Canadian Regulation Update on Emissions
Operators in refineries, chemical, petrochemical, LNG and oil & gas production must keep GHG & environmental regulations for emissions in mind. One area where this is extremely important is in the processing of oil and gas. This overview discusses the most recent regulation updates issued by the Canadian Federal Government. By Gobind Khiani, M.Eng., P.Eng.
The Canadian Federal Government published and enforces the Canada Gazzette regulations, which is divided into the following sections:
Part 1: Material required by Federal Statute or Regulation.
Part 2: Canadian Environmental Protection.
Part 3: Acts - These are published Acts (applied as soon as is reasonably practicable after they have received royal assent in order to expedite their distribution).
Part 2 is the most important and relevant to emissions. The briefing is as follows:
Protection of environment and reduction of harmful effects
(a) Impose requirements on the oil and gas sector in order to reduce emissions of methane and volatile organic compounds.
(b) Designate the contravention of certain of its provisions as serious offences by adding them to the schedule to the Regulations Designating Regulatory Provisions for Purposes of Enforcement (Canadian Environmental Protection Act 1999).
Interpretations (i.e. definitions apply in this regulation)
Onshore Upstream Oil and Gas Facilities, in determination of Volume of Gas by directives. For example:
a) Measurement requirements for Oil and Gas Operations, PNG017, published by Government of Saskatchewan on August 1, 2017.
b) Measurement requirements for Oil and Gas Operations AER Directive 017, published by Alberta Energy Regulation March 31, 2016 and,
c) Measurement Guidelines for upstream oil and gas operations, published by the Oil and Gas Commission of British Columbia on March 1, 2017.
This includes information required for following:
• Advice on venting limits
• Leak detection and repair program
• Regulatory LDAR programs
• Period of inspections
• Release not considered a leak
• Period of repair
• Granting of extension
• Alternative LDAR programs
• Document keeping
• Revocation of permits
• Gas detection systems and repair
The above is applicable starting January 2020 for all facilities in Canada and compliance is required by January 1, 2023.
Further, Part 2 refers to a table providing a “Summary of Modifications” from the proposed regulations as seen in Tables 1 and 2.
The Government of Canada federally announced methane emissions reduction from oil and gas must decrease by 45%. This can be achieved by applying the emission regulations to legacy facilities/plants/operating units. Simply focusing on emission reduction only on new facilities will not help achieve this target.
Currently, the PTAC-Petroleum Technology Alliance Canada has started a Methane Emission Reduction Forum, whereby oil and gas companies and associations, including environmental groups and academia participants, learn and share knowledge. Frequency of monitoring, inspection and leak detection and repair cycles remains one of the most critical pieces of puzzle as some are annualized and some are more frequent inspections and monitoring requirements.
British Columbia has formed BC Methane Research Collaborative due to tighter timelines on implementation of federal regulations by January 1, 2020, they have stepped up their development efforts for on track for equivalency by the time emission reduction requirements come in effect. Similarly, Saskatchewan has plans to reduce emissions by 4.5 million tonnes by 2025 (as quoted by Saskatchewan Research Council). Cosia, the Canadian Oil Sands Innovation Alliance and SRC see the gap in field testing of new technologies and have built a system called CeDER (Centre for the Demonstration of Emissions Reductions). In Alberta, AER works closely with CPAT (Climate Policy Assurance Team), EDF (Environmental Defense Fund), Pembina Institute, and CAPP (Canadian Association of Petroleum Producers) in an effort to implement emission reduction technologies.
As the industry dives deeper into emissions, new methane regulations are being issued and updated to the latest and most current technologies, which is achieved in collaboration with national and international institutes such as ISO, API, CSA, ERM Alberta etc. For example, ERM Alberta in Year 2018 has executed 145 projects with ERA funding of $467,000,000 and those projects will have 9,700,000 GHG reductions by 2020.
In conclusion, the Federal Government of Canada set the following reduction targets for 2018-2025 and beyond.
• In the US, leak detection and repair is monitored by US Environmental Protection Agency (EPA). They fine towards emission violations. The agency requires repairs of leaks and minimizing of hazardous or toxic air pollutant emissions that require monitoring and repairing within stipulated time per their consent decree with each company.
• The US Environmental Defense Fund works closely with oil and gas companies, universities and technology developer to find solutions to challenges like mobile methane monitoring and satellite monitoring.
1. Government of Canada, Public Services and Procurement Canada, Canada Gazette. “Canada
Gazette.” Canada.ca, April 18, 2019, www.gazette.gc.ca/accueil-home-eng.html.
2. Emissions Reduction Alberta, www.eralberta.ca.
3. Various Industry regulations in the United States and Canada.
4. Public Services and Procurement Canada, Canada Gazette. “Canada Gazette, Part II: Volume 152- Canada.ca.” Canada Gazette, Part II: Volume 152 - Canada.ca, 21 Feb. 2019, gazette.gc.ca/rp-pr/p2/2018/index-eng.html. Table 1 and 3 from Canada Gazzette, Part 2-Environmental Section.
Image Courtesy of REUTERS/David M. Parrott.