The AER has approved two detection technologies for fugitive emission management programs (FEMPs) in section 18.104.22.168 of Directive 060: Upstream Petroleum Industry Flaring, Incinerating, and Venting:
- an organic vapour analyzer (OVA) able to detect hydrocarbons at a concentration of 500 ppm and is operated in accordance with the United States Environmental Protection Agency’s Method 21: Determination of Volatile Organic Compound Leaks
- an optical gas-imaging (OGI) camera able to detect a stream of pure methane gas emitted at a rate of 1.0 gram per hour or less under controlled laboratory conditions and is operated within six metres of the equipment being surveyed
The AER requires fugitive emission surveys at a prescribed frequency using either a portable OVA or OGI cameras (see table 4 of Directive 060).
To accommodate the fast-paced evolution of technologies to identify and quantify emissions, sections 22.214.171.124 and 8.10.6 of Directive 060 allow duty holders to propose “other equipment or methods that are equally capable of detecting fugitive emissions.” The duty holder must assess the equivalency of the proposed technology and demonstrate the equivalence if requested by the AER.
The AER will consider innovative and science-based alternatives to the FEMP described in section 8.10 of Directive 060. Alternative programs may incorporate various technologies, such as unmanned aerial vehicles, vehicle-mounted sensors, and continuous monitoring devices to detect, track, repair, and report fugitive emissions.
A duty holder must submit alternative FEMP (alt-FEMP) proposals to the AER and follow the requirements in sections 8.10.2 and 8.10.4 until the AER has approved its alternative program.
For more information about alt-FEMPs, see the following: