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Measurement Requirements for Oil and Gas Operations in Saskatchewan (Directive PNG017)

As of December 2019, the Government of Saskatchewan has implemented Directive PNG017: Measurement Requirements for Oil and Gas Operations, revision 3.0 in Saskatchewan. As part of Directive PNG017, revision 3.0, the definitions of fuel gas, flare gas and vent gas, for measurement and reporting purposes, have changed effective January 1, 2020. These changes affect how fuel gas, flare gas and vent gas are categorized and how the volumes are to be reported. All operators in Saskatchewan are subject to the fuel gas, flare gas and vent gas definitions and are required to measure and report according to Directive PNG017. Directive PNG017, revision 3.0 will remain in effect until September 1, 2020, at which point Directive PNG017, revision 4.0 will come into force.

Revision 4.0 of Directive PNG017

On April 9, 2020, a Minister's Order (MRO 59/20) was published authorizing an amended version of Directive PNG017, revision 3.0. The Directive PNG017: Measurement Requirements for Oil and Gas Operations, revision 4.0, will come into force on September 1, 2020. Until Directive PNG017, revision 4.0 is in force, operators of heavy oil facilities are encouraged to review the measurement requirements in Directive PNG017, revision 4.0 in an effort to become informed and prepared to meet the new requirements by September 1, 2020.

Guideline PNG035: Estimating Venting and Fugitive Emissions

Guideline PNG035: Estimating Venting and Fugitive Emissions has been created to aid industry in estimating and reporting vent gas, which includes fugitive emissions, by providing tools and estimation formulas. Due to the high complexity of determining vented gas volumes at some sources, a Gas Estimation Tool has been developed to allow industry to input site-specific field operation information into the tool, and the tool will calculate the volume of gas being vented from sources associated with that site.

Intent of this Directive

Directive PNG017 consolidates, clarifies and updates the regulatory requirements with respect to measurement points used for accounting and reporting purposes, as well as those measurement points required for upstream petroleum facilities and some downstream pipeline operations under existing regulations. This Directive specifies:

  1. Which and how volumes must be measured;
  2. Which, where, and how volumes may be estimated;
  3. Accounting procedures, and how they must be performed to determine the volumes;
  4. Data that must be retained for audit purposes; and
  5. Resultant volumes which must be reported to the Regulator.

Enforcement

This directive replaces and supersedes a number of Saskatchewan regulatory documents, as identified in Appendix 1 of Directive PNG017. Effective April 1, 2016, this directive has regulatory authority in Saskatchewan. Regulatory enforcement, including audits and inspections, intended to ensure compliance with the oil and gas measurement requirements will be applied in accordance with the implementation schedule outlined below. Enforcement actions will be applied according to Section 13.6 of Directive PNG076: Enhanced Production Audit Program. As a result of the implementation of Directive PNG017, all Measurement Exemptions approved in Saskatchewan before April 1, 2016 have been rescinded.

Industry must make continuous progress with respect to compliance for measurement and reporting by April 1, 2021, and the Government of Saskatchewan may require operators to demonstrate their progress throughout the implementation schedule. Operators must meet the following implementation schedule:

  1. Requirements must be 25 per cent implemented by April 1, 2017
  2. Requirements must be 50 per cent implemented by April 1, 2018
  3. Requirements must be 75 per cent implemented by April 1, 2019
  4. Requirements must be 100 per cent implemented by April 1, 2021

Any facilities licensed after April 1, 2016, must be designed and operate in full compliance with Directive PNG017. For facilities licensed prior to April 1, 2016, operators are expected to comply with the 5-year implementation schedule.

For more information

Please refer to the FAQs about Directive PNG017 for frequently asked questions regarding Directive PNG017.

Compliance Reporting Tool for Directive PNG017

The Government of Saskatchewan expects industry to make continuous progress towards being 100% implemented by April 1, 2021, and may require operators to demonstrate their progress during this period. When requested, operators are required to provide documentation that demonstrates their level of compliance. The Compliance Reporting Tool for Directive PNG017 may be one way to provide an approximate compliance percentage with Directive PNG017. Please refer to the Compliance Reporting Tool for Directive PNG017.

This document can also be used by operators to track their approximate compliance percentage with Directive PNG017 throughout the five-year implementation period. If there are any suggested changes to this document, please email directive17.er@gov.sk.ca.

Exemption from Base Measurement Requirements

Any approved measurement exemptions granted before April 1, 2016, have been rescinded. Operators are responsible for applying for new measurement exemptions if they cannot meet the base requirements outlined in Directive PNG017. The criteria set out in Section 5 of Directive PNG017 provide instructions on measurement exemptions (also known as site-specific deviations from base requirements). All applications for measurement exemptions must be submitted through IRIS. Measurement exemption applications must include a completed Measurement Exemption Application form, and other supporting documentation and be submitted to IRIS under the Applications – Measurement Exemptions. Find more information, along with the Measurement Exemption Application.

Guideline PNG042: Measurement, Accounting, and Reporting Plan (MARP) Requirements for Thermal Heavy Oil Recovery Projects

The Guideline PNG042: Measurement, Accounting and Reporting Plan for Thermal Heavy Oil Recovery Projects Version 2.0 outlines the requirements for submitting a measurement, accounting and reporting plan (MARP) for thermal heavy oil facilities in Saskatchewan. Effective May 1, 2018 applicants are no longer required to submit their MARP with their application for a Thermal Heavy Oil Recovery (EOR) Project. All MARP applications must be submitted through IRIS under Applications – Measurement, Accounting and Reporting Plan. For a new EOR project, the MARP application must be submitted after the EOR project application has been submitted and must be approved prior to injection or production of the thermal heavy oil project. For an existing EOR project without an approved MARP, the MARP application must be submitted only if the licensee changes an existing project, including new or additional wells, and/or surface facilities. For an existing EOR project that already has an approved MARP and is adding new or additional wells and/or surface facilities or the scope of the project is changing, a new MARP is required only if the licensee is changing the measurement, accounting and reporting methodology that was originally approved in the MARP.

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