In 2020, several audit and inspection activities were conducted to help improve industry compliance with the methane requirements. Below are some highlights of each of these initiatives.
Audits are desktop exercises that mainly review information submitted by industry through various reporting programs or direct exchanges that result from interaction with duty holders. Different audit activities count the number, duration, and completion of audits differently. Here are highlights of the 2020 methane audit program:
- Forty-three notices of noncompliance were issued to operators who didn’t submit 2019 OneStop annual methane emissions report by June 1, 2020. Twelve “failure to comply” letters were subsequently issued to operators who did not respond to the notice within the requested timeline.
- Overall vent gas limit (OVG) audits are conducted to ensure facility IDs and well licences are compliant with the OVG limit of 15 103 m3/month. Responding to a noncompliance includes any actions taken to achieve compliance, such as correcting a reporting error, combusting the gas, conserving the gas, or shutting-in gas production. Fifty-two OVG audits were conducted, resulting in forty-seven noncompliances.
- Fuel flare vent (FFV) audits are conducted to ensure accurate reporting of fuel, flare, and vent gas volumes to comply with definitions in Directive 060. Sixteen FFV audits were conducted, resulting in no noncompliances.
- OneStop data quality audits are conducted to ensure accurate reporting of annual methane data to OneStop. The scope of these audits also includes requesting the pneumatic inventory to ensure that vent volumes from pneumatic devices are accurate. One hundred and thirty-eight OneStop data quality audits were conducted, resulting in no noncompliances.
- FEMP audits are conducted to confirm the duty holder has created a FEMP and that it includes the information required. Twenty-eight FEMP audits were conducted. There was one notice of noncompliance issued because the duty holder didn’t respond within the timeline. All duty holders had a FEMP document in place, with various levels of detail and quality.
- Methane reduction retrofit compliance plans are documents that duty holders must create and maintain as per requirements in Directive 060. They outline what resources, budget, and equipment need to be retrofitted and under what timelines to be compliant with the new equipment requirements of Directive 060. Seventeen methane reduction retrofit compliance plan and pneumatic inventory audits were conducted. One duty holder did not have a pneumatic inventory, five operators did not report pneumatic volumes to OneStop, and six operators submitted revised data as a result of the pneumatic inventory audit.
Given the significant scope and magnitude of the new methane requirements, industry education was the focus of the 2020 inspections. Inspectors were educated internally at the AER from January through July. Significant delays to inspection training occurred due to COVID-19 restrictions since the training required multiple people on site or in indoor environments. As a result, independent inspections didn’t start until August 2020 across the province.
A total of 266 methane inspections were conducted in Alberta in 2020. Of these, 32 (12 per cent) were considered to have unsatisfactory outcomes, meaning the inspection resulted in required follow-up work for the duty holders. All issues leading to an unsatisfactory inspection were resolved. Going forward, inspections will be conducted throughout the year and will shift from focusing on industry education to compliance assurance. This is likely to result in changing compliance rates year over year.