Directive 039

Directive 039: Revised

Program to Reduce Benzene
Emissions from Glycol
Dehydrators
January 22, 2013
Effective June 17, 2013, the Energy Resources Conservation Board
(ERCB) has been succeeded by the Alberta Energy Regulator (AER).
As part of this succession, the title pages of all existing ERCB directives
now carry the new AER logo. However, no other changes have been
made to the directives, and they continue to have references to the
ERCB. As new editions of the directives are issued, these references
will be changed.
Some phone numbers in the directives may no longer be valid. Contact
AER Inquiries at 1-855-297-8311 or [email protected].

Directive 039
Release date: January 22, 2013
Effective date: January 22, 2013
Replaces previous edition issued July 7, 2008

Revised Program to Reduce Benzene Emissions from Glycol Dehydrators

The Energy Resources Conservation Board and Alberta Environment and Sustainable Resource
Development have approved this directive on January 18, 2013.
<original signed by>

<original signed by Matthew Machielse>

Brad McManus
Acting Chairman
Energy Resources Conservation Board

for Dana Woodworth

Deputy Minister
Alberta Environment and Sustainable Resource Development

Introduction
This edition of Energy Resources Conservation Board (ERCB) Directive 039 updates the
requirements for the reduction management and reporting of benzene emissions from glycol
dehydrators (dehydrators). Licensees, however, are still required to meet ERCB Directive
060: Upstream Petroleum Industry Flaring, Incinerating, and Venting requirements for
cumulative emissions from all sources at the facility or lease site.
With the issuance of this directive, the ERCB and Alberta Environment and Sustainable
Resource Development (ESRD) have established requirements to ensure continued reductions
of benzene emissions to reduce potential impacts on the public and the environment. New
modelling results show that to consistently meet the Alberta Ambient Air Quality Objectives
for the benzene one-hour average, the upstream oil and gas industry must reduce current
emission targets.
Whats New in This Edition
This January 2013 edition of Directive 039 contains the following key changes:

Section 1: The Decision Tree Analysis requirement has been changed to a

recommendation.

Section 2: Revised benzene emission reductions have been set out, as well as the
implementation schedule with new annual benzene emission limits for some dehydrators
coming into effect by January 1, 2014. The new emission limits are based on distance to a
permanent residence or public facility.

Section 4: The due date for submitting the annual Dehydrator Benzene Inventory List has
been changed to May 1 from July 1, and the e-mail address for submissions has been
updated.

ERCB Directive 039: Revised Program to Reduce Benzene Emissions from Glycol Dehydrators (January 2013) 1

Requirements
1) Licensees must follow the public consultation process outlined in the most recent edition
of the Canadian Association of Petroleum Producers (CAPP) document Best
Management Practices for Control of Benzene Emissions from Glycol Dehydrators
(Benzene Control BMP).
When evaluating dehydration requirements in order to achieve the lowest possible
benzene emission levels, licensees should use the Decision Tree Analysis in Appendix A
of the Benzene Control BMP and retain appropriate analysis documentation for review by
regulatory agencies.
2) Licensees must ensure that all their dehydrators do not exceed the benzene emission
limits for each dehydrator, based on the applicable calendar year, as outlined in Table 1,
Table 2, or Table 3.
Unless Table 2 or Table 3 applies to a dehydrator, benzene emission limits must comply
with Table 1. The implementation schedule in Table 2 sets out the updated emission
limits at the beginning of the listed calendar year for a dehydrator based on the distance
from the emission source to a permanent residence or public facility. Licensees must
verify the distance from an emission source to the nearest permanent residence or public
facility to ensure that all requisite changes to the dehydrator are made and emission levels
assessed.
The implementation schedule in Table 2 ensures continuous reductions until all existing
dehydrators operate within the updated emission limits by January 1, 2018, as set out in
Table 3. As of January 1, 2014, all new or relocated dehydrators must not exceed the
emission limits specified in Table 3. To qualify for the emission limits for an
appropriately designed flare or incinerator, a flare or incinerator must be used that meets
the minimum performance requirements in Directive 060, Section 7.
If a dehydrator requires changes to comply with the updated emission limits, the licensee
should consider the implications of making multiple changes to comply with the
successive reductions set out in Table 2 and are encouraged to upgrade each dehydrator
only once to meet the limits in Table 3.
Table 1. Grandfathered glycol dehydrator benzene emission limits
Date dehydrator installed or existing dehydrator
relocated
Benzene emission limits
Prior to January 1, 1999

Greater than 750 m to permanent resident or public

facility

Less than 750 m to permanent resident or public

facility
January 1, 1999, to January 1, 2007
After January 1, 2007

5 tonnes/yr
3 tonnes/yr
3 tonnes/yr
1 tonne/yr

2 ERCB Directive 039: Revised Program to Reduce Benzene Emissions from Glycol Dehydrators (January 2013)

Table 2. Implementation schedule and updated annual benzene emission limits for degrandfathering glycol
dehydrators based on distance to a permanent residence or public facility
Implementation schedule by calendar year to
reduced emissions
2014
2015
2016
2017
2018
Distance in metres (m)
Emission limit required as of January 1 of the calendar year in
tonnes (t)
No control or a
100
0.0
control other than an
appropriately
101250
0.1
designed flare or
incinerator
251750
1.0*
0.5
>750
After control emission
limit for an
appropriately
designed flare or
incinerator**

250

3.0*

2.0*

1.0

1.0

251750

1.0

>750

3.0

* Licensees are encouraged to upgrade each dehydrator only once to meet Table 3 limits and to consider the implications of making multiple
changes to meet successive reductions as outlined in Table 2.
** An appropriately designed flare or incinerator must meet the performance requirements in Directive 060, Section 7.

Table 3. Calendar-year emission limits for all glycol dehydrators effective January 1, 2018
Reduced benzene emission requirements
Distance
in metres (m)
No control or a control other than an
appropriately designed flare or incinerator
After control emission limit for appropriately
designed flare or incinerator source

100
101250
251750
>750
750
>750

Emission limit in tonnes (t) in

each calendar year
0.0
0.1
0.5
1.0
1.0
3.0

Specific Benzene Emission Limits

i)

If more than one dehydrator is located at a facility or lease site, the cumulative
benzene emissions for all dehydrators must not exceed the limit of the dehydrator
with the highest emission limit on that site. Modifications may be required to existing
unit(s) to meet the site limit.

ii) Any new or relocated dehydrators added to an existing site with dehydrator(s) must
operate within maximum benzene emission limit. The cumulative benzene emissions
must not exceed the limit of the dehydrator with the highest emission limit on that
site.
iii) For dehydrators that are only in operation for a portion of the year, the average daily
emission rate must not exceed the above annual benzene emission limits divided by
365. (For example, for a dehydrator with an annual benzene emission limit of
3 tonnes that only operates for six months of the year, the maximum annual emission
ERCB Directive 039: Revised Program to Reduce Benzene Emissions from Glycol Dehydrators (January 2013) 3

limit would be 1.5 tonnes or an average maximum daily emission rate of 8.2 kg/day.)
See Section 2.3 of the Benzene Control BMP for details on calculating and reporting
of emissions from dehydrators that only operate a portion of the year.
3) Licensees must complete a Dehydrator Engineering and Operations Sheet (DEOS)
(Attachment 1) to determine the benzene emissions from each dehydrator. This sheet
summarizes a dehydrators average operating conditions and estimates benzene emissions
for up to a 12-month period following the DEOS Revision Date and must be posted at
the dehydrator for use by the operations staff and inspection by the ERCB. The DEOS
must be revised every 12 months, upon relocation, or upon a change in status (resume
operation, shut-in, bypassed) of the dehydrator.
4) Licensees must complete and submit by May 1 of each year an annual Dehydrator
Benzene Inventory List for the operations of the previous calendar year (Attachment 2),
listing all the licensees dehydrators. This information must be submitted to the ERCB as
an Excel file by e-mail to [email protected] annual Dehydrator Benzene
Inventory List form is available on the ERCB Directive 039 webpage.
The latest version of the Benzene Control BMP is available from CAPP at
http://www.capp.ca/raw.asp?x=1&dt=PDF&dn=105760. This document describes procedures
for selecting appropriate dehydration, calculating emissions, maintaining records, and
reporting reductions of benzene emissions from glycol dehydrators. Questions regarding the
document and the processes it outlines may be directed to CAPP at 403-267-1100.
Compliance and Enforcement
Requirements are those rules that industry must follow and against which the ERCB may take
enforcement action in cases of noncompliance. The requirements set out in this directive will
be subject to compliance review by the ERCB. A list of noncompliant events is available on
the ERCB website, www.ercb.ca. Enforcement for noncompliance will be in accordance with
the latest edition of Directive 019: Compliance Assurance.
ESRD may also review for compliance, and failure to comply may result in the issuance of
Environmental Protection Orders (EPO), as outlined in the Alberta Environmental Protection
and Enhancement Act.
Contact Information
Any comments or questions about this directive should be directed to the ERCBs Technical
Operations Group at 403-297-6918 or by e-mail at [email protected] or to the ESRDs
Policy Branch at 780-427-6869 or by e-mail at [email protected].
Background
As described in IL 2001-07, the oil and gas industry has had a Benzene Reduction Program in
place since 1997. The program is managed by the Benzene Technical Advisory Team, which
has included representatives from Health Canada, CAPP, Environment Canada, the ERCB,
ESRD, B.C. Environment, and Saskatchewan Environment. A status report showed that only
26 per cent of new dehydrator installations used the Decision Tree Analysis outlined in the
November 2000 CAPP BMP for Control of Benzene Emissions to optimize dehydrator
performance to reduce benzene emissions to as low a level as possible.

4 ERCB Directive 039: Revised Program to Reduce Benzene Emissions from Glycol Dehydrators (January 2013)

Attachment 1

Dehydrator (Dehy) Engineering and Operations Sheet (DEOS)

Version Date: June 2006

(This sheet must be revised annually, or upon dehydrator relocation or change in status, and posted at the dehy.)
Technical Contact: Print Name/Phone #/email: _____________________________________________________________
Revision Date (dd-mm-yyyy): ________________ Facility or Site Name: _______________________________________
Licensee Name: __________________________________ Operator Name: ____________________________________
Govt Licence No: _______________
Location, DLS: _ -__ -__
-__ W _( or NTS:__________________)
Installation Type: Well Compressor Battery Plant Cavern Other DEHY Type: TEG DEG EG
Date Dehy installed/relocated? (dd-mm-yyyy): _______________ Current Dehy Status: Producing Shut-In
Bypassed Other: ___________________________ Date Dehy Status Changed? (dd-mm-yyyy): _______________
Typical number of operating days per year: ________ Number of dehys on site: ________________________
Distance to Closest Resident (if < 750 metres): _________ Normal Gas Flow Rate to Dehy: (e3 m3/d): __________

Benzene Content in Gas to Dehy (mole %):_______ (If zero, Dehy operations sheet must still be posted)
Feed gas benzene determination method: Analysis Date of analysis (dd-mm-yyyy): _________
Other (describe): _____________________________________________________________________
Glycol Pump Make/Model# ____________________________________ Normal Pump Speed:_________ RPM or SPM
Plunger diameter/stroke length: _______________ inches, or _____________________ mm
Normal Glycol Circulation: ________USgpm Normal Absorber Temp: _____C Normal Absorber Press: ______kPag
Emission Calculation Method: GRI GLYCalcTM Version #:__ HYSYSTM ProSimTM Total Capture
Rich/Lean Glycol OtherDescribe:
Benzene Emission Controls: No Yes Describe (condenser, tank, incinerator, flare, other):
________________________________________________________________________________________________
Dehy decision tree analysis (DTA) completed?:
No Yes (mandatory for all new or relocated dehys)
When operating, average benzene emissions (in tonnes/yr)* Before Controls: _________ After Controls: _________
*Note: In accordance with EUB Directive 039, this dehydrator must be operated below ______ tonnes/yr benzene
emissions. If multiple dehys exist on this site, the aggregate benzene emissions must be less than _____ tonnes/yr,
which is the maximum per year allowed for the oldest dehy on site.
Typical Dehydrator Operations Graph
@ 7,580 kPag, 40 C, 100 ppm benzene, 98.6% TEG

3.5

3.50

3.00

2.5

Benzene Emission Limit

2.50

2.00

1.5

1.50

1.00

0.5

0.50

0
0.00

0.25

0.50

0.75

1.00

1.25

1.5

Benzene Emissions
(tonnes per Year)

Dry Gas Water Content

(lbs/mmscf)

Wet Gas to dehy contains

61 lbs w ater per mmscf or
0.978 kgs w ater per e3m3

0.00
1.75

Circulation Rate USgpm

Graph Prepared by :

Dewpoint @ 3.5 mmscfd (100 e3m3/d)

BZ @ 7.0 mmscfd (200 e3m3/d)

Dewpoint @ 7.0 mmscfd (200 e3m3/d)

ERCB Directive 039: Revised Program to Reduce Benzene Emissions from Glycol Dehydrators (January 2013)

6 ERCB Directive 039: Revised Program to Reduce Benzene Emissions from Glycol Dehydrators (January 2013)

Attachment 2

2006 (yyyy)

Canadian Oil and Gas Industry - Annual Dehydrator Benzene Inventory List For:

Company Net Gas Production:

103 m3 /day

Instructions: This form must be completed and submitted annually by July 1st for the previous year of operations. Upon completion, submit this form to the Benzene Technical Advisory Team by email to [email protected] Attention: Manager of Alberta Operations, CAPP
Company Data Revision Date:

July 1, 2007

DEOS Completed

Yes
No / Specify:

Operating Company Name

July 1, 2007

Unique Identifier

Licensee
Multiple
Dehys on
Site?

Date Submitted to CAPP:

Field Name

BC Centizone

Complete LSD
01-01-020-25W4

Dehydrator Use (Installation Type)

LSD Sect Twn

Rge

Installation Type

TEG
DEG
EG
Other

Rge

Mer

Compressor
Battery
Wellsite
Gas Plant
Storage Cavern
Other

25
25

4
4

Compressor
Compressor

TEG
TEG

Yes / No

- Shut In
- Separator Ops
- Sold

Field Name
Example Data:
Yes
Yes

Yes
Yes

ABC Resources Inc.

ABC Resources Inc.

BC Centizone

Sample Location Field

Sample Location Field

Complete LSD
01-01-020-25W4
01-01-020-25W4

LSD Sect Twn

1
1

1
1

20
20

Glycol
Type

Mer

Operating Status

Production Status

Number of
Operating Days
per year

Benzene
Emissions Rate
While Operating

Normal gas flowrate to

dehy

Operating
103 m3 /day
Shut-in
or shut-in
De-commissioned
or by-passed, or
By-passed
operating as separator
Operating as a separator
or other
Other
Operating
Operating

Benzene Concentration
(Gas to Dehy)

200
200

Annual Benzene Emissions

for dehydrator
Emissions Prior Emissions After
to Control
Control

Mole % for each dehy

days

tonnes

kilograms/day

Number of Operating Days x

Emissions Rate

0.015%
0.018%

300
200

2.00
9.50

3.50
6.00

0.60
1.90

*Note: Copies of the Annual Dehydrator Benzene Inventory List Forms are available from CAPP at www.capp.ca

ERCB Directive 039: Revised Program to Reduce Benzene Emissions from Glycol Dehydrators (January 2013) 7

Annual Dehydrator Benzene Inventory List (continued)

Cumulative Annual
Benzene Emissions

Emissions
Calculation Method

Above Dehy
Limit?

For all dehydrators on

site

Above Site
Limit?

Yes / No

tonnes
Add up the emissions
from all previous rows
per site. Leave single
dehys blank.

Yes / No

2.50

No

No
No

Installation
Details

Emission Control Method

GRI-GLYCalc
HYSYS
Prosim
Total Capture
Rich/Lean Glycol
Other (describe)

No Control / Emit to Atmosphere

Aboveground/ Underground Tank
Flare / Incinerator
Process Optimization
Commercial Condenser
Other (describe)

Yes / No

Date of
Installation/
Relocation, if
known
yyyy-mm-dd

GRI-GLYCalc
GRI-GLYCalc

No Control
No Control

Yes
No

2/1/2001
2/1/1998

Installed /
Modified after
Jan. 1, 2001?

Comments
Oldest Dehy
Oldest Dehy
For This Dehy
For This Dehy
Date Site
Were
Distance to
Decision Tree Analysis Number of
Allowed Annual Allowed Daily Allowed Annual Allowed Daily
Record
residents
Closest
dehys on
Completed? (EUB
Benzene
Benzene
Benzene
Benzene
Changed
Residence contacted?
site
Directive 039)
Emissions
Emissions
Emissions
Emissions
Required for all
tonnes/yr
kilograms/day
tonnes/yr
kilograms/day
m
Yes / No
yyyy-mm-dd
New/
Show dehy limit Show dehy limit Flag red if
Show dehydrator Show dehydrator of oldest dehy on of oldest dehy on <750 m
Relocated
limit only
limit only
site if more than site if more than
Dehydrators
one dehy
one dehy
a
c
Yes
Yes

2
2

3.0
5.0

8.22
13.70

5.0
5.0

13.70
13.70

1,120
1,120

No
No

10/12/2005
10/12/2005

Additional
Comments

New unit
Old unit

*Note: Copies of the Annual Dehydrator Benzene Inventory List Forms are available from CAPP at www.capp.ca

ERCB Directive 039: Revised Program to Reduce Benzene Emissions from Glycol Dehydrators (January 2013) 8