by Tammy J. Murphy
Volatile Organic Compounds (VOCs) are precursors to ground-level ozone as well as to Particulate Matter (PM). Both of these are main components of smog which may have detrimental effects on human health and on environmental quality. And, the release of VOCs, including petroleum and petrochemical gases, may expose individuals to carcinogens that are potentially contained within the releases. In the Petroleum Sector, releases of “fugitive” VOCs occur primarily due to leaks within process equipment components.
As such, The Reduction in the Release of Volatile Organic Compounds Regulations (Petroleum Sector), published in the 11 November 2020 edition of the Canada Gazette, Part II, aim to strengthen the current measures in place to limit these fugitive emissions.
What is regulated?
- VOCs are defined in the Regulation as “a compound that participates in atmospheric photochemical reactions and that is not excluded under Item 65 of Schedule 1 to the Canadian Environmental Protection Act, 1999.”
Who must comply with the Regulations?
- Petroleum refineries;
- Petrochemical facilities that are operated in an integrated way with petroleum refineries and upgraders.
What are the requirements?
- Implementation of a “leak detection and repair (LDAR) program;”
- Designing and operating certain equipment components to prevent leaks (i.e., – “preventive equipment requirements”);
- Measuring specified VOC concentrations at the fence line of facilities;
- Maintaining required records, meeting reporting requirements, and undergoing auditing activities as described in the Regulations.
When do the Regulations come into force?
- With the noted exceptions, the Regulations come into force on 1 December 2020;
- Sections 3 to 10 (Leak Detection and Repair Requirements) come into force on 1 January 2022;
- Sections 11 to 16 (Requirements for Certain Equipment Components) come into force on 1 January 2023.
The full text of the Regulations should be consulted for complete details.
Additional information may also be found on the Government’s Pollution and Waste Management website.
Note that in April 2018, the “Regulations Respecting Reduction in the Release of Methane and Certain Volatile Organic Compounds (Upstream Oil and Gas Sector)” were published. Similar to the Regulations targeting the Petroleum Sector, this Regulation introduced facility and equipment standards with the goal of reducing “fugitive and venting emissions of hydrocarbons, including methane, from the upstream oil and gas sector.” Those Regulations, with the exception of certain sections, came into force on 1 January 2020. The complete details can be found in the appropriate edition of the Canada Gazette.
Recommended Action Items:
- Become familiar with the Regulations and ensure awareness of implementation dates.
- Determine if your facility must comply with the Regulations.
- Plan for and implement the requirements of the Regulations.
Department of the Environment and Department of Health, Canadian Environmental Protection Act, 1999, “Reduction in the Release of Volatile Organic Compounds Regulations (Petroleum Sector).” Canada Gazette, Part II, 11 November 2020 edition: http://canadagazette.gc.ca/rp-pr/p2/2020/2020-11-11/pdf/g2-15423.pdf
Government of Canada, Environment and Climate Change Canada, Pollution and Waste Management, Reduction in the Release of Volatile Organic Compounds Regulations (Petroleum Sector) website: https://pollution-waste.canada.ca/environmental-protection-registry/regulations/view?Id=147
Department of the Environment and Department of Health, Canadian Environmental Protection Act, 1999, “Regulations Respecting Reduction in the Release of Methane and Certain Volatile Organic Compounds (Upstream Oil and Gas Sector).” Canada Gazette, Part II, Extra, 26 April 2018: http://gazette.gc.ca/rp-pr/p2/2018/2018-04-26-x1/pdf/g2-152×1.pdf
Canada, Canadian Environmental Protection Act, 1999 (CEPA, 1999), Volatile Organic Compounds (VOC), Petroleum Sector
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