2023 Thought Leadership In Review

Following the legislative mandates carried by the PIPES act of 2020, and the Inflation Reduction Act of 2022, PHMSA and EPA proposed this summer a revision to their current regulations to improve emission reporting and direct operators to take action towards emission abatement.

For the first time, PHMSA’s Gas Pipeline Leak Detection and Repair (LDAR) proposed regulation includes methane emissions reduction as a goal along with existing safety considerations. This broadened scope leads to four main changes for local distribution companies (LDC):

The acceleration of the leak survey cycle from 5 years to 3 years and even to 1 year for assets the most prone to leaks.
The classification of leaks larger than 10 such as grade 2- to prioritize their repair within 6 months.
The requirement of repairing all grade 3 leaks within 2 years of discovery.
The annual report of methane emission estimates.

In addition, PHMSA proposed to mandate operators to use detection tools with a better than 5 ppm sensitivity and to file of a long-term Advanced Leak Detection Program (ADLP) presenting their plans to improve their leak management efforts including detection, repair, and pipeline replacement.

In parallel, EPA’s new proposed regulation explores the use of direct measurement to support gas distribution network emission reporting. This would replace the use of emission factors that do not offer the accuracy and specificity needed to properly measure each LDC’s emissions reduction progress. As a first step, EPA decided to align the emissions factors set through Subpart W and those used for its GHGI that previously displayed a factor three difference in estimation.

Both proposed regulations demonstrated a profound shift in their intent towards the collection of accurate, actionable, and auditable data to drive emission abatement and improve gas distribution network safety. Details are still to be finalized but our customers are already leveraging Picarro’s solutions to address the upcoming requirements.

Picarro’s AMLD grants accuracy, scale, and traceability needed to achieve annual emissions reporting of entire gas distribution systems. Quantification of all detections not only addresses the daunting sampling challenge of emission factor-based reporting but also identifies the larger leaks to enable the cost-effective abatement of emissions without adding a significant workload to maintenance.
Several leading utilities have also successfully demonstrated using Picarro how to accelerate leak survey from 5 to 3 years by replacing miles of ineffective foot surveys by investigations limited to the indications of presence of methane in the air. The benefits of this feature increase when more frequent surveys lead to a lower number of leaks found per mile.
The Super Emitter program of Picarro not only fulfills the requirement of accelerated repair of leaks larger than 10 scfh but also supports the acceleration of their detection that is critical to reduce emissions and the adjustment of the threshold in time to progressively capture deeper emission abatement.
By quantifying all leak detections Picarro offers a direct representation of their contribution to emissions and, by this way, justifies the definition of a leak by a minimum flowrate. WSU’s data shows that, altogether, emissions from all less than 0.5 scfh sources only represent 6% of the total emissions in a gas distribution network.
The data collected by Picarro is the foundation of consistent reporting across agencies: EPA and PHMSA that will both request soon an annual emissions reporting. It is also a unique source of truth that will help leading LDCs design and feed their ADLP to rationally improve all aspects of leak management to reduce emissions and enhance system safety.

The new Emission360^TM application of Picarro will automate these processes and calculations to bring to your fingertips the full power of the data collected across your gas networks to assess emissions and enable the most effective plans for their abatement.

Picarro submitted its comments to the new regulations on August 15^th(PHMSA) and October 2nd respectively (EPA). The final texts of the new regulations are expected at the turn of the year.