Saskatchewan Emissions Requirement Changes 2024-2025

As the year draws to a close, we aim to help our clients stay informed and ready for the regulatory changes taking effect in 2025. Saskatchewan introduced updated regulations earlier this year, many of which will come into force starting January or April 2025. Below is a summary of Directive PNG036 Venting and Flaring requirements which would affect many companies with operations in Saskatchewan.  

Directive PNG036 Venting and Flaring Requirements

Revision 4.0 issued March 2024

Came into force on March 8, 2024

Summary:

Directive PNG036 Venting and Flaring Requirements were reissued in March 2024 and include:

• Reduced venting limits for existing oil wells and oil facilities, effective April 1, 2025
• Reduced venting limits for new oil wells and oil facilities, effective January 1, 2025
• A prohibition on venting natural gas from pneumatic devices at facilities licensed on or after January 1, 2025
• A requirement to submit inventories of natural gas driven pneumatic devices installed at existing facilities; initial annual report is due by April 1, 2025
• A phase-out schedule to reduce natural gas venting from pneumatic devices at existing facilities, with 100% reduction by end of 2028
• Further to existing requirements for gas facilities, semi-annual leak detection surveys are also required at oil facilities and compressor stations effective January 1, 2025
• Leak detection surveys are required three times annually, effective January 1, 2027

Updated Venting Requirements

Section 6.1 Venting Limit at Existing Oil Wells and Facilities

Unless the gas is vented to avoid serious risk to human health or safety arising from an emergency situation, the following limits apply:

Effective April 1, 2025, oil wells and oil facilities licensed prior to January 1, 2025 that vent and flare a combined volume of gas greater than a daily average of 500 m³/day on a monthly basis must flare all non-conserved volumes of gas.  <<< Reduction from 900m³/day >>>

In the course of properly operating equipment according to the manufacturer's instructions, gas may be vented from:

• The seals of a centrifugal compressor or from the rod packings and distance pieces of a reciprocating compressor;
• Pneumatic devices; or
• Flashing losses and breathing losses from storage tanks operating at low pressures
  
  

Section 6.2 Venting Limit at New Oil Wells and Facilities

Unless the gas is vented to avoid serious risk to human health or safety arising from an emergency situation, or pressures or flow rate do not allow for the continued operation of properly installed destruction or conservation equipment, the following limits apply:

Oil wells and oil facilities licensed on or after January 1, 2025 that vent and flare a combined volume of gas greater than a daily average of 100 m3/day for any three-month consecutive period must flare all non-conserved volumes of gas.

In the course of properly operating equipment according to the manufacturer's instructions, gas may be vented from:

• The seals of a centrifugal compressor or from the rod packings and distance pieces of a reciprocating compressor;
• Flashing losses and breathing losses from storage tanks operating at low pressures.

Venting from pneumatic devices is not included.

Compressor Seal Vents (no change)

• at Gas Wells and Gas Facilities
• at Oil Wells and Oil Facilities 

In the course of a properly operating equipment according to the manufacturer's instructions, has may be vented from:

• The seals of a centrifugal compressor or form the rod packings and distance pieces of a reciprocating compressor;

Subject to vent limits in sections 6 and 7.

Storage Tank Venting at Oil Wells and Oil Facilities (no change)

In the course of properly operating equipment according to the manufacturer's instructions, gas may be vented from:

• Flashing losses and breathing losses from storage tanks operating at low pressures

Subject to vent limits in section 6.

Gas-Driven Pneumatic Devices 

powered by pressurized gas , including pneumatic pumps and pneumatic instruments
 (e.g., controllers, switches, transducers, and positioners)

Section 11.1  New Facilities

Licensees must not vent natural gas from pneumatic devices at facilities licensed on or after January 1, 2025.

Section 11.2  Existing Facilities

As of January 1, 2025, licensees must maintain an inventory of natural gas driven pneumatic devices installed at existing facilities.

In accordance with the timelines specified in the table below, licensees must reduce either:

• the total annual vented natural gas volumes from pneumatic devices at facilities licensed prior to January 1, 2025; or
• the total number of pneumatic devices venting natural gas at facilities licensed prior to January 1, 2025.  

Section 11.3 Exemptions

If a pneumatic device that vents natural gas is needed to maintain safe operating conditions and no non-emitting alternatives exist, the pneumatic device is exempt from the requirements in sub-sections 11.1 and 11.2. The licensee must demonstrate that venting is required to maintain safe operations. Exempt devices must be identified with a visible tag.

Section 11.4  Annual Reporting

Companies must submit a report annually for the purpose of establishing corporate-level natural gas driven pneumatic inventories to demonstrate compliance with the reduction requirements in section 11.2.

Companies must submit an initial annual report by April 1^st, 2025.

Revised Leak Detection and Repair Requirements

Section 8.1 Applicable Facilities

LDAR surveys must be completed at applicable facilities that produce or receive, or are expected to produce or receive, a combined volume of more than 60 103m3 of gas annually.

Facilities that vent all produced gas are exempt from LDAR survey requirements.

Prior to January 1, 2025:

Effective January 1, 2025 (in addition to gas facilities listed above):

Effective January 1, 2027, leak detection surveys are required three times annually for all facility types which previously required semi-annual leak detection surveys.

Next Steps for Producers

These significant changes to the Saskatchewan regulations provide new opportunities and challenges in emissions management. Producers should go through the full draft to fully understand these changes and assess their implications for operations, as this summary is not all-encompassing.

Reach out to our team if you have questions about how these changes affect compliance and emissions management practices at info@processecology.com