Oil and gas industry: guide to reporting

This document will be useful if you are responsible for an oil and gas facility and need to better understand your National Pollutant Release Inventory (NPRI) reporting obligations. It is not a comprehensive reporting guide for the industry; it clarifies the reporting requirements for certain types of oil and gas facilities. This document is meant to be a companion to the more comprehensive  Guide for reporting to the NPRI.

Various factors determine your NPRI reporting obligations, including:

  • the type of facility
  • the nature of its operations
  • the total number of employee hours worked

With these factors in mind, the NPRI has developed four cases for oil and gas facility reporting. These cases are listed below, and their reporting obligations are outlined the sections that follow. You can also use the flow chart included as Appendix A to help you determine the case that best matches your facility.

Case 1. Facilities where employees work 20,000 hours or more and facilities to which the 20,000-hour threshold does not apply

Facilities from any industry where the employees work a total of 20,000 hours or more during the calendar year are required to report to the NPRI for each Part 1 – 5 substance where the reporting criteria is met. Facilities in the oil and gas industry where employees typically work 20,000 hours or more, could be from any part of the industry: upstream, midstream or downstream. Some examples include:

  • large gas plants
  • refineries
  • oil sands mines and in-situ oil sands. Note: Information specific to in-situ oil sands is provided at the end of this section
  • offshore installations. Offshore installations include an offshore drilling unit, production platform or ship, or a subsea installation that is related to the exploitation of oil or natural gas and that is attached or anchored to the continental shelf of Canada or within Canada’s exclusive economic zone
  • other facilities that meet the 20,000-hour employee threshold

There are activities to which the 20,000-hour threshold does not apply, because, even with very few employees, your facility is likely to release significant quantities of NPRI substances.

A complete list of these activities is included in the Guide for reporting to the NPRI. For the oil and gas industry, the most relevant activity on this list is terminal operations. Terminal operations refer to either the use of storage tanks and associated equipment at a site used to store or transfer crude oil, artificial crude or intermediates of fuel products into or out of a pipeline; or the operating activities of a primary distribution installation, normally equipped with floating roof tanks, that receives gasoline by pipeline, rail car, marine vessel or directly from a refinery. Terminal operations do not include bulk plants or service stations.

If terminal operations or one of the other listed activities takes place at your facility, the same reporting requirements apply as the ones for facilities that meet the 20,000-hour threshold (in other words, you are required to report for each Part 1 – 5 substance where the reporting criteria is met).

Reporting on Parts 1 through 3 substances

Case 1 facilities are required to consider all sources of releases and report to the NPRI for each Part 1, 2 or 3 substance where the reporting criteria are met.

Please note that Case 2, 3 and 4 facilities do not report on these substances.

Reporting on Part 4 and Part 5 substances

There are seven Part 4 substances, and each has a reporting threshold, as listed in Table 1.

Table 1. Reporting threshold and stack release threshold for Part 4 substances
Substance Reporting threshold (tonnes) Stack release threshold (tonnes)
Carbon monoxide 20 5
Nitrogen oxides 20 5
PM2.5 0.3 0.15
PM10 0.5 0.25
Sulphur dioxide 20 5
Total particulate matter 20 5
Volatile organic compounds (VOCs) 10 5

Part 5 substances are speciated VOCs. These substances each have a 1-tonne reporting threshold.

Case 1 facilities must report Parts 4 and 5 substances based on quantities of air releases from all sources, as follows:

  • Part 4 substances: Release quantities must be reported for each Part 4 substance that meets the reporting threshold listed in Table 1. In addition, you are required to report releases from individual stacks with a height of 50 m or more above grade, for each Part 4 substance that meets the stack release threshold in Table 1
  • Part 5 substances: If 10 tonnes or more of Part 4 total VOCs were released, each Part 5 speciated VOC that was released in a quantity or 1 tonne or more must be reported. If less than 10 tonnes of total VOCs were released, no speciated VOCs need to be reported

The flow chart included as Appendix B provides a visual representation of the information included above regarding reporting on Parts 4 and 5 substances. Case 1 facilities should refer to the Guide for reporting to the NPRI for more comprehensive guidance on the NPRI reporting requirements that apply to these types of facilities.

Information specific to in-situ oil sands operations

In-situ oil sands are Case 1 facilities. This section clarifies how the NPRI’s facility definition applies to in-situ oil sands operations and how they must report underground releases.

How the NPRI’s facility definition applies

In-situ facilities extract bitumen or crude oil from underground using thermal or other methods. The facility includes a central processing plant that is connected by pipeline to one or more sets of injection and production wells (well pads). The central processing plant and well pads are considered to function as an integrated site because of the cyclic production process (that is, the central processing plant processes the bitumen or crude oil emulsion generated at the well pads and regenerates steam, solvent and/or polymers for the wells).

If the well pads and the central processing plant are owned or operated by the same company or parent company, they are considered contiguous for the purposes of reporting to the NPRI. The company must consider the wells and the central processing plant as a single facility in determining whether the 20,000-hour threshold is met and must report to the NPRI for both the activities at the wells and the central processing plant in a single report. Therefore, if substance thresholds are met, the reporting facility must report any quantities released to air, water and land (both underground and surface), disposed of or recycled for the facility as a whole (the central processing plant and the contiguous wells).

How underground releases must be reported

Case 1 facilities are required to report to the NPRI for each Part 1 – 5 substance where the reporting criteria is met. In terms of underground releases, you must report the total quantity of an NPRI substance that your facility injects underground but does not recover within the same calendar year (that is, the net quantity) at wells that are part of the contiguous facility. In the case of in-situ oil sands, underground releases of solvent are typically part of a cyclical process that involves recovery of some of the solvent along with the bitumen. The quantity of the substance recovered may possibly exceed the quantity injected within a given calendar year. If this is the case, a quantity of zero would be reported.  If, instead of being reused in the process, the solvent is disposed of or transferred off-site after being recovered from the bitumen, the substance must be reported accordingly (that is, as a disposal or transfer).

Tip for the online reporting system: If your facility meets the above conditions to report underground releases, you must report this quantity under the category “Releases to land – Other”. The nature of the release must be specified in the “Nature of other land release comments” field. For example, the comment could say: “The nature of the other releases to land is injection underground to enhance the recovery of bitumen.”

Case 2. For the oil and gas industry, generally only pipeline installations and compression equipment

In general, facilities from any industry that have less than 20,000 employee hours and have air releases from stationary combustion equipment have Case 2 reporting requirements. However, if the facility is in the oil and gas extraction sector [North American Industry Classification System (NAICS) code 211110] and is not a facility that solely consists of compression equipment, Case 3 or Case 4 reporting requirements may apply. Refer to the sections below for guidance specific to these types of facilities.

In the oil and gas industry, Case 2 facilities are generally only

  • pipeline installations – a collection of equipment situated at a single site, used in the operation of a natural gas transmission or distribution pipeline. This includes pipeline compressor and storage stations along pipelines used to transport both raw and processed natural gas
  • compressor stations – a facility where gas pressure is increased to overcome friction losses through a pipeline or pipe system or for underground natural gas storage. If a compressor station is part of a contiguous facility that includes equipment other than compression equipment (for example, that also contains a storage tank), Case 3 or Case 4 reporting requirements may apply

Tip for the online reporting system: Only if your facility is classified under NAICS 211110 and solely consists of compression equipment (for example, there are no storage tanks on-site), you must answer “Yes” to the question “Does the facility solely consist of compression equipment?” on the Facility information screen.

If your facility has previously reported to the NPRI, you must submit your report with the correct NPRI ID and the physical address location (i.e. land survey description or national topographic description). If you acquire any new facilities that have previously reported to the NPRI, be sure to obtain the NPRI ID from the previous owner/operator. Facilities must also report their Petrinex Facility IDs (if applicable) and all other provincial license or identification numbers.

Reporting on Part 4 and 5 substances

Case 2 facilities are only subject to the reporting requirements for Part 4 and 5 substances. The reporting thresholds are based on quantities of releases from stationary combustion equipment only, and you must report as follows:

  • Part 4 substances: Quantities released from stationary combustion equipment must be reported for each Part 4 substance that meets the reporting thresholds listed in Table 1. In addition, you are required to report releases from individual stacks with a height of 50 m or more above grade, for each Part 4 substance that meets the stack release threshold in Table 1
  • Part 5 substances: If 10 tonnes or more of Part 4 total VOCs were released from stationary combustion equipment, each Part 5 speciated VOC that was released in a quantity of 1 tonne or more (also from stationary combustion equipment) must be reported. If less than 10 tonnes of total VOCs were released, no speciated VOCs need to be reported

The flow chart included as Appendix B provides a visual representation of the information included above. Case 2 facilities should refer to the Guide for reporting to the NPRI for more comprehensive guidance on the NPRI reporting requirements that apply to these types of facilities.

Case 3. Facilities from the oil and gas extraction sector that have less than 20,000 employee hours and meet the threshold for at least one Part 4 substance

Starting in 2018, if a facility meets the following conditions, additional requirements apply for Part 4 and 5 substances:

  • has less than 20,000 employee hours
  • is classified under the NAICS code 211110 (oil and gas extraction except oil sands)
  • meets the reporting thresholds listed in Table 1 for at least one Part 4 substance based on stationary combustion sources
  • consists of more than just compression equipment (for example, also contains a storage tank)

Examples of facilities subject to Case 3 reporting requirements are as follows, all with stationary combustion equipment:

  • operating wells
  • gas gathering systems
  • small gas plants
  • batteries
  • glycol dehydrators

Tip for the online reporting system: If your facility meets the above conditions, you must answer “No” to the question “Does the facility solely consist of compression equipment?” on the Facility information screen. You must also answer “No” to the question “Does the facility have one or more light or medium crude oil batteries with a total oil throughput for the battery components of the facility of 1,900 m3 or more per year?” on the same screen.

If your facility has previously reported to the NPRI, you must submit your report with the correct NPRI ID and the physical address location (i.e. land survey description or national topographic description). If you acquire any new facilities that have previously reported to the NPRI, be sure to obtain the NPRI ID from the previous owner/operator. Facilities must also report their Petrinex Facility IDs (if applicable) and all other provincial license or identification numbers.

Reporting on Part 4 and 5 substances

Case 3 facilities are required to report releases of all seven Part 4 substances from all sources of air emissions (not just releases from stationary combustion sources). This requirement is sometimes referred to as “trigger one, report all.” Even if your facility meets the threshold for only one Part 4 substance, you are required to report for all seven Part 4 substances. The release quantity reported must reflect all sources of air emissions, even though the threshold is calculated based on stationary combustion sources only. If there are no releases of certain Part 4 substances, these substances must still be included in your report, but the quantity reported should be zero.

Note: The term “all sources of air emissions” refers to all sources of air releases of the substance, broken down into the following categories:

  • stack or point releases (for example, from stationary combustion, venting and flaring)
  • storage or handling releases (for example, from storage tanks, loading and unloading activities)
  • fugitive releases (for example, from equipment leaks)
  • spills
  • other non-point releases

In addition to reporting total stack or point releases, you are required to report releases from individual stacks with a height of 50 m or more above grade, for each Part 4 substance that meets the stack release threshold in Table 1.

Road dust releases are excluded for Case 3 facilities since they are generally not expected to meet the threshold of 10,000 vehicle-kilometers travelled. In addition, the normal exclusions (for example, articles and facility grounds maintenance) would still apply. See the Guide for reporting to the NPRI for more information.

For Part 5 substances, Case 3 facilities are required to report releases of benzene. If there are no releases of benzene, it must still be included in your report by reporting a zero quantity for this substance.

If less than 10 tonnes of total VOCs are released (Case 3A in diagram in Appendix B), then no Part 5 substances other than benzene need to be reported.

Additional Part 5 substances must be reported if the following two requirements are met (Case 3B in the diagram in Appendix B):

  • the facility releases 10 tonnes or more of Part 4 total VOCs from stationary combustion sources
  • the facility releases 1 tonne or more of the Part 5 substance from stationary combustion sources

The quantity reported for benzene and any other Part 5 substances should reflect all sources of air emissions, not just releases from stationary combustion.

Case 4. Facilities from the oil and gas extraction sector that have one or more batteries, have less than 20,000 employee hours and do not meet the threshold for any Part 4 substance

Starting in 2018, if a facility meets the following conditions, additional requirements apply for certain Part 4 and 5 substances:

  • has less than 20,000 employee hours
  • is classified under the NAICS code 211110 (oil and gas extraction except oil sands)
  • does not meet the reporting thresholds listed in Table 1 for any Part 4 substance, based on stationary combustion sources
  • has one or more light or medium crude oil batteries (that is, batteries that have crude oils with a density of less than 900kg/m3) with a total oil throughput for the battery components of the facility of 1,900 m3 or more per year. Oil throughput from non-battery components of the facility do not have to be included in the calculation of the throughput threshold

Tip for the online reporting system: If your facility meets the above conditions, you must answer “Yes” to the question “Does the facility have one or more light or medium crude oil batteries with a total oil throughput for the battery components of the facility of 1,900 m3 or more per year?” on the Facility information screen.

If your facility has previously reported to the NPRI, you must submit your report with the correct NPRI identification number and the physical address (including land survey description or national topographic description). If you acquire any new facilities that have previously reported to the NPRI, be sure to obtain the NPRI identification number from the previous owner/operator. Facilities must also report their Petrinex Facility IDs (if applicable) and all other provincial license or identification numbers.

Reporting on Part 4 and Part 5 substances

Case 4 facilities are required to report for the Part 4 substance VOCs and for the Part 5 substance benzene, regardless of whether the reporting thresholds listed in Table 1 are met. The quantity reported for these two substances should reflect air releases from storage tank sources. You should report the quantity for VOCs under the category “`Releases to air – Storage or handling releases” and the quantity for benzene under the category “Speciated VOCs – Other sources”. Storage tank releases must include releases from all types of storage tanks at the facility, in addition to hydrocarbon tanks. If there are no releases of VOCs or benzene from storage tanks, these substances must still be included in your report, but the quantity reported for storage releases should be zero.  A comment should also be included in your report to explain why zero is reported, for example if a Vapour Recovery Unit (VRU) is used.

For Case 4 facilities, benzene is the only Part 5 substance that you are required to report. Refer to Appendix B for an illustration of how Case 4 facilities must report Part 4 and Part 5 substances.

Exemption: Facilities involved only in drilling and exploration

If your facility is involved only in drilling and exploration, you are exempt from reporting to the NPRI. As such, no report is required for any NPRI listed substance that is manufactured, processed or otherwise used, incidentally manufactured, or released as a result of drilling or exploration activities.

Appendix A: Determining what reporting requirements apply to your facility
Long Description

This image is a flowchart that asks the reader a series of questions to determine if they have case 1, 2, 3, or 4 reporting requirements. There are five question boxes as follows.

The first question box asks, “Were the only activities that took place at the facility exploration for oil and gas or the drilling of oil or gas wells?” If you answer “yes” to the question in this box, you are not required to submit a report. If you answer “no”, you proceed to the second question box.

The second question box asks, “Did employees work a total of ≥ 20,000 hours during the calendar year? Or did terminal operations or other activities to which the employee threshold does not apply take place at the facility?” If you answer “yes” to either of the questions in this box, you have case 1 reporting requirements. If you answer “no” to both of the questions, you proceed to the third question box.

The third question box asks, “Was the only activity that took place at the facility the operation of compression equipment?” If you answer “yes” to the question in this box, you have case 2 reporting requirements. If you answer “no”, you proceed to the fourth question box.

The fourth question box asks, “Is the facility in the oil and gas extraction (except oil sands) sector (NAICS 211110)? And was at least one Part 4 substance released to air from stationary combustion equipment in a quantity ≥ its reporting threshold (see Table 1)?” Table 1 includes a list of Part 4 substances and their reporting thresholds. Nitrogen oxides, Sulphur dioxide, carbon monoxide, and total particulate matter have reporting thresholds of 20 tonnes. Volatile organic compounds has a reporting threshold of 10 tonnes. Particulate matter 10 has a reporting threshold of 0.5 tonnes. Particulate matter 2.5 has a reporting threshold of 0.3 tonnes. If you answer “no” to either of the questions in this box, you proceed to the fifth question box.  If you answer “yes” to both of the questions, you have case 3 reporting requirements and are asked the sub-question “Were ≥ 10 tonnes of Part 4 total VOCs released?”. If you answer “yes” to this sub-question, you have case 3a reporting requirements. If you answer “no” to this sub-question, you have case 3b reporting requirements.

The fifth and final question box asks, “Does the facility have one or more light or medium crude oil batteries with an annual oil throughput of ≥ 1,900 m3?” If you answer “yes” to the question in this box, you have case 4 reporting requirements. If you answer “no” to this question, you are not required to submit a report.

Appendix B: Determining how to report Part 4 and Part 5 substances
Long Description

This image is a flowchart that describes to the reader how to report Part 4 and Part 5 substances for case 1, 2, 3, and 4 reporting requirements. The flowchart is organized like a table that has 5 columns. The title of the first column is “reporting requirements” and includes separate rows for case 1, case 2, case 3 and case 4. The title of the second column is “Basis of threshold calculations for Part 4 and Part 5 substances”. The title of the third column is “Part 4 substances that must be reported” and makes reference to Table 1. Table 1 includes a list of Part 4 substances and their reporting thresholds. Nitrogen oxides, Sulphur dioxide, carbon monoxide, and total particulate matter have reporting thresholds of 20 tonnes. Volatile organic compounds has a reporting threshold of 10 tonnes. Particulate matter 10 has a reporting threshold of 0.5 tonnes. Particulate matter 2.5 has a reporting threshold of 0.3 tonnes. The title of the fourth column is “Part 5 substances that must be reported”. The title of the sixth and final column is “Sources of Part 4 and Part 5 substances that must be reported”.

If you select case 1 from the column “reporting requirements”, the second column describes that you must base your threshold calculations on quantities of releases from all sources. The third column describes that you must report release quantities for each part 4 substance that meets the reporting threshold in Table 1. The fourth column describes that if ≥ 10 tonnes of total VOCs were released, you must report each part 5 substance that was released in a quantity of ≥ 1 tonne. If < 10 tonnes of total VOCs were released, you do not need report any part 5 substances. The fifth column indicates that you must report all sources.

If you select case 2 from the column “reporting requirements”, the second column describes that you must base your threshold calculations on quantities of releases from stationary combustion sources only. The third column describes that you must report release quantities for each part 4 substance that meets the reporting threshold in Table 1. The fourth column describes that if  ≥ 10 tonnes of total VOCs were released, you must report each part 5 substance that was released in a quantity of  ≥ 1 tonne. If < 10 tonnes of total VOCs were released, you do not need to report any part 5 substances. The fifth column indicates that you only need to report stationary combustion sources.

If you select case 3 from the column “reporting requirements”, the second column describes that you must base your threshold calculations on quantities of releases from stationary combustion sources only. The third column describes that if the threshold in Table 1 is met for at least one part 4 substance, you must report release quantities of all part 4 substance. The fourth column describes the part 5 substances that need to be reported for case 3a and case 3b facilities. For case 3a facilities, if ≥ 10 tonnes of total VOCs were released, you must report each part 5 substance that was released in a quantity of ≥ 1 tonne. And you must report releases of benzene, regardless of quantity. For case 3b facilities, if < 10 tonnes of total VOCs were released, you must report releases of benzene, regardless of quantity. You do not need to report any other part 5 substances. The fifth column indicates that you must report all sources of air emissions.

If you select case 4 from the column “reporting requirements”, the second column describes that you must base your threshold calculations on quantities of releases from stationary combustion sources only. The third column describes that if no thresholds in Table 1 are met for any part 4 substance, you must still report release quantities of total VOCs. The fourth column describes that you must report releases of benzene, regardless of quantity. You do not need to report any other part 5 substances. The fifth column indicates that you only need to report storage tank sources.

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