Regulations Respecting Reduction in the Release of Methane and Certain Volatile Organic Compounds (Upstream Oil and Gas Sector) (SOR/2018-66)

Canada’s 2018 rule directly regulates methane from upstream facilities. Provisions go into effect on two different dates:

 

On/after January 1, 2020

Any gas well that is hydraulically fractured at an onshore facility must undergo “reduced emission completions” (Section 11), unless the facility is subject to requirements set by Alberta and British Columbia (Section 13).

 

Onshore and offshore facility operators must tie emissions from compressors used at the well pad into a gas conservation system, a gas destruction system (i.e., an incinerator or flare), or a metered vent to the atmosphere. (Section 14, 49, 50) Venting must not exceed rates set for compressors based on type, size (over/under 5 MW), and install date.

 

Upstream facilities that produce or receive at least 60,000 std cubic metres of product/year, must conduct leak detection and repair (LDAR) inspections at least three times a year, using a portable monitoring instrument that complies with EPA Method 21, or an optical gas-imaging instrument (Section 30). If the inspection identifies an actionable leak (Section 32), a repair must be made within 30 days or during the next planned shutdown (Section 33). Canada may approve other equally effective detection technologies (Section 29, 35). 

 

Offshore facilities must limit venting to 15,000 std cubic metres/year (excluding venting “to avoid serious risk to human health or safety”) (Section 47), and be equipped with a gas detection system that monitors leaks in real-time. These systems were previously required by regulations issued jointly by Canada and the Maritime Provinces. If leaks are detected, they must be repaired within 730 days (Section 52).

 

On/after January 1, 2023

Larger onshore facilities ( > 60,000 st m3 of product/year) must limit total venting to 15,000 std cubic metres of product/year (Section 26). This excludes liquids unloading, blowdowns, glycol dehydration, use of pneumatic controllers, pneumatic pumps or compressors, well completions, or venting for safety reasons. These facilities must limit the bleed rate of pneumatic controllers (Section 37) and pneumatic pumps (Section 39), and ensure hatches and pipe openings are generally closed (Section 42). If pump replacement or control is not feasible,  operators must apply for a permit on or before June 30, 2022 to continue to use the emitting pumps (Section 40). These permits only extend to the date a pump is replaced or its emissions captured, or to December 31, 2025, by which time the pumps must be phased out.

 

The rule includes reporting and recordkeeping requirements. Some are to justify exemptions from and application/non-application of the rules (Sections 12, 21-25, 48). Others report the number of emitting components at an upstream facility (Sections 19, 38, 44, 51); volumes of gas vented, destroyed, or delivered from each facility (Sections 27, 48); and results of LDAR inspections and monitoring (Sections 19, 36, 53). 

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