The Government of Saskatchewan published the details of the Accelerated Site Closure Program (ASCP) on their website. The primary purpose of this program is to put Saskatchewan people and companies back to work in the struggling oil and gas services sector. The ASCP will utilize$400 million of federal funding provided to the Province of Saskatchewan for the abandonment and reclamation of inactive oil and gas wells and facilities.

The program is being rolled out in multiple funding phases, starting with $100 million for Phase 1. Abandonment and reclamation work approved under Phase 1 will be funded at 100% of the eligible costs, paid directly to eligible service companies. Eligible licensees will receive a funding allocation established by considering the eligible licensee’s total deemed liability as a percentage of the total deemed liability of all eligible licensees. This ratio will be applied to the $100 million Phase 1 funding tranche to arrive at a licensee’s eligible funding allocation. The Saskatchewan Ministry of Energy and Resources will determine licensee eligibility and funding allocations which will be posted on Saskatchewan.ca no later than May 29, 2020.

Once the eligible licensee has its funding allocation, they will be required to nominate wells and facilities through the Integrated Resource Information System (IRIS). Phase 1 will close once the $100 million is fully prescribed, or at a date to be determined with sufficient advanced notice. Upon nomination of wells, facilities and sites, eligible licensees will identify preferred contractors. The program will make every effort to facilitate the licensee’s use of preferred contractors, though this may not be possible in all circumstances.

North Shore Environmental Consultants Inc. meets the eligible service company requirements and will be applying to become an eligible service company under the ASCP. We offer eligible activities for Phase 1 of the ASCP, including environmental site assessments (Phase 1 & Phase 2 ESAs), remediation, and surface reclamation work. Please contact us if you are interested in discussing the program or our service offerings in more detail.

Contact – Todd Clouse, tclouse@northshoreenv.com, 306-216-7900

Government Link – Saskatchewan Accelerated Site Closure Program

Right now is a critical time to create your plan for MSAPR compliance! The first phase of NOx emissions limit is in force for pre-existing engines on January 1, 2021 – companies can choose a subset (50% of rated brake power) of engines to comply with the limit. The remainder of your engine fleet does not have to comply until 2026.

Subset Strategy
It is all about cost savings. Companies will need to strategically pick their first subset of pre-engines, considering the following:

  • Size of engine – Engines <375 kW only requires a one-time test to prove compliance. Including these engines in your first subset will avoid “starting the clock” on an arduous and expensive testing schedule.
  • Burn type – Lean-burn engines (≥375 kW) only require a 1 time/year emissions check/performance test. Including mostly lean-burn engines will allow you to save costs and delay the time-consuming testing schedule for rich-burn engines (4 times/year). Lean-burn engines are also likely already compliant with the emissions limit.
  • Location of engines – Optimize your subset to minimize mobilization costs for conducting performance tests/emission checks.
  • Ability to meet the limit with minimal/no retrofitting – Choose engines that are relatively new for your subset, as these engines will be able to meet the emissions limit with little to no additional cost. This gives companies more time to prepare for costly retrofits for older engines, or have the option to replace the engines all together.

Record Keeping
Inventory is everything. Companies need to invest the time in proving their inventory and maintaining records. Each engine will have different testing schedules, different reporting requirements, and different emission limits to follow. Any changes, retrofits, replacements, or transfers need to be documented and reported to Environment and Climate Change Canada (ECCC).

It is essential that this information is kept up to date and accessible.

North Shore Expertise
We at North Shore understand that it can be a confusing process to maintain compliance in the light of numerous emissions reduction regulations. We can guide you through this regulatory process, conduct training sessions to keep operations up-to-date, and help you become complaint in a cost-effective way.

We recommend conducting emissions checks in Summer 2020 to confirm that the engines will meet the limit. This allows ample time for retrofits or re-grouping to meet Phase 1 of the limit.

  • MSAPR Management – Strategize and optimize MSAPR compliance, maintain records, notifications for testing and key deadlines
  • Emission Checks and Performance Tests – Our team has over 10 years in expertise in emissions testing, and is fully proficient in the required MSAPR testing protocols (ASTM D6522-11, EPA Method 7E, EPA Method 3A, EPA Methods 1-4).
  • Reporting – Manage Schedule 9 Engine registries, submit Schedule 10 compliance reports.

Contact Tanner or Hillary at North Shore if you have any questions:

Tanner Nesbitt, EP
Emissions Specialist – Fugitive Emissions & MSAPR Coordinator
Main: 403-228-3095 ext.221
Email: tnesbitt@northshoreenv.com

Hillary Yeung, P.Eng
Air Quality and Emissions Coordinator
Main: 403-228-3095 ext.229
Email: hyeung@northshoreenv.com

Visit – Methane and MSAPR Services

MSAPR Background: Part 2 – Engines

Multi-Sector Air Pollutants Regulation (MSAPR) is Canada’s first mandatory national air pollutant emissions standards that establishes a standard process for registering, testing, monitoring and reporting of NOx emissions and NOx emission intensity limits for boilers, heaters and engines.

Engines are split into different categories based on manufactured date, pre-existing engines are those that were manufactured before September 15th, 2016 and have a ≥ 250 kilowatt (kW) rated output capacity. Modern engines are those that are manufactured after the pre-existing date and have an output capacity of either ≥ 75 kW (if regular use) or ≥ 100 kW (if low use). Both performance tests and emissions checks are required to meet the regulations, ranging from a one time test, 4 times/year or 1 time/year depending on the size of your engine and the burn type.

Important dates:

  • Pre-existing engines – registration: January 1, 2019
  • Pre-existing engines – notice to indicate yearly average election: October 31, 2020
  • Pre-existing engines – compliance reporting for the prior year: July 1 (starting in 2022)
  • Pre-existing engines – 1st phase of NOx emission limits: January 1, 2021
  • Pre-existing engines – 2nd phase of NOx emission limits: January 1, 2026
  • Modern engines – registration: July 1 after the first year of operation
  • Modern engines – compliance reporting for the prior year: July 1 (starting in 2020)
  • Modern engines – compliant with limit by first hour of operation

Since May 1st, North Shore, along with many other environmental, abandonment, and decommissioning service companies, has been busy making numerous grant funding applications under the Alberta Site Rehabilitation Program (ASRP). With many media and industry reports indicating that tens of thousands of applications were made under the program in just the first four or five days, it is evident that the Department of Energy (DOE) has a daunting task of trying to sort through all of the applications in an efficient and effective manner. We certainly do not envy that particular task! As such, the DOE has already issued statements that application processing times will be delayed due to the high participation in the program and the volume of applications made.

Over the last two weeks, additional information and updates to the ASRP have been released. Some of these updates include guideline and fact sheet documents related to the program specifics and instructions for making applications. All of these updates can be found on the ASRP web page for reference – https://www.alberta.ca/site-rehabilitation-program.aspx

Some additional clarifications from the DOE were also communicated through industry hosted information webinars. One of the more substantial clarifications made by the DOE about the program pertained to funding eligibility during the first and second phases of the program. The DOE indicated that because the intention of the program is to get Alberta Oil Field Service (OFS) Companies back to work as soon as possible, applications made during the first phases of the program will be reviewed and approved based on cost reasonableness without any significant consideration of a licensee’s ability to pay. This ultimately allows for fewer restrictions on which sites can be applied for, as well as for the DOE to review applications with increased flexibility and speed. However, further assessment on a licensee’s “ability to pay” may be implemented in future phases of the program as the application process is refined.

With the second phase of funding under the program proposed to be opened up later this week (May 15th), we are hopeful that additional details regarding the program and application processing will be communicated by the DOE in the coming days. In the meantime, North Shore would like to thank all licensees and OFS companies that have been working with us over the last few weeks to submit applications as part of this program. The willingness to participate and cooperate during the proposal and application process is greatly appreciated. There will no doubt be some great opportunities that are born out of this program and we are extremely excited to initiate the projects being proposed.

For additional information on how to work with North Shore as either an eligible producer/licensee, or as an applicable service provider, please contact us either by phone or the email below.

Contact – ABSiteRehabProgram@northshoreenv.com

Government Link – Alberta Site Rehabilitation Program

Following the provincial government’s announcement of the Alberta Site Rehabilitation Program (ASRP) on April 24th, 2020, North Shore has been inundated with calls and meetings with existing clients, potential clients, and environmental service providers curious on how they can take part in and receive some of the program benefits. With many details of the program not yet officially released, there are two common questions being asked:

  • What will determine a licensee’s “ability to pay” and subsequent funding eligibility (25-100%)?
  • If an application is made and desirable funding eligibility (e.g. 25% vs 100%) is not received, can the application be withdrawn?

These are all very good and important questions that we’re sure will be answered shortly and will ultimately have an impact on a licensees willingness to participate with various service providers in the program.

Some other concerns we are hearing is that the program is restrictive in terms of the potential funding being offered compared to the work required to complete a task (especially when there can be many unknowns to account for). This is especially true for a lot of the higher expense services like downhole abandonment and remediation activities. This initial phase of the ASRP may seem somewhat restrictive in the fact that funding is capped and applications are currently required to be made on a site by site basis. It is however important to consider that this initial phase will be a trial of the program with further revisions and details to follow in the implementation of future phases.

North Shore feels that it is equally important to maintain context of this program and what it is attempting to achieve. The main intention of the ASRP is to support eligible oil and gas service companies by creating jobs and putting Albertans to work, with the added benefit of addressing outstanding environmental liabilities in Alberta and perhaps also lessening future financial burdens on the province, the Orphan Well Program, and many of the currently active licensed producers. When reviewing the program goals, it is also quite obvious that the program itself is not necessarily focused on achieving site “closure” or completing all aspects of each closure activity under its funding model. It simply states that it is designed to accelerate abandonment and reclamation efforts and quickly complete a high volume of environmentally significant work. These goals align closely with the overarching intention of the program, to immediately get Alberta’s specialized oil and gas labour force back to work. Further to this, the list of eligible activities under the program is also quite broad. We feel that this is by design in order to allow flexibility to licensees and ensure service providers are able to make applications to conduct as many different closure tasks (or portions thereof) as possible.

As we await further application details regarding the initial phase of the program, we would also like to encourage licensees and service providers to consider opportunities for other “activities” that may be eligible for funding applications. Some of these opportunities could include partial or interim activities where, if completed, would:

  • Help accelerate the site closure progress;
  • Reduce, identify, or characterize potential surface or subsurface liability; and
  • Continue the trajectory towards future site closure.

If possible, any remaining portions of the work required could then be deferred and completed at a later date and/or possibly under funding applications as part of future phases of the ASRP.

North Shore will continue to share information and work with service providers and potentially eligible oil and gas licensees to ensure we are positioned to effectively and efficiently maximize program benefits and opportunities when the application process is initiated on May 1st, 2020.

For additional information on how to work with North Shore as either an eligible producer/licensee, or as an applicable service provider, please contact us either by phone or the email below.

Contact – ABSiteRehabProgram@northshoreenv.com

Government Link – Alberta Site Rehabilitation Program

On April 17th, 2020, Canada’s Prime Minister announced over $1.7 Billion in available funding to support inactive and orphan site closure within the oil and gas industry as part of it’s COVID-19 Economic Response Plan. Following the federal funding release, Alberta’s provincial government announced the implementation of the Site Rehabilitation Program on April 24th, 2020.

The primary goals and intentions of Alberta’s Site Rehabilitation Program are to:

  1. Immediately get Alberta’s specialized oil and gas labour force back to work;
  2. Accelerate site abandonment and reclamation efforts; and
  3. Quickly complete a high volume of environmentally-significant work.

Details regarding Alberta’s Site Rehabilitation Program (including available grant funding, eligibility requirements, and the application process) can be found through the link below which will be updated regularly by the Alberta government: https://www.alberta.ca/site-rehabilitation-program.aspx

Some of the key eligibility and program requirements include:

  • Oil and Gas sites must be located in Alberta, putting Albertan’s to work.
  • Available grant funding between 25-100% of project costs to a maximum of $30K per site.
  • Eligible services currently include:
    • Wellsite abandonment
    • Pipeline abandonment
    • Pipeline segment removal
    • Facility abandonment
    • Phase 1 and Phase 2 Environmental Site Assessments
    • Site Remediation
    • Site Reclamation
  • A valid and executable contract with a producer/licensee must be obtained prior to application.
  • All work must be completed by skilled contractors that possess the necessary expertise, capacity, and equipment to perform the work. Verification of the work by an applicable professional may be required to receive full grant payment.
  • Applications for the first round of available funding ($100 Million) can be made May 1st, 2020.
  • Additional rounds of available funding will become available as the program is developed.

In the coming days and weeks there will be more questions arising from the implementation and execution of Alberta’s Site Rehabilitation Program. However, what is not in question is North Shore Environmental Consultants ability to deliver the desired results of the program’s goals.

Since 2002, North Shore has been focused on site remediation and reclamation activities within Alberta’s oil and gas energy sector. Throughout the last 18 years, we have established ourselves as the industry leader in efficient high volume site closure activities throughout the province. With our unparalleled experience, operational agility, and extensive network of professionals and subcontractors throughout key areas of the province, we are best positioned to quickly complete high volumes of environmentally significant work that benefits our clients, landowners, service providers, and the province of Alberta as a whole.

North Shore will continue to be a leading authority in oil and gas site closure activities in Alberta and is positioned to maximize all benefits and opportunities through Alberta’s Site Rehabilitation Program when the application process is initiated on May 1st, 2020.

For additional information on how to work with North Shore as either an eligible producer/licensee, or as an applicable service provider, please contact us either by phone or the email below.

Contact – ABSiteRehabProgram@northshoreenv.com

Government Link – Alberta Site Rehabilitation Program