Oil and gas industry: guide to reporting

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 are 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	10
Nitrogen oxides	20	10
PM2.5	0.3	0.25
PM10	0.5	0.5
Sulphur dioxide	20	25
Total particulate matter	20	25
Volatile organic compounds (VOCs) total	10	5

Part 5 substances are speciated VOCs. These substances each have a 1-tonne reporting threshold and a 0.25 tonne stack 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 25 m or more above grade, for each Part 4 substance that meets the stack release threshold in Table 1
• Part 5 substances: Each Part 5 speciated VOC that was released in a quantity or 1 tonne or more must be reported. In addition, you are required to report releases from individual stacks with a height of 25 m or more above grade, for each Part 5 substance that meets the stack release threshold of 0.25 tonnes

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.”

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 25 m or more above grade, for each Part 4 substance that meets the stack release threshold in Table 1
• Part 5 substances: Each Part 5 speciated VOC that was released in a quantity of 1 tonne or more from stationary combustion equipment must be reported. In addition, you are required to report releases from individual stacks with a height of 25 m or more above grade for each Part 5 substance that meets the stack release threshold of 0.25 tonnes

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.

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 you must indicate that there are no on-site releases of the substance.

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 tank and related handling releases (for example, from storage tanks, loading and unloading activities)
• fugitive releases (for example, from equipment leaks)
• spills or other accidental releases
• other non-point releases (facilities reporting under this category are required to provide a comment specifying the nature of the release)

Case 3 facilities do not have additional reporting requirements for individual stacks.

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) 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, regardless whether the facility releases more than 1 tonnes or not. The quantity reported for benzene should reflect all sources of air emissions, not just releases from stationary combustion. If there are no releases of benzene, it must still be included in your report, but you must indicate that there are no on-site releases.

Additional Part 5 substances must be reported if:

• the facility releases 1 tonne or more of the Part 5 substance from stationary combustion sources

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

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 (total) 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 (total) under the category “`Releases to air – Storage tank and related 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 (total) or benzene from storage tanks, these substances must still be included in your report, but you must indicate that there are no on-site relases of the substance. A comment should also be included in your report to explain why no releases are 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.

Case 4 facilities do not have additional reporting requirements for individual stacks.

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.

Note that the following flowchart is intended to assist oil and gas facilities in determining which reporting requirements apply. For all other types of facilities, refer to the Guide for reporting to the NPRI for assistance in determining reporting requirements.