Changes to Directive 060: What Alberta’s Upstream Petroleum Producers Need to Know

On October 24, 2024, the Alberta Energy Regulator (AER) released a draft update to Directive 060, the Upstream Petroleum Industry Flaring, Incinerating, and Venting regulation. This update is part of Alberta’s Red Tape Reduction Implementation Act, and aims to:

Reduce administrative processes
Simplify and consolidate regulatory requirements
Implement recommendations from the Methane Emission Mitigation Policy Working Group

Here is a summary of key changes and what producers need to know for emissions management and compliance.

Major Updates at a Glance

New Emissions Research and Innovation Section – Introduces requirements related to emissions testing facilities.
Geothermal and Other Operations – Extends Directive 60 requirements to geothermal, brine-hosted materials, and helium operations.
Reference to CSA Standards – References CSA Z620.3 performance requirements, including specifications for residence time, exit temperature, design, and conversion efficiency.
Expanded Alt-FEMP Options – Offers more flexibility for alternative fugitive emissions management programs (Alt-FEMPs).
Clarification on Vent Gas and Flare Gas Definitions – Updates definitions and control requirements for waste gas.
Combustion Requirements for Non-Routine Events – Extends Section 3 combustion requirements to all non-routine events, not only well tests.
Updated Flare Gas Definition – Broadens “flare gas” to include waste gas destroyed in any control device and defines “flare stack” as a device with an open visible flame.
Enclosed Combustion Clarifications – Adds references and guidance on enclosed combustion alongside flaring and incineration.
Significant Content Consolidation and Reorganization – Consolidates content, moving appendices into the main body, and updates section, figure, table, and appendix numbering.

Detailed Breakdown of Key Sections for Compliance

While different readers may focus on different sections of Directive 060, this article focuses on items specifically related to emissions management and compliance:

Section 5: Emissions Research and Innovation - Introduces industry collaboration on research to improve emissions detection and combustion efficiency.
Sections 8.3 and 8.4: Updated Vent Gas Requirements - Sets new conservation and destruction requirements for vented gas with updated compressor seal standards.
Section 8: Expanded Alt-FEMP Options - Increases flexibility for fugitive emissions management programs, with performance-based standards for detection technology.

1. Section 5: Emissions Research and Innovation

This section could likely be thought of as the “NGIF West Wolf” clause (related to the well-known Tourmaline/Perpetual test facility), and states:

“The AER expects that industry will support and participate in continued research focusing on:

understanding the relationship between gas composition and combustion efficiency, including the effects of H2S content;
understanding the effects of flare stack design, including flare tips on combustion efficiency;
reviewing the results of any field testing of combustion efficiency monitoring methodologies;
improving estimates of the amounts of methane emitted; and
testing new technologies for emissions detection and reduction.”

There are a number of requirements documented in this section, with some clarification regarding allowable emissions test volumes. Test facilities could include the use of mobile test equipment utilized by organizations such as the Saskatchewan Research Council. It is also noted that this section mandates sharing research results with the AER.

For further information, refer to Section 5 of the draft or contact the AER methane team.

Section 5 Changes Summary
The new Emissions Research and Innovation section encourages industry collaboration in research focused on improving emissions detection, estimating methane emissions, and testing advanced technologies. Producers are expected to:
Participate in field testing for methane monitoring and technology innovations.
Share research findings with the AER to support regulatory advancements.

2. Section 8: Updated Vent Gas Requirements

Sections 8.3 and 8.4 now state that the overall vent gas (OVG) and defined vent gas (DVG) limits are maximum cumulative vent volumes and not acceptable vent rates (15 e3m3 and 3 e3m3).

Section 8.4.3 clarifies that conservation is the best alternative to reduce flare and vent volumes, followed by combustion. If gas vent rates or volumes are sufficient to be combusted, the gas must be conserved or destroyed. It is also noted that the AER may investigate vent rates or volumes as low as 300 m3/day if it appears that the vent gas could be controlled.

When managing a noncombustible gas mixture that cannot be conserved, the duty holder must choose the control method that minimizes the amount of carbon dioxide equivalent (CO2e) being released.

The duty holder must ensure a qualified person evaluates the resulting CO2e emissions from the release of noncombustible gases as a vent as compared to a combustion event (flare, incineration, enclosed combustor) applying equations that are published by the manufacturer or using engineering estimates that are published and accepted for current industry emission reporting practices.
The calculated emissions of nitrous oxide and methane resulting from a combustion event must be converted to a CO2e value using the global warming potential values as required by the Technology Innovation and Emissions Reduction (TIER) Regulation.

Additionally, compressor seal rate measurements have been adjusted to clarify that the +-10% uncertainty applies for volumes greater than 0.7 m³/hr (from 0.1 m3/hr).

Summary
The updated requirements for overall vent gas (OVG) and defined vent gas (DVG) emphasize conservation and require operators to:
Conserve or destroy vented gas if volumes exceed set thresholds (15 e3m3 OVG, 3 e3m3 DVG).
Use control methods with the lowest CO₂ equivalent (CO₂e) release for noncombustible gases.
Apply updated compressor seal testing standards, increasing the +-10% uncertainty limit from 0.1 m³/hr to 0.7 m³/hr.

3. Section 8.10: Expanded Alt-FEMP Options

Now that the AER has several years of experience with Alt-FEMP, the section in Directive 060 describing this option has been significantly expanded. Since Alt-FEMP was introduced, there were about 30 Alt-FEMP applications, with 15 currently identified as “Active” (these are published on the AER website here). A technical report issued September 2024, entitled “Alternative Methane Detection Technologies Evaluation” authored by Highwood Emissions Management provides a summary of the modelling that was done to support guidance added to this section.

Both mobile and stationary emission detection technologies are referenced in Section 8, and tables are provided that document the minimum detection thresholds for these technologies.

Mobile Emissions Detection Technology: a technology that is moved around or at a site for less than 730 hours per calendar year and has a minimum detection threshold and probability of detection.
Stationary Emissions Detection Technology: a continuous methane detection technology that is stationary or at a site for greater than 730 hours per calendar year and has a minimum detection threshold and probably of detection.

For stationary emissions measurement, the follow-up criteria may not require a survey and allow for the use of the emissions screening equipment. Follow-up requires reviewing emissions data at a set interval, with large emission follow-up within 30 days for sources that sustain 500 m3/d over 24 hours.

An Alt-FEMP program may not require approval if the technology meets a documented minimum detection threshold (MDT) with a probably of detection (PoD) of 90%:

MDT is defined as the smallest release rate of methane a technology can detect, typically described as kg methane/day
PoD is defined as the likelihood that a technology can detect an emission, given variables like release rate, wind speed, and distance from measurement to source. This is typically visualized as a logistic regression curve.

It is noted that the AER is attempting to provide general standards without prescribing specific technologies (as done by other regulators, such as EPA).

A key definition term used is “Emissions Detection Follow Up,” which means an emissions investigation to identify the source of an emission, verified with emission detection technology or a fugitive emissions survey. This is where plant data monitoring systems could potentially be used to evaluate SCADA/historian data with the objective of identifying and mitigating root causes.

Summary
The AER now offers a wider range of acceptable Alt-FEMP options to manage fugitive emissions. With this change:
Producers can choose mobile or stationary detection technologies that meet minimum detection thresholds (MDT) and probability of detection (PoD) standards.
Mobile technologies are defined as being on-site for less than 730 hours annually, while stationary technologies remain for longer periods.
Follow-up on emissions within 30 days will be required for sources exceeding 500 m³/day.
The AER has avoided prescribing specific technologies, instead setting general performance standards that allow operators flexibility in their approach.

Provide Your Feedback
Feedback on the draft update is due by November 24, 2024 and can be submitted by producers by filling out a public comment form on the AER website that can be found here. Industry groups such as the Canadian Association of Petroleum Producers (CAPP) and Methane Emission Leadership Alliance (MELA) are expected to submit feedback.

Next Steps for Producers

Significant changes in Directive 060 provide new opportunities and challenges in emissions management. As this summary is not comprehensive, producers should review the full draft and consider how these updates will impact their operations.

Of particular importance in the recent changes is Section 8, which introduces significant flexibility for managing fugitive emissions programs. Producers can now opt for either mobile or fixed continuous monitoring technologies. Moving forward, evaluating the causes of emissions leak events will be essential, and plant data monitoring systems can be valuable tools in this process.

Process Ecology is here to help. Reach out to our team if you have questions about how these changes affect compliance and emissions management practices.