Bringing Advanced LDAR to Dominion Energy’s Cove Point
Alternative Work Practice and Leak Detection and Repair for LNG Facilities
In 2017, Montrose Environmental began a partnership with Dominion Energy at its expanding Cove Point Terminal, located near Lusby Maryland on the western shore of Chesapeake Bay. Cove Point is a portside facility that receives transport vessels, stores liquified natural gas (LNG) onshore, and transforms the LNG back to gas as needed – allowing Dominion to liquefy gas onsite and safely transport it to tanker ships for export abroad. With a storage capacity of 1.6 billion cubic feet and the capacity to send out 1.8 billion cubic feet of gas daily, Cove Point is a critical facility for the storage, processing and shipment of natural gas domestically and globally.
Critical Planning and Fugitive Emission Management
As the first company in North America to implement AWP Leak Detection and Repair programs to full EPA compliance and with services for over 2000 natural gas facilities across the United States, Montrose was a logical choice to assist in Dominion’s planning efforts. As planning commenced it became clear that as a state without a deep history of large-scale natural gas facilities, Maryland’s permitting process required careful study and included strict limits on Cove Point’s fugitive emissions. As a result, Dominion Energy offered to follow the stringent guidelines of Texas Commission on Environmental Quality regulation TX 28 LAER and chose Montrose as its partner for developing a Fugitive Emission Management Program (FEMP) and subsequently implemented that program to achieve and maintain compliance. Montrose managed the creation of the component inventory during the final construction phase of the facility and then began Leak Detection and Repair (LDAR) monitoring during the initial start-up process.
As planning progressed and the Cove Point permit was reviewed (and TX 28 LAER guidelines were factored in) Montrose confirmed that the facility could take advantage of the benefits of establishing an Alternative Work Practice (AWP) program – meaning that Dominion Energy could achieve compliance through the use of advanced Optical Gas Imaging (OGI) leak detection. The EPA AWP requires facilities to conduct OGI surveys of all components (often totalling over one hundred thousand components or more) every two months and an additional annual Method 21 survey. The end result being that each component would be monitored more often and more times per year than a traditional Method 21 based LDAR program.
A single LNG tanker visiting Cove Point Terminal can carry roughly 34 million gallons of LNG – enough to meet the daily energy needs of more than 10 million homes.
Alternative Work Practice (AWP) Nets Immediate and Significant Results
Cove Point’s AWP increased the frequency of component surveys – resulting in leaks being identified quickly and repaired sooner, keeping Cove Point’s emissions low and well below permit limits. Another AWP program benefit is an estimated cost reduction of more than 30% compared to a traditional LDAR program. The use of OGI at Cove Point enabled technicians to survey areas normally exempt from monitoring such as insulated components. The program also provided an extra layer of protection as potential natural gas related safety hazards can be detected and eliminated quickly with the use of OGI.
There’s no substitute for experience and cutting edge technology, and the two embedded Montrose technicians brought additional efficiency increases to the program and helped create the QA/QC program while providing valuable guidance with the Management of Change process. Dominion Energy also made the most of TARGET ONLINE, Montrose’s custom LDAR program management software. Designed specifically for OGI and AWP systems, this software has assisted the facility with communicating leak information, tracking repair activities and compliance reporting – ultimately saving money, reducing/eliminating leaks and increasing facility safety.
Benefits of the AWP
In addition to general efficiencies and increased quality and process control, the Montrose implemented AWP benefits include:
- Targeted identification of exact leak sources – preventing leak and repair errors – no more “ghost leaks”
- Identification of potentially hazardous conditions associated with leaks from process equipment
- Significant reduction of total emission rates due to faster identification and repair of leaks when surveys are conducted on a more frequent basis
- Identification of ongoing leaks from unmonitored equipment
- Ability to monitor ~2000 components per hour versus ~60 using Method 21
Two embedded Montrose employees manage Dominion’s program, and are responsible for all aspects of monitoring, quality assurance, and quality control. This includes the annual M21 requirements, facility camera scans, repair confirmations, and complicated emission calculations.
OGI allows Dominion to detect leaks from insulated and/or difficult or unsafe-to-monitor components. These components are monitored more frequently than if Method 21 alone was used, allowing Dominion to reduce facility emissions, improve site safety, and provide substantial cost savings by the reduction of lost product.
The AWP program enables Dominion to confirm leaks that were previously identified using Method 21. OGI proves especially useful in areas of tight component configurations where Method 21 may have difficulty identifying—or, in some cases, can even misidentify—the source of a leak.
The strategic partnership between Montrose and Dominion Energy has met with positive feedback and recognition for the development and execution of a highly successful and innovative emissions program without disruption of ongoing daily operations. The advances in technology and practical application of OGI have resulted in a reduction of leaks, cost savings, and reduced emissions.