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The Ministry of Energy and Resources in Saskatchewan has introduced important updates to its regulations governing greenhouse gas (GHG) emissions in the upstream oil and gas industry (Directive PNG036).
These updates emphasize the importance of Leak Detection and Repair (LDAR) inspections and the collection of pneumatic device inventories, which play a critical role in cutting methane emissions and supporting Saskatchewan’s Methane Action Plan. Here’s an overview of these new requirements and their implications for the industry.
LDAR Inspections: Strengthening Emission Control
Applicable Facilities
Starting January 1, 2025, LDAR requirements will be mandatory for oil and gas facilities that produce, receive, or are expected to produce or receive over 60,000 m³ of gas each year. This includes Single-Well and Multi-Well Gas Batteries, Sweet and Sour Gas Plants, Straddle and Fractionation Plants, and Gas Gathering Systems. The inclusion of oil facilities marks a notable expansion in Saskatchewan’s LDAR regulations.
Inspection Frequency
Beginning on January 1, 2025, all relevant oil and gas facilities must undergo LDAR inspections twice a year. By January 1, 2027, the inspection frequency will increase to three times per year. This adjustment is designed to improve leak detection and repair efforts, thereby reducing emissions more effectively.
Record-Keeping Requirements
Detailed records of all LDAR inspections must be kept for a minimum of five years. These records should include:
- Facility ID
- Date of survey
- Surveyor’s name
- Type of detection instrument used
- Equipment components surveyed and exempted
- Details of any detected leaks (location, concentration, repair status)
Pneumatic Inventory Collection: Minimizing Vented Gas
Requirements for New Facilities
Starting January 1, 2025, new facilities will be prohibited from venting gas from pneumatic devices. This strict requirement is aimed at preventing vented gas emissions from new sites right from the start. Montrose can assist by screening your pneumatic devices using optical gas imaging (OGI) to identify malfunctioning intermittent bleed pneumatics or malfunctioning no-bleed devices. We can also quantify actual emission rates from pneumatic device vents using the SEMTECH HI-FLOW 2.
Requirements for Existing Facilities
Existing facilities must reduce their vented gas emissions from pneumatic devices in phases:
- 25% reduction by December 31, 2025
- 50% reduction by December 31, 2026
- 75% reduction by December 31, 2027
- 100% reduction by December 31, 2028
This phased approach gives facilities time to modify their operations and implement non-emitting alternatives over the years.
Annual Reporting
To ensure compliance, companies are required to submit annual reports detailing their pneumatic inventory and the volumes of vented gas. The first report, due by April 1, 2025, will serve as a baseline for future compliance and reduction goals. This reporting process is essential for maintaining transparency and accountability as companies work to meet these regulatory standards.
Preparing Your Facilities for Saskatchewan’s Methane Regulations
For industry professionals, staying up-to-date and compliant with these new regulations is essential. Regular LDAR inspections, meticulous record-keeping, and proactive management of pneumatic devices will be crucial in meeting these goals and contributing to a more sustainable oil and gas industry.
These regulatory changes will take effect at the beginning of the new year, so timely action is critical. Montrose Environmental experts are ready to assess your current LDAR program and pneumatic inventory collection processes to ensure your facilities are well-prepared for Saskatchewan’s updated methane regulations before the January 1, 2025, deadline. Contact us today to get started. Explore our content to stay informed on the latest regulations and environmental updates.
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