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. Revision to Use of H2S Scavenger in Crude Oil white paperThis Information Bulletin has been developed with input and consultation from many of our CCQTA members from across the industry. The CCQTA is distributing this bulletin to members for information purposes to provide industry with an overview on the use of scavenger including: purpose, entry routes, application as well as the potential downstream impacts. This bulletin was first published in 2019 and was revised in 2025 to include additional chemistries and clarifications and now again in 2026 to improve the section on dithiazine fouling. Please see the Documents for Download on the homepage or under the Publications tab under white papers. |
