Benzene Content Measurement in ECCC VOC RegulationCCQTA members have identified an ongoing compliance concern with the ECCC “Reduction in the Release of Volatile Organic Compounds (Storage and Loading of Volatile Petroleum Liquid Regulations)”. The regulation requires operators to generate and report ongoing analytical data to support compliance; however, the test methods cited for benzene content are not applicable to crude oils and condensates. The analytical methods referenced in the regulation are designed for refined petroleum products (e.g., automotive gasoline, naphtha, and solvents) and do not include crude oils within their validated scope. As a result, their direct application to crude oil and condensate streams is technically inappropriate and may not produce defensible results. While the regulation provides a pathway to use alternate test methods through ASTM D6708 (Standard Practice for Statistical Assessment and Improvement of Expected Agreement Between Two Test Methods), this provision is not practically applicable. ASTM D6708 requires that the methods being compared have overlapping scopes and measure the same property within a common applicability range. In the case of crude oil methods (e.g., ASTM D7900) versus the methods cited in the regulation, there is no overlap in scope. Consequently, equivalency cannot be demonstrated, and the alternate method pathway cannot be utilized. This creates a compliance gap whereby operators are required to report analytical data but lack technically valid and standards-compliant methods to generate that data. Without an applicable test method or a viable equivalency pathway, operators are exposed to potential non-compliance with record-keeping and reporting requirements, as well as increased audit and regulatory risk. The CCQTA identified this issue during the draft stage of the regulation and communicated concerns to ECCC prior to its publication in March 2025. CCQTA continues to engage with ECCC on this matter and will keep members informed of any developments or guidance as it becomes available. This topic will be discussed at the June 9, 2026 Vapour Pressure project meeting. Viscosity Measurement at Elevated PressureCCQTA members are currently investigating approaches for measuring viscosity at elevated pressures. With increased focus on volatility and its impact on analytical measurements, several operators have begun performing density measurements at approximately 500 kPa using direct injection from sealed sample cylinders (MPC/FPC). This approach has proven effective for density measurements, as fluid compressibility at these conditions is minimal and does not significantly influence results. There is growing interest in extending this methodology to viscosity measurements in order to prevent crossing the bubble point as a result of elevated test temperatures. Crossing the bubble point may result in microbubble formation within the test cell, which can interfere with viscosity measurements and lead to non-representative results. This is particularly relevant for volatile crude oils and condensates where even moderate temperature increases can induce phase change under insufficient pressure conditions. This topic will be discussed at the June 10, 2026 Open Forum meeting. |
