Bulletin 2009-44

Bulletin 2009-44: Reminder of the January 1, 2010, Fugitive Emissions Program Effective Date

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Reminder of the January 1, 2010, Fugitive Emissions Program Effective Date

Dec 16, 2009

The Energy Resources Conservation Board (ERCB) Directive 060: Upstream Petroleum Industry Flaring, Incinerating, and Venting (November 2006) contains the requirements for fugitive emissions management in Section 8.7. These requirements resulted from the work of a Clean Air Strategic Alliance (CASA) multistakeholder team in 2004.

The ERCB will be ensuring compliance with the requirements in Section 8.7 of Directive 060 effective January 1, 2010. These requirements will be interpreted as follows:

Enforcement Items

Section 8.7: Fugitive Emissions Management reads:

1) Operators must develop and implement a program to detect and repair leaks.

Noncompliance with this requirement is assessed as High Risk: Failure of the operator to develop and implement a fugitive emissions program to detect and repair leaks.
To be considered a “program,” the following must be met:

  • The program must be implemented at the facility to detect and repair leaks. “Facility” includes all facilities requiring a licence under Directive 056: Energy Development Applications and Schedules.
  • The program must address leak repairs within the timeframe required. Simple repairs must be done in 45 days; repairs requiring a major shutdown (complex repairs) must be done during the next shutdown.
  • Repairs that meet the economic test in the Canadian Association of Petroleum Producers (CAPP) Best Management Practice for Fugitive Emissions Management must be made.

Section 8.7 item (1) further states:

a) These programs must meet or exceed the CAPP Best Management Practice for Fugitive Emissions Management.

Noncompliance with 1(a) is assessed as Low Risk: Failure of the fugitive emissions program to meet the CAPP Best Management Practice for Fugitive Emissions Management:

  • Components are not being monitored with the minimum frequency provided in Appendix 1 of the CAPP Best Management Practice for Fugitive Emissions Management or the company is unable to show that based on historical data at the facility, including surveys or other credible facility-specific operating data, a lower or higher frequency is warranted.
  • Leaking components have not been identified and/or record keeping does not meet minimum information recommended in Appendix 3 of the CAPP document. This would include records of repairs of leaking components, including leak repair frequency.

Further Information

Directive 060 is available from ERCB Information Services, 640 – 5 Avenue SW, main floor; telephone: 403-297-8311; fax: 403-297-7040; e-mail: infoservices@ercb.ca. The directive is also available on the ERCB Web site www.ercb.ca.

CAPP’s Best Management Practice for Fugitive Emissions Management is available at www.capp.ca under Library & Statistics : Publications : Policy and Regulatory.

If you have any questions regarding this bulletin, you may contact Al Duben at 403-588-2272 or Jim Spangelo at 403-297-3566 or send an e-mail to fugitives@ercb.ca.

<original signed by>

Dwayne Waisman, B.E.S., C.E.T.
Executive Manager
Field Surveillance and Operations Branch