AER Bulletin 2014-13

AER Bulletin 2014-13: Revisions to Directive 060: Upstream Petroleum Industry Flaring, Incinerating, and Venting Requirements

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Revisions to Directive 060: Upstream Petroleum Industry Flaring, Incinerating, and Venting Requirements

Apr 15, 2014

This bulletin announces revisions to Alberta Energy Regulator (AER) Directive 060: Upstream Petroleum Industry Flaring, Incinerating, and Venting and the ERCBflare dispersion model.The revisions become effective on June 16, 2014.

During the feedback period on the draft directive from May 8, 2013, to July 10, 2013, the AER received submissions from the public, industry, and its own staff, as well as from the Canadian Association of Petroleum Producers (CAPP). A summary of the stakeholders’ submissions and the AER’s responses is available from the directive’s webpage on the AER website,

Directive 060 contains the requirements for flaring, incinerating, and venting activities conducted in Alberta by all upstream petroleum industry wells and facilities. Directive 060 requirements also apply to pipeline installations that convey gas (e.g., compressor stations, line heaters) licensed by the AER in accordance with the Pipeline Act. Most of these requirements have been developed in consultation with the Clean Air Strategic Alliance (CASA) to eliminate or reduce the potential and observed impacts associated with these activities and ensure that public safety concerns and environmental impacts are addressed prior to commencing flaring, incinerating, and venting activities. Directive 060 requirements also ensure compliance with Alberta Environment and Sustainable Resource Development’s (ESRD’s) Alberta Ambient Air Quality Objectives and Guidelines (AAAQO).

The changes to Directive 060 align with changes proposed by ESRD to the Government of Alberta’s Air Quality Model Guideline (AQMG) and Non-Routine Flaring Management: Modelling Guidance

The changes regarding nonroutine dispersion modelling revisions are based on recommendations from CAPP’s Non-Routine Flaring Task Team (NRFTT). 

The revisions to Directive 060 are also intended to provide the AER with additional jurisdiction to respond to issues and concerns regarding off-lease nonhydrogen sulphide (H2S) hydrocarbon sourced emissions and odours. The proposed revisions are intended to bring hydrocarbon odour requirements in alignment with the Environmental Protection and Enhancement Act (EPEA) and existingodour requirements for processing plants in the Oil and Gas Conservation Rules.

Finally, the AER is issuing a number of nonsubstantive revisions to Directive 060 that are based on recommendations from CASA, the Government of Alberta, and AER staff. A detailed summary of the proposed revisions is provided below.

General changes
to the directive

Directive 060 includes flaring and venting requirements from Interim Directive (ID) 91-3: Heavy Oil/Oil Sands Operations. The area-based definition from ID 91-3 has been removed. A crude bitumen battery is an oil battery with crude bitumen production that has a density of 920 kilograms per cubic metre (kg/m3) or greater at 15 degrees Celsius (°C) for the purpose of Directive 060 only.

With the exception of oil sands mining schemes and operations, Directive 060 applies to all schemes and operations approved under section 10 of the Oil Sands Conservation Act (OSCA). Directive 060 does not apply to any processing plants approved under section 11 of the OSCA

Certain other sections and appendices have been reordered as a result of the revisions.

Revised requirements in the 2014 edition of Directive 060 become effective June 16, 2014. This edition replaces the previous edition issued on November 3, 2011.

Section 2: Solution Gas Management

Sections 2.4 and 2.5 have been rearranged and titles revised to “Conservation at Crude Bitumen Batteries” and “Conservation at Crude Oil Batteries,” respectively. 

Section 2.6, “General Conservation Requirements at all Crude Oil and Crude Bitumen Batteries,” has been added for clarity. Conservation requirement revisions include -$55  000 NPV (revised from -$50 000 NPV) and the AER may direct the licensee to conserve solution gas regardless of economics. Subsection 1(c)( i) has been moved to section 2.10(6).

Section 2.7, “Clustering,” requires the licensee of a multiwell or bitumen development to assess conservation on a project of development area basis regardless of distance. The AER may suspend production at any facility until the economic assessment is complete.

In section 2.9.2, “Economic Evaluation Criteria,” subsection 10 (royalties-in basis) has been moved to subsection 2. An evaluation must be complete on a before-tax basis and must exclude contingency and overhead costs. The production forecast calculation must be reviewed by a qualified technical professional that is a member of the Association as defined in the Engineering and Geoscience and Professions Act.

Section 2.10 has been retitled to “Public Involvement.” Section 2.10 also now states that licensees or operators with continuous solution gas flares, incinerators, or vents are expected to respond to questions or concerns raised by the public in relation to activities related to the flaring, incinerating, and venting of solution gas at upstream petroleum industry facilities. To assist in responding to the public, public information packages should be prepared and provided. The 500 metre (m) radius has been removed.

Emergency or plant upset shut in of production and reduction of solution gas plant inlet requirements in table 1 of section 2.11 do not apply to thermal in-situ production. The operator must meet notification requirements outlined in table 1.

Section 2.13.2, “Data Access,” has been removed. Statistical reports are available on the AER website.

Section 3: Temporary and Well Test Flaring and Incinerating

Section 3.2, “Oil and Gas Well Flaring, Incinerating, and Venting Duration Limits,” includes cleanup, completion workover, and testing operations. Cleanup is considered complete when sand, proppant, or acid are no longer produced or when the gas composition meets the minimum pipeline specifications for the nearest pipeline that could accept the gas.

The volume allowance threshold is defined in three tiers. This is based on the volume of raw gas flowed back from the well (i.e., does not include fuel gas added and co2 or nitrogen used for hydraulic fracturing). These volumes apply to gas well tests only.

Section 3.3.2, “Conditions That Do Not Require a Temporary Flaring Permit,” has been revised to add the word “maximum” to describe sulphur emission rates and gas flow rates. The AER does not require temporary permits for flaring at oil and bitumen batteries. Licensees must meet conservation requirements described in section 2.

Section 3.6 was moved to section 7.12.4 and retitled to “Temporary Flare Stacks and Well Test Flaring Dispersion Modelling.”

Flares and incinerators must not be operated outside design operating ranges as specified by the designing or reviewing qualified technical professional that is a member of the Association as defined in the Engineering and Geoscience Professions Act.

The site-specific requirement related to well flaring secondary containment requirement has been removed because it is covered in Directive 056: Energy Development Applications and Schedules.

Notification must include information about duration and volume from flowback operations. Reported volumes must distinguish volumes from flared hydrocarbon gas to surface and volumes from vented nitrogen or carbon dioxide used in fracturing fluid.

Section 7: Performance Requirements

Licensees, operators, and approval holders must ensure that a qualified technical professional that is a member of the Association as defined in the Engineering and Geoscience Professions Act is responsible for the design or review of flare and incinerator systems, including separation, related piping, and controls, and for the specification of safe operating procedures.

In section 7.1.2, “Minimum Residence Time and Exit Temperature for Incinerators,” the requirement for the facility to automatically shut down if the exit temperature drops below 600°C has been increased from 10 moles per kilomole (mol/kmol) H2S to 50 mol/kmol H2S.

For batteries regulated as bitumen sites where the maximum potential H2S release rate is greater than 0.04 m3 per hour, the minimum height above ground level for the flare stack or incinerator has been increased from 4 m to 12 m. A greater height may be required to ensure that the AAAQO are not exceeded. Existing batteries regulated as bitumen sites must meet the minimum height requirement by December 31, 2015.

In section 7.6, “Liquid Separation,” manually operated flares and visual level indicators are not required where the operator has operating procedures in place to ensure that no liquids are present. In the absence of an adequate operating procedure, the separator or knockout must be emptied before each flaring event. Where only manually operated flaring will occur and the operation is continuously attended, high-level facility shut downs or alarms are not required.  

Flare knockout drums and integral knockout drums are exempt from flare and incinerator spacing requirements provided that they have no means to vent to atmosphere. The incinerator that combusts gas from the sulphur recovery process is not required to meet incinerator spacing requirements for sulphur plant process equipment (i.e., converters and condensers).

Licensees, operators, and approval holders must immediately report fires (both on and off lease) caused by flares or incinerators to the local field centre.

All existing flare pits must be decommissioned by December 31, 2015.

All references to ESRD’sEmergency Process Upset Flaring Management Guidance have been replaced with the Non-Routine Flaring Modelling Guidance.

SO2 cumulative emissions assessments are not required for nonroutine flaring.

All references to AER low risk criteria in section 7.12.4, “Temporary and Well Test Flaring Dispersion Modelling,” have been changed to the risk-based criteria. The risk-based criteria is described in ESRD’s Non-Routine Flaring Modelling Guidance. 

Section 7.12.5, “Nonroutine Flaring Dispersion Modelling,” has been added, which requires licensees to assess the impacts of nonroutine sour gas flaring from permanent flares on ambient air within the specified timelines. The licensee must apply the flare management strategy flowchart before using modelling methods described in ESRD’s Non-Routine Flaring Modelling Guidance. Licensees must implement design or operational changes to meet the risk-based criteria. Licensees must post model cases where maximum flaring hours may be exceeded or where a facility has not been modified to comply with the AAAQO. Thenew AERflare dispersion modelling tool replaces the ERCBflare tool.

Unless the AER requires otherwise, where previous modelling reports of nonroutine flare events show compliance with the AAAQO using tools and methods no longer accepted by ESRD (e.g., SCREEN3, RTDM, ISC3, AQMG, and ERCB low risk criteria), the facility can continue to operate as is. If any emission changes occur at the facility or if the AER requests that new dispersion modelling be conducted for any reason, the operator must apply the flare management strategy flowchart and must reassess dispersion modelling using current modelling methodology and tools.

For more information, see the AERflare User Guide: A Screening Model for Non-routine Flaring Approvals and Routine Flare Air Dispersion Modelling for Sour Gas Facilities.

Section 8: Venting and Fugitive Management Requirements

Where metering is not required for gas vented in association with heavy crude or crude bitumen production, the AER may, at any time, request a new GOR or hourly rate test to be performed to verify vented volumes. Refer to section of Directive 017: Measurement Requirements for Oil and Gas Operations for acceptable testing methods. Upon request, the operator must provide the evaluation to the AER within 30 working days.

Both section 8.1 and the footnote in table 2 that states that Temporary venting is not permitted within 500 m of a residence unless consented to by the resident and approved by the AER field Centre have been removed. Consultation is covered in Directive 056. Notification is required instead of consent.

The reference to spacing in Directive 008: Surface Casing Depth Requirements no longer exists. The 35 m spacing clause in Directive 060 has been removed.

Venting and/or fugitive emissions must not result in any offensive hydrocarbon odours outside the lease boundary that, in the opinion of the AER, are unreasonable either because of their frequency, their proximity to surface improvements and surface development (as defined in Directive 056), their duration, or their strength

Requirements relating to Directive 039: Revised Program to Reduce Benzene Emissions from Glycol Dehydrators have been removed from Directive 060.

Section 8.4, “Venting in Heavy Oil/Oil Sands Operations,” has been removed in its entirety as the substantive requirements formerly contained in that section and in ID 91-3 have been moved to other, more applicable sections of Directive 060.

Appendix 1: References and Contacts Cited

The following new references are now cited in the directive:

  • ESRD Non-Routine Flaring Management: Modelling Guidance
  • AERflare User Guide: A Screening Model for Non-Routine Flaring Approvals and Routine Flare Air Dispersion Modelling for Sour Gas Facilities
  • ABflare User Guide: A Refined Air Quality Dispersion Model for Evaluating Non-routine Flaring for Sour Gas Facilities
  • CAPP, 2013, Sour Non-Routine Flaring Framework
  • CAPP, 2006, Best Management Practices for Facility Flare Reduction
  • Engineering and Geoscience Professsions Act, RSA 2000 c. E-11
  • Forest and Prairie Protection Act, RSA 2000 c. F19
  • Forest and Prairie Protection Regulations Part I and II (AR 135/72)

Appendix 2: Definitions of Terms used in Directive 060

The following definitions have been added: routine flaring, venting and incinerating, nonroutine flaring venting and incinerating, planned flaring, unplanned flaring, upset flaring, emergency flaring, crude bitumen, crude bitumen battery, crude oil, crude oil battery, heavy oil, qualified technical professional, risk-based criteria, sour gas, and site.

Appendix 7: Air Quality Plans for Temporary SO2 Emissions

The management plan must clearly define under what conditions flaring or incinerating may resume if suspended or return to normal operations if a management option such as fuel gas is proposed. Flaring or incinerating must remain suspended for at least one hour before operations may resumeto prevent an exceedance or to respond to an exceedance.

Real-time dispersion modelling flare management plans must be based on maximum predicted concentrations. Pseudo input parameters must be calculated using AERFlare. If real-time dispersion modelling goes down, the operator must revert to a conventional flare management plan or shut in the well.

Appendix 8: Screening Dispersion Modelling Using AER Spreadsheet

For more information, see AERflare User Guide: A Screening Model for Non-Routine Flaring Approvals and Routine Flare Air Dispersion Modelling for Sour Gas Facilities

Sections 3.1, 3.2, and 3.3(1) and figure 1 from ID 91-3 have been rescinded and superseded by this edition of Directive 060.

The new edition of Directive 060 is available on the AER website, Printed copies of the directive may be purchased from the AER Information Management Branch, Suite 1000 , 250 – 5 Street SW, Calgary, Alberta; telephone: 403-297-8311 or 1-855-297-8311 (toll free); fax: 403-297-7040; e-mail:

The AER will be hosting information sessions on the revisions to Directive 060 for industry personnel who regularly file subsurface applications. The session details will be announced shortly on the AER website.

Questions about Directive 060 may be directed to the Directive 060 inbox at

<original signed by>

Jim Ellis
President and Chief Executive Officer