Air Emissions Reporting from the oil & gas sector in Western Canada - keeping on top of it all
If you are responsible for air emissions reporting in Canada, you are likely struggling to keep on top of all the regulations and their demands – including data gathering, emissions measurement & estimation, and reporting.
How can oil & gas companies cost effectively manage all the air emissions regulations and corresponding requirements?
On one hand, compliance with air emissions regulations can be very onerous and difficult, and in some cases, technology and solutions are just being developed to help companies manage emissions and the required reductions. For various reasons, it has been a challenging environment for oil and gas companies in Western Canada, and it can be difficult for many companies to come up with the capital to invest in the projects necessary to reduce emissions. In addition, there are a broad range of regulations, each complex and often with very different data requirements, methodologies for emissions estimation, and reporting requirements.
However, these rules are kick-starting innovation in technology and software to assist in measuring, managing and reducing emissions (see CBC News). The Methane Emissions Leadership Alliance is one group (of which Process Ecology is a founding member) which is helping to promote the solutions that will help Canada meet its commitment to emissions reduction.
Furthermore, Western Canada is one of the most progressive reporting regimes in the world – its energy industry is at the forefront of emissions management, which is progressively becoming more important as energy companies are being held to a higher environmental standard not only from environmental NGOs but also from their boards and shareholders. In theory, this should allow the oil and gas companies in Canada to take a lead in the sustainable development of energy resources and become more globally competitive. At the same time, it appears that the Canadian industry is under much more scrutiny than other regimes, so it remains to be seen if this becomes a competitive advantage.
These are some of the key air emissions regulations that oil and gas companies in Western Canada are managing:
- Alberta Energy Regulator (AER) Directive 39 (also BC and Saskatchewan regulations): Benzene in Dehydration/Refrigeration facilities
- AER Directive 60 (also BC, SK and Federal regulations): Methane and fuel/flare/vent reporting
- Provincial and Federal Greenhouse Gas Emissions regulations
- Federal Pollutant Inventory (NPRI)
- Multi-sector Air Pollutant Regulations (MSAPR): NOx from compressor engines, heaters and boilers
- Air Monitoring Directive (AMD): new annual reporting (Sep 30)
Process Ecology has published many articles outlining key changes to these regulations (including this update). There continue to be ongoing changes, both in the regulation requirements and timelines, requiring companies to closely review and understand these changes.
This leads us to the key question - how can companies cost effectively manage all these air emissions regulations and corresponding requirements?
1. Company Alignment. First, within oil and gas companies, air emissions management is no longer just the domain of the health, safety and environment (HSE) professional. Everyone from top management to HSE, to operations, engineering and production accounting need to be aligned. It is critical for company management to set the company direction and be aware of the impact of emissions reduction on the company. Operations is at the front line, and is critical to accurate reporting of field data used for emissions reporting. Engineering is critical to coordinating projects related to emissions reduction. For methane emissions regulations in particular, coordination with production accounting is critical in accurately reporting fuel, flare and vent emissions.
2. Data Gathering Consolidation. Companies need to be aware of all of the air emissions reporting requirements, and ensure that data gathering processes are continuously consolidated to minimize data requests going out to operations. While all the emissions regulations have a different focus, there is also much overlap; for example, dehydration emissions calculated for benzene regulations can also be used for methane, GHG and NPRI reporting. Compressor engine NOx emissions are a key focus of the MSAPR regulations, and many other regulations (NPRI, GHG, AMD) also require compressor engine data to estimate corresponding emissions.
3. Access to Expertise. It can be very difficult, especially for small to midsize companies, to be knowledgeable in every aspect of air emissions reporting. Companies like Process Ecology, which provide emissions expertise, software solutions and engineering knowledge, can help companies to comply with emissions regulations as well as find the most cost-effective opportunities for the emissions reductions demanded by these regulations. Furthermore, the experience and software developed for specific problems can generally be applied to all clients, helping to reduce the overall costs for everyone.
4. Software Tools. The data requirements are becoming more complex, spread across facilities in the organization, as well as requiring multiple types of reporting for the same facilities. Efficiency can be significantly improved, and errors can be minimized, through utilization of software tools which automate the import of data, calculation, and export of data for reporting.
5. Leveraging Data for Optimization. A significant amount of data is obtained to estimate emissions, and this same information can also be used to find opportunities to optimize processes and reduce emissions. The combination of regulatory and engineering knowledge is essential in determining the most cost-effective and efficient emissions-reduction opportunities.
In short, what is required is a consolidated system which allows interaction with various stakeholders, brings in data from many sources, performs the calculations using an engine which manages all of the emissions estimation methods, and finally stores the data in a centralized database which is accessible to all. This is conceptualized in the following figure:
Even though air emissions reporting is more complex and demanding than ever before, companies can cost-effectively mange all of these air emissions regulations, and thrive in the new regulatory environment.
For more information, see http://processecology.com/projects/air-emissions-reporting-our-approach.