Finalized in March 2025, Canada’s Reduction in the Release of Volatile Organic Compounds (Storage and Loading of Volatile Petroleum Liquids) Regulations establish national requirements for controlling VOC emissions from petroleum liquid storage and loading operations. The regulation covers tanks, loading racks, and the associated vapour control system. Trinity previously covered the key highlights of this new regulation in an article last year. In this article, we are focusing on the leak detection and repair (LDAR) requirements that apply specifically to vapour control systems.
Under this regulation, a vapour control system is not considered compliant simply because it is installed. The regulation is structured to ensure the system remains effective over time. That is why the rule ties compliance directly to recurring inspections, instrument-based leak detection, performance testing, and defined repair timelines for leaks and other defects.
Key compliance timing
The Regulations came into force (CIF) on March 7, 2025 making March 7, 2026 as the CIF anniversary and therefore, the timeline for commencement of compliance requirements for all existing vapour control systems. For new systems, the requirements kick in immediately following commencement of operations of the new vapour control systems.
Existing facilities should therefore treat March 7, 2026 as a planning anchor to develop a consistent schedule for monthly and annual inspections, performance testing, and repair tracking.
Monthly visual inspection requirements
The regulation requires that operators visually inspect vapour control systems on a defined monthly cadence. Specifically, the operator must, at least once a month and no less than 14 days after the day the previous inspection was performed, visually inspect all components of each vapour control system for vapour leaks, liquid leaks, or any other visually detectable defects.
If a tank or loading rack is not in service, the operator may delay or omit the inspections in section 86 of the regulation until 30 days after the tank or loading rack is returned to service. That flexibility is useful for intermittent operations, but it also makes restart planning important. When a unit returns to service, the inspection schedule needs to resume promptly to remain aligned with the rule.
Annual instrument-based leak detection
In addition to monthly visual inspections, operators must complete an annual instrument-based inspection for vapour leaks. The operator must, at least once in a calendar year and no less than 10 months after the day the previous inspection was performed, inspect each vapour control system for vapour leaks using one of the specified leak detection instruments. (Regulations, s. 86(2)).
The instrument types that qualify for detecting vapour leaks are defined in section 26. An instrument used to determine the presence of VOCs in vapour form, including for detecting vapour leaks, must be one of the following:
- a portable monitoring instrument, or
- an optical gas-imaging instrument, or
- a combustible gas detector with a catalytic bead sensor that meets the section 28 requirements.
Each instrument type has specific minimum requirements to be met as per the rules. In Trinity’s experience, the two most commonly used instruments for LDAR programs are:
- Flame ionization detectors (FIDs) as outlined by the United States Environmental Protection Agency (US EPA) Method 21 – Volatile Organic Compound Leaks. The FIDs can detect and quantify leaks at accessible connectors, flanges and other locations where leaks may occur.
- Optical gas imaging (OGI) cameras. OGI cameras allow for leak detection of larger or difficult access locations. Leaks appear as a smoke plume on the camera indicating leak locations.
Performance testing
Leak detection confirms whether the system is tight. Performance testing confirms whether the system is performing adequately relative to the standards defined for vapour control systems. Section 87 of the regulation requires the operator to test the performance of each vapour control system for the defects referred to in section 90(3) within the time limits in the design specifications and at least once every five years.
Where applicable, section 88 ties performance testing for vapour recovery and vapour destruction systems to the CAN/CGSB-3.1000 standard with specific modifications in the regulation. (Regulations, s. 88).
The 45-day repair deadline
When a vapour control system defect is detected, the operator must act within a defined period. The operator must, within 45 days after the day on which a defect is detected, either repair the defect and perform any tests or inspections necessary to confirm the repair is successful or use a temporary vapour control system. (Regulations, s. 90(1)).
Section 90(3) defines defects for vapour control systems. In addition to vapour leaks and liquid leaks, defects include situations where a recovery or destruction system has a continuous monitoring device that does not meet section 54 requirements, or where its VOC recovery or destruction performance is insufficient to meet the applicable performance requirements.
Recordkeeping
LDAR compliance consists of more than field work. It also requires records that make inspection timing, testing, and repairs traceable.
Section 109 sets recordkeeping requirements for vapour control systems. Those records include, among other items, the dates and duration of in-service and out-of-service periods, reasons for out-of-service periods, standard operating procedures, and a maintenance plan that includes the latest allowable dates of the next inspections under section 86 and the next performance test under section 87. Section 109 also requires detailed information about performance tests, including instruments used and calibration test details.
For many operators, the most practical approach is to embed these requirements into an equipment-specific maintenance plan and to use that plan as the schedule-control mechanism for the 14-day, 10-month, and five-year timing requirements.
How Trinity can assist
Trinity supports facilities in translating regulatory requirements into practical LDAR programs that can be executed consistently across sites and operating conditions. Trinity has an experienced team with extensive experience with visual inspections, leak tests and performance testing of vapour control units following the CAN/CGSB-3.1000 standard. Using flame ionization detectors (FIDs) or non-dispersive infrared (NDIR) sensors, Trinity can quantitatively measure the exhaust gas stream emissions and efficiency of vapour control units (VCUs).
If you would like assistance reviewing your facility’s compliance program or designing and implementing LDAR or performance testing programs, please email Steve Babaris in Trinity’s Toronto office or call us at 416.391.2527.
