PEM Inc. supports the U.S. GHG Measurement, Monitoring, and Information System (hereafter referred to as U.S. GHGMMIS or GHGMMIS.
EPA Greenhouse Gas Reporting Rule PEM Comments (2023)
Recording of the public hearing on the proposed rule “Greenhouse Gas Reporting Rule: Revisions and Confidentiality Determinations for Petroleum and Natural Gas Systems (88 FR 50282) that was held on August 21, 2023. Comments made by PEM Inc.
https://youtu.be/BoBDJ6iY3jQ?feature=shared&t=4612
Comments submitted by PEM Inc.
EPA-HQ-OAR-2023-0234-0419_attachment_1
EPA-HQ-OAR-2023-0234-0194_attachment_1
DAC-CCUS Leakage Data Rate Product
Based on DOE, National Energy Technology Laboratory Cooperative Grant (DE-FE0001116; 2012 – 2014): Near Surface Leakage Monitoring for the Verification and Accounting of Geologic Carbon Sequestration Using a Field Ready 14C Isotopic Analyzer. The methods employed in the DOE/NETL work for carbon capture and storage (CCS), and carbon capture, utilization, and storage (CCUS), can be applied to Direct Air Capture (DAC) performance with a Measurement, Monitoring, Reporting, and Verification (MMRV) system and applied to related technologies that concentrate CO2 followed by geological sequestration. Note: CCS and CCUS are used interchnageably.
Contact PEM for additional information here.
Background PEM DAC-CCUS Leakage Rate Products
The primary objective of the PEM DAC-CCUS leakage rate product is to develop an unassailable automated system of systems (SoS) supporting an intelligent sensor network for leakage detection from a DAC-CCUS project that informs operators and stakeholders of decreased storage containment.
The PEM Integrated Measurement, Monitoring, Reporting, and Verification (MMRV) system of systems, is a software application featuring five components: (1) comprehensive, reliable measurements of GHG emissions across all DAC-CCUS sectors; (2) sustained monitoring of emissions over time; (3) integrated, standardized, and timely reporting to provide feedback on emissions reduction approaches and guide course corrections; (4) rigorous independent verification to provide confidence in the reported emissions reduction; and (5) ongoing engagement over the lifetime of the DAC-CCUS project (e.g., 100-years) to ensure that data supports the evolving needs of stakeholders who are working to reduce emissions and buyers of offsets representing “permanently” sequestered CO2.
For example, operational definitions to be defined based on the results of the proposed work for increasingly lighter values of Δ14CO2 indicate the mixing of modern tropospheric air with dead CO2 from injected ff-CO2. Multiple approaches across biogeochemical boundaries will be used to define baseline variations (e.g., 1 σ) incorporating two eddy covariance towers, repeated measures of multiple soil flux locations, extraction of CO2 from groundwater wells, and gas from soil probes. The methods employed will be integrated with continuous flow analyzers measuring CO2 and CH4 isotopologues including, 16O12O16O, 16O13C16O, 16O12C18O, 16O14C16O, 12CH4, and 13CH4. Intermittent collection of CH4 will be analyzed individually using flask collection for 14CH4 and 14CHD.
The isotopic variations will be employed to define detection levels of leakage (e.g., tons ff-CO2 yr-1) and corresponding storage permanence relative to a 1000-year reference containment period (e.g., 100%, 99%, etc.). The suite of isotopologues and their direct correspondence to source gas identity and isotopic fractionation (e.g., kinetic, equilibrium) represents an advancement beyond what has thus far been achieved in the field. The resulting patterns of data relative to conditions may provide an interpretative framework across diverse DAC-CCUS sites. The range of molecular species is also employed to explore differentiation between ff-CO2 and potentially confounding CO2 originating from coal seams that are also present in the area. The two-system eddy covariance integrated with the GMP continuous flow analyzer should also detect dead CO2 from outside of the immediate EC area.
As described in the PEM MMRV field plan (available upon request), air will be sampled from two heights of an eddy covariance tower providing further possible identification of air masses from areas outside of the DAC-CCS environment. The rationale for employing continuous 13CH4 measurement is based on the wide variation of CH4 sources relative to 13C composition representing thermogenic and biogenic gas also present in coal seams (e.g., C1/(C2+C3) versus d13C CH4 ‰) and likely to be present in many DAC-CCS environments. A C2-C7 analyzer will be employed for methane comparisons on one of the EC platforms. Values for 14CH4 and 14CHD although available as single samples will further differentiate methane sources.
The EC systems will be configured with automated, controllable solenoid valves to incorporate calibration runs for all analyzers. This work will be performed by PEMs’ highly experienced team in electro-mechanical systems engineering and with eddy covariance. Also to be deployed in the project are adsorbent cartridges for selective collection of CO2. The products are manufactured by Radeco Inc. and are designed to be passively deployed for varying amounts of time or can be deployed with high-volume calibrated air samplers. The cartridges are routinely analyzed by AMS or other means and were developed for sampling air in nuclear power and nuclear materials areas. Given that long-term surveillance will be needed over the lifetime of a CCS project the objective is to calibrate this product within the project site relative to the AMS analyses that will be taking place. The cartridges are of minor cost and are covered by the supply budget. The large amounts of data, as described in the PEM Data Management Plan (available upon request), will be processed and made available for inversion model analysis by one or more expert groups TBD upon project initiation.
The ground sensor networks will be augmented by available satellite data products for CO2 and CH4, summarized below.
