the industry’s limited experience in controlling its emissions have resulted in many questions about compliance with this important regulation. In our role as an Authorized Third Party, we have held several meetings with ASEA to expose the industry’s doubts and the gray areas of the regulation that need to be clarified. In this one-pager we present a compilation of the most frequently asked questions we have encountered in our interaction with regulated companies and the regulator. Disclaimer: The following conclusions are in the process of being officially assessed by the ASEA and are the sole responsibility of COVAR ENERGY CONSULTING S.C.
Methane emissions regulatory compliance frequently asked questions
The nature of regulations is dynamic. The key to accelerating the results sought by regulations lies in agile communication between all stakeholders. Third Party Licensees have a responsibility to be a bridge between industry and regulators to close gaps in regulatory compliance and accelerate the implementation of best practices in methane emissions control and reduction.
Recommended steps in the preparation of the PPCIEM
The Guidelines require the formation of a Multidisciplinary Group and the appointment of a Technical Responsible of the company that will manage the PPCIEM. This implies a deep involvement of different areas of the regulated companies in its preparation, for which we recommend the following stages:
Conduct project preparation, where delivery times are established, and conduct a training workshop on methane emissions and their regulation in Mexico.
- Multidisciplinary Group (MDG).
Selection of the members of the MDG and the Technical Manager.
Choice of quantification method (direct, indirect or mixed methods). Formalization of the MDG (delivery of curriculum vitae, preparation and signing of appointments and minutes).
Quantify methane emissions from all equipment and its components at each facility.
- Working groups of the multidisciplinary group
Present and approve the diagnosis.
Define actions and emission reduction goals.
Define dates for LDAR.
- File Integration
Integrate the file with all the documentation of the preparation of the PPCIEM for its delivery to the Authorized Third Party.
At Talanza we are committed to facilitating compliance and proposing solutions that allow for greater understanding and efficiency in the development of oil activities in Mexico.