Simplifying Alberta’s New Pump Inspection Rules

On February 27, 2025, Alberta Environment and Protected Areas issued a memorandum to the Quantification Protocol for Greenhouse Gas Emissions Reductions from Pneumatic Devices (Version 3.0). This protocol introduces new requirements for oil and gas operators, including biannual inspection requirements for pneumatic chemical injection pumps, updated rules for reporting vent gas limits, reconciliation of chemical injection volumes, and correcting emissions calculations.

Pneumatic chemical injection pumps are widely used in oil and gas operations to inject chemicals into pipelines and production equipment to prevent issues like corrosion, hydrates, and wax buildup. These pumps are often powered by pressurized natural gas, which releases methane into the atmosphere during operation. The updated protocol aims to reduce these emissions by enforcing regular inspections and improved data tracking, ensuring optimal pump performance and minimizing unnecessary venting.

Projects may adopt the requirements under items 1, 2, and 3 above at any date on or prior to June 30, 2025, if they choose, but all projects must follow these requirements as of July 1, 2025. Operators must act quickly to understand these changes, assess their impact, and implement strategies to meet the new requirements efficiently.

This blog will provide key updates to the rule, explain what these changes mean for oil and gas operations, and outline ways operators can prepare to meet compliance requirements.

Key Updates to the Quantification Protocol

1. Biannual Inspection Requirements for Pneumatic Pumps

The protocol now mandates two inspections per year (spring/summer and fall/winter) for all pneumatic chemical injection pumps. These inspections must document:

• Stroke count
• Stroke length
• Injection pressure

If a biannual inspection is missed, operators must apply a discount rate penalty, starting at 2.5% for the first missed inspection and increasing with subsequent lapses. This ensures that seasonal variations in pump performance are accurately captured and reported.

2. New Monthly Reporting Requirements for Overall Vent Gas (OVG) Limits

Operators must now demonstrate that total emissions reductions from pneumatic devices, combined with total site-wide venting reported in Petrinex, remain below the OVG limit established under Alberta Directive 060.

If a project lacks precise monthly emissions data, one of two estimation methods must be used:

1. Applying a 1.42 multiplier to a site’s 12-month average emissions reductions to account for seasonal variations.
2. Assuming all pumps operate at their maximum manufacturer-specified rate for the entire month.

If reported emissions exceed the OVG limit, operators must follow the reconciliation process outlined in the protocol or seek approval for alternative methods.

3. Reconciliation of Chemical Injection Volumes

The most accurate method for quantifying injected chemical volumes remains direct metering on a per-pump basis. Sites with metered injection volumes do not need to conduct additional reconciliation or biannual inspections.

For sites without per-pump metering, reconciliation must be done by comparing:

• Calculated injection volumes using protocol-approved formulas
• Recorded delivery receipts for chemical volumes received at the site

If these values cannot be reconciled, operators must apply a 1% discount factor to emissions reductions calculations.

4. Correction to the Pneumatic Pump Emissions Calculation Formula

The protocol has corrected an error in the formula used to calculate the volume of chemical injected by a pneumatic pump. The previous formula incorrectly used the pump piston diameter; the corrected version now correctly applies the piston plunger area to improve accuracy.

What These Changes Mean for Oil & Gas Operators

These protocol updates strengthen emissions accounting but also require more detailed monitoring, reporting, and compliance tracking. Ensuring inspections are conducted on time, chemical volumes are properly reconciled, and emissions limits are met will be critical to avoiding penalties and maintaining a proper record of your inventory.

Operators may adopt these requirements before June 30, 2025, but all projects must comply by July 1, 2025.

For those looking to streamline this new compliance update, integrating pump inspections into existing environmental monitoring workflows can help minimize additional site visits and ensure that data collection aligns with the latest standards.

Your Partner for Regulatory Confidence

By integrating pneumatic pump inspections into our existing fugitive emissions surveys, we make compliance seamless—minimizing additional mobilizations, reducing costs, and ensuring accurate, auditable data.

Montrose is more than a service provider—we’re your compliance partner. Our goal is to simplify regulatory requirements and deliver practical, field-ready solutions that keep your operation efficient and aligned with evolving standards.

Additionally, maintaining a detailed LDAR inventory of pneumatic pumps and other regulated equipment can help operators track inspection schedules, reconcile chemical injection volumes, and ensure accurate emissions reporting. By integrating LDAR inventory management with routine site surveys, operators can reduce administrative burdens and improve data accuracy for reporting.

Have questions about the new memorandum or need help preparing for your biannual inspections?

Let’s talk. We’re here to support your success every step of the way.