A Fugitive Emissions Management Program must be designed to reduce fugitive emissions and be updated to reflect any changes to operations. Effective June 1, 2019 the Alberta Energy Regulator requires producers to prepare a FEMP.
Fugitive emissions management is based on the systematic detection and repair of leaks, malfunctioning equipment, and surface casing vent flows. Systematic detection relies on regular surveys or screenings of sites for fugitive emissions.
The Fugitive Emissions Management Program must contain the following elements:
- Contact information of the individual accountable for the FEMP.
- Resources allocated to developing and implementing the FEMP. Include which group within the company is responsible for maintaining and updating the FEMP and who (e.g., corporate environmental or operations group, third party) will be conducting the surveys.
- Preventive maintenance practices to reduce or prevent fugitive emissions. Include any practices under development, and if data from previous surveys have been used to inform preventive maintenance practices.
- The procedures and plans that will be used to meet the required frequency of fugitive emission surveys and screenings and to complete repairs. Indicate any deviations from the prescribed frequency and provide justification.
- Techniques and equipment used for fugitive emissions surveys and screenings. Include equipment make and model and any plans to use alternative technologies.
- Calibration methods and equipment maintenance practices for equipment used for fugitive emissions surveys.
- Training programs and certification completed by individuals conducting fugitive emission surveys or screenings.
- Description of how individuals will be trained and how often they will be retrained or re-certified.
- Methods used to evaluate training effectiveness.
- Internal procedures to track, manage, and verify the status of repairs.
- Data management practices and systems to ensure that survey and screening results trigger required repairs and that the repairs are captured for annual reporting.
- Provisions for continuous improvement of the FEMP, including how FEMP data will be used to evaluate program performance.
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