Proposed regulatory framework for reducing oil and gas methane emissions to achieve 2030 target
The Government of Canada is proposing to amend the existing federal regulations for methane emissions from the oil and gas sector in order to achieve at least a 75% reduction in oil and gas methane by 2030 relative to 2012.
The proposed amendments would achieve this goal by expanding the scope of the existing regulations to apply to a wider set of sources, eliminating exclusions, and driving as many individual sources as possible toward zero emissions:
- Expanding application of the regulatory measures to apply to virtually all facilities potentially handling natural gas;
- Minimizing compliance through combustion, while ensuring that all combustion systems operate at maximum efficiency to address potential methane emissions;
- Expanding the application and intensity of inspection programs, including non-producing assets;
- Requiring non-emitting equipment when feasible;
- Including temporary activities in facility emission ceilings, and lowering these limits to absolute minimum levels; and
- Developing a comprehensive, nationally-consistent emission monitoring and reporting system.
Proposed Source-by-Source Approach
Hydrocarbon Gas Conservation and Destruction Equipment
- Destruction equipment would be required to operate at a 99%+ control efficiency;
- Conservation equipment would be required to operate at 98%+ efficiency; and
- Fuel combustion would be required to meet a 95% control efficiency.
- Would be prohibited at oil sites;
- Enclosed combustion methods and equipment would be required to have an auto-igniter; and
- Operators would be required to ensure that equipment is working as intended.
General Facility Venting and Flaring
- Would no longer be bound by conditional requirements. All oil facilities exceeding a 5 m3/day (combined flare + vent volume) threshold would be required to eliminate venting by complying with only gas conservation requirements; and
- Surface casing vents would be controlled by conservation or destruction.
- Would no longer be bound by conditional requirements. All pneumatic pumps and controllers at oil and gas facilities would be required to be non-emitting or captured.
- Would no longer be bound by conditional requirements. All facilities would be required to have a fugitive emission management plan with monthly inspections; single wellhead sites included;
- Once a suspected leak is detected, the operator would be required to confirm and fix the leaking component immediately or if not feasible, within 30 days; and
- An extension repair request in extreme circumstances could be granted by the Minister.
Compressor Engine Exhaust
- Compressor engines would be required to achieve complete combustion and reliable ignition;
- Methane emissions at these engines would not exceed 1 g/kWh methane; and
- Smaller compressors would be included in vent limits.
- Fugitive management, pneumatic device and blowdown rules would be applied.
- Hydrocarbon emissions associated with planned pipeline blowdown activities would be controlled by routing gas to a capture system for beneficial use, destruction or by implementing practices that re-route or avoid the need to blowdown gas. In certain cases, a company's alternative approach that achieves equivalent reductions may be considered.
- Annual inspections for methane emissions; any detected emissions would require measurement. A record of these inspections and any subsequent measurements would need to be kept by the responsible party; and
- Operators could decide to opt-in to a site-specific demonstration of equivalent methane outcomes supported by verified and approved continuous monitoring systems.
- Would be required to reduce emissions by at least 95% or emissions would have to be captured.
- Unloading activities would be required to use capture and recovery techniques or install and use a control device to achieve at least 95% control of hydrocarbon emissions during well liquids unloading events.
The key to effective performance-based regulation is understanding actual emissions and incorporating standard emissions monitoring methods, with comprehensive recordkeeping and reporting requirements, such that sufficient information is available to verify compliance and demonstrate Canada's progress in meeting climate commitments.
The existing methane regulations include some performance-based requirements, including maximum emission limits for venting from facilities, and alternative leak detection and repair approaches. Extending these concepts could allow for near-continuous monitoring of all methane emissions at a facility-level. ECCC is investigating the feasibility of adding specific program parameters to allow an opt-in provision for this approach.
The requirements would be regulated under the Canadian Environmental Protection Act, 1999 (CEPA). Equivalency agreements are possible under CEPA.
The Government of Canada is inviting interested stakeholders to provide their feedback on the Proposed Regulatory Framework until December 12, 2022. Feedback can be sent to firstname.lastname@example.org .
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