Is Your Fugitive Emissions Management Plan Enough?
What is a FEMP?
Fugitive Emissions are gases or vapors unintentionally released into the atmosphere. A Management Program is put in place to stop these unintentional releases from happening.
FEMP's are intended to complement overall emissions reduction strategy by establishing a plan and supporting systems to systematically detect and manage fugitive emissions.
What is Needed in a FEMP?
- Contact Information and Resourcing: Identify contacts as well as internal and external resources.
- Preventative Maintenance: Incorporating preventative practices into operations.
- Procedures and Plans: Plans to meet required frequency of fugitive emissions.
- Equipment and Training: Best practices for equipment use and training.
- Data Management: Track, manage and verify status of repairs.
- Continuous Improvement: how data will be used to evaluate performance.
Contact Information and Resourcing
A FEMP must clearly identify which individual is accountable for the FEMP and should provide their title and contact information. This person will be the primary contact for any questions from the Alberta Energy Regulator (AER) about the FEMP. The FEMP must document internal (e.g., individual staff, groups, departments) and external (e.g., contractors) resources allocated to develop, implement, maintain, and update the FEMP.
Preventative Maintenance
FEMP must indicate what preventive maintenance practices are being used to reduce or prevent fugitive emissions. This could include checklists used by field operators during routine inspections, regularly scheduled maintenance programs and preventative maintenance practices. Ensuring proper inspections and all equipment is operational are example preventative maintenance options that should be executed regularly.
Procedures and Plans
The FEMP must have documented procedures and plans for meeting the required frequency of fugitive emissions surveys and screenings. This should include information like the number of surveys or screenings required and completed at each site, the results of surveys and screenings and the status of any required repairs. Site survey and screenings vary in time and frequency for multiple reasons depending on regulations.
Equipment and Training
A FEMP must describe the methods and equipment used for surveys and screenings, including the make and model of survey and screening equipment. It's not necessary to use the same type of equipment for all surveys and screenings. Surveyors must identify the specific type of equipment or method used for each survey or screening.
There are no minimum training requirements for individuals completing fugitive emissions surveys, however it does require that these individuals are properly trained. the FEMP must also describe any internal and external surveyor training programs and frequency of training.
Data Management
Companies must have procedures to track, manage, and verify the status of repairs and to meet the reporting and record-keeping requirements. One of the most challenging aspects of a FEMP is managing the collection and flow of data. Most programs that fail are due to inconsistent or incomplete data collection and poor communication of data.
Continuous Improvement
The FEMP must describe how data will be used to evaluate performance and inform continuous improvement. The following are indicators to evaluate performance:
emissions reductions over time (e.g., by corporate or operating area, or by facility type or equipment),
volume of gas conserved by managing fugitive emissions,
number of leaking components over time (e.g., by corporate or operating area or by facility type or equipment),
specific components within facilities that are more prone to leaks,
time between leak detection and repair.
Creating a FEMP doesn't have to be complicated. By implementing the proper steps like planning and proper training and maintenance, fugitive emissions can be minimized. Guardyan is here to help you every step of the way. Please reach out to use at info@gconservation.com.