Multi Sector Air Pollutant Regulations – What is new for the Oil and Gas industry in Western Canada

Environment and Climate Change Canada (ECCC) states:

“The Regulations implement a subset of the Base Level Industrial Emission Requirements (BLIERs) that have been developed under the Air Quality Management System (AQMS)"

Purpose: Nationally consistent air pollutant emission standards for nitrogen oxides (NOx) and sulphur dioxide (SO2) from the cement sector and from the boilers, heaters and stationary spark-ignition engines that are used in several industrial sectors at a level that is consistent across the country.”These regulations will apply to upstream oil and gas and oil sands in the following areas:•Large new and existing boilers and heaters that burn gaseous fossil fuels, such as natural gas. Ongoing emission testing and reporting will be required for the larger boilers and heaters (>105 GJ/hr). There is a transitional period of up to three years to ease financial impacts during which some equipment will be required to meet NOX emission intensity limits that are less stringent than equipment that is installed after the transitional period.•New and existing stationary engines at facilities. Compliance with the NOX requirements for existing engines can be achieved on a per engine basis or based on the average of the annual emissions of all of a company’s engines. Engine registration and ongoing emission testing and reporting will be required.

Boilers & Heaters

Only for boilers and heaters larger than 10.5 GJ/h (9.95 MMBtu/h).

ECCC states:

“The performance standards in the MSAPR depend on several factors:

• Whether the equipment is existing (called “pre-existing” in the MSAPR), redesigned, transitional, or new (called “modern” in the MSAPR)
• Whether it is a boiler or a heater
• The type of fuel it combusts (i.e. either natural gas or alternative gas)
• For a heater, the amount of air preheat
• For a boiler, its efficiency

The performance standards range from 16 grams of NOX per gigajoule of energy input (g/GJ) for a new boiler or heater that burns natural gas and has an efficiency of 80%, to 40 g/GJ for a large transitional boiler.”

The details of the calculations are complex as a result of the above factors, so we recommend that if you have a large Boiler or Heater (>10.5 GJ/h), ensure that you have registered it with ECCC and that you consult to determine what reporting and measurement you are required to do. Deadline to do your initial classification and registration could be as early as June 17, 2017.

Stationary Spark-Ignition Engines

If a modern engine (manufactured after Sept 15 2016), 75 kW or larger was operated for at least one hour in 2016, the owner or operator must use a spreadsheet developed by ECCC (pursuant to Section 120(1) of the Regulations) to:

1. Register these engines by July 1^st 2017 as set out in Schedule 9; and
2. Provide one compliance report for all of these engines by July 1^st 2017 as set out in Schedule 10.

If you have an older pre-existing engine, 250 kW or larger, the first date you are required to register it by is January 1, 2019 (although it could be earlier).

The registration will need to be accompanied by a compliance report in respect of NOx emissions. Thus, planning and cataloging all engines prior to the middle of 2018 is recommended to allow time for testing of units that are not fitted with CEMS.

More Info

• Government overview document: http://www.ec.gc.ca/lcpe-cepa/default.asp?lang=En&n=FEA2BB78-1
• Ensure you get on the Environment Canada mailing list for MSAPR : email them at: ec.nge-mgn.ec@canada.ca
• Visit the website to see the full regulation: http://laws-lois.justice.gc.ca/eng/regulations/SOR-2016-151/index.html

How we can help

If you need help in determining which equipment fall under the new MSAPR regulations, please call or email us: 403-313-8931 or info@processecology.com