Bulletin 2013-17

Bulletin 2013-17: Invitation for Feedback on Draft Revised Edition of Directive 060: Upstream Petroleum Industry Flaring, Incinerating, and Venting Requirements

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Invitation for Feedback on Draft Revised Edition of Directive 060: Upstream Petroleum Industry Flaring, Incinerating, and Venting Requirements

May 08, 2013

The Energy Resources Conservation Board (ERCB) invites stakeholders to provide feedback on proposed revisions to Directive 060: Upstream Petroleum Industry Flaring, Incinerating, and Venting (Directive 060) and ERCBflare version 2.

ERCB Directive 060 contains the requirements for flaring, incinerating, and venting at all upstream petroleum industry wells and facilities in Alberta. Directive 060 requirements also apply to pipeline installations that convey gas (e.g., compressor stations, line heaters, etc.) licensed by the ERCB 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 before beginning to flare, incinerate, or vent. Directive 060 requirements are also aligned to ensure compliance with Alberta Environment and Sustainable Resource Development’s (ESRD’s) Ambient Air Quality Objectives and Guidelines (AAAQO).

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

The proposed changes in nonroutine dispersion modelling revisions are based on recommendations of the Canadian Association Petroleum Producers (CAPP) Non-Routine Flaring Task Team.

The proposed revisions to Directive 060 are also intended to provide the ERCB with additional jurisdiction to respond to issues and concerns about off-lease non-hydrogen sulphide (H2S) hydrocarbon-sourced emissions and odours. The proposed revisions are intended to bring hydrocarbon odour requirements in alignment with existing odour requirements for processing plants specified in the Oil and Gas Conservation Regulation.

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

General changes to the directive Directive 060 includes flaring and venting requirements from the Interim Directive (ID) 91-3: Heavy Oil/Oil Sands Operations. Directive 060 defines—for the purpose of Directive 060 only—the area in which bitumen sites are regulated (appendix 12).

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

Revised requirements in the 2013 edition of Directive 060 are effective October 1, 2013. This version replaces the previous edition issued November 3, 2011.

Section 2: Solution Gas Management Sections 2.4 and 2.5 have been rearranged and titles have been 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 net present value (NPV) (revised from -$50 000 NPV), and the ERCB may direct the licensee to conserve solution gas regardless of economics.

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

Economic Evaluation Criteria section 10 (royalties-in basis) has been moved to section 2. Evaluation must be complete on a before-tax basis and must exclude contingency and overhead costs. The production forecast must be calculated by a qualified technical professional who is a member of the association as defined in the Engineering and Geoscience and Professions Act.

Section 2.10 “Consultation and Notification” has been removed and replaced with “Public Involvement.” 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, incineration, and venting of solution gas at upstream petroleum industry facilities. To help respond to the public, public information packages should be prepared and provided.

Section 2.11.1 “Limitations on Nonroutine Flaring, Incineration, and Venting During Outages at Solution Gas Conserving Facilities” table 1 does not apply to thermal in-situ production.

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

The volume allowance threshold is defined in three tiers. This is based on the volume of raw gas that has flowed back from the well (this does not include fuel gas added and CO2 or nitrogen used for hydraulic fracturing). These volumes apply to gas well tests only.

The ERCB may suspend well flaring or incineration for noncompliance with conditions of the permit. The licensee must comply with the conditions of the temporary flaring permit.

Section 3.3.2 “Conditions That Do Not Require a Temporary Flaring Permit” has been revised to add the word “instantaneous” to describe sulphur emission rates and “Gas flow rates do not exceed 10 103/d” has been removed. The ERCB 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 “Temporary Flare Stacks and Well Test Flaring Dispersion Modelling.”
Flares and incinerators must not be operated outside of design operating ranges as specified by the designing or reviewing qualified technical professional who is a member of the association as defined in the Engineering and Geoscience Professions Act.

The site-specific requirement related to the well flaring secondary containment requirement has been removed because it is covered in Directive 056.
Table 2 notification requirements include information about duration and volume from flow-back 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 who 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 install automatic shut down if the exit temperature drops below 600oC has been increased from 10 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/hr, the minimum height above ground level for the flare stack or incinerator has been increased from 4 m to 12 m, or such greater height as may be required to ensure that the AAAQO are not exceeded.

In section 7.6, “Liquid Separation,” for manually operated flares, visual level indicators are not required where the operator has operating procedures in place to ensure that no liquids are present. Where only manually operated flaring will occur and the operation is continuously attended, high-level facility shut downs or alarms are not required.

Flare knock-out drums and integral knock-out drums are exempt from flare and incinerator spacing requirements provided 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).

All existing flare pits must be decommissioned by December 31, 2014.

All references to ESRD’s Emergency Process Upset Flaring Management Guidance are replaced with the Non-Routine Flaring Modelling Guidance.

SO2 cumulative emissions assessment is not required for nonroutine flaring.

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

New section 7.12.5, “Non-Routine Flaring Dispersion Modelling,” has been added. It requires licensees to assess 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 the ESRD Non-Routine Flaring Modelling Guidance. Licensees must implement design or operational changes so that the risk based criteria are met. 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. A new ERCBflare version 2 dispersion modelling tool will replace the existing tool. For more information, see the ERCBflare 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 Emissions Management Requirements Where metering is not required for gas vented in association with heavy crude or crude bitumen production, the ERCB may at any time request a new gas:oil ratio or hourly rate test to verify vented volumes. Refer to Directive 017: Measurement Requirements for Oil and Gas Operations, section for acceptable testing methods. Upon request, the operator must provide the evaluation to the ERCB within 30 working days.

Venting or fugitive emissions must not result in any hydrocarbon odours outside the lease boundary that, in the opinion of the ERCB, 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 of the odour.

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 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.

Section 11: Dealing with Public Concerns/Objections Section 2.11 “Dealing with Public Concerns/Objections” has been removed. This is covered in section 2.10 and Directive 056.
Appendix 1: References and Contacts Cited New references cited:
ESRD Non-routine Flaring Management: Modelling Guidance
ERCBflare 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 Parts I and II (AR 135/72)
Appendix 2: Definitions of Terms used in Directive 060 New definitions 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, 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. Flaring or incinerating must remain suspended for at least one hour before operations may resume, in order to 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 ERCBFlare. If real-time dispersion modelling goes down, the operator must revert to a conventional flare management plan or shut in.
Appendix 8: Screening Dispersion Modelling Using ERCB Spreadsheet For more information, refer to ERCBflare User Guide: A Screening Model for Non-routine Flaring Approvals and Routine Flare Air Dispersion Modelling for Sour Gas Facilities.
Appendix 12 New Map: Directive 060 Area Regulated as Bitumen Sites.

The ERCB is seeking stakeholder feedback on the changes to Directive 060 and the ERCBflare version 2 dispersion modelling tool by July 10, 2013. All feedback received will be reviewed for the purposes noted in the bulletin and used for the purposes of the directive changes. All of the comments provided through this consultation will form part of the public record and, at the discretion of the ERCB, any comment received may also be attributed to the specific individual(s) providing it. Personal information provided with comments will be collected, used and disclosed in accordance with the Freedom of Information and Protection of Privacy Act. The ERCB may use the personal contact information you provide for follow-up communication related to your feedback.

Revised Directive 060 showing the proposed revisions is available on the ERCB website www.ercb.ca. Printed copies of the directive may be purchased from ERCB Information Services, Suite 1000, 250 – 5 Street SW, by telephone at 403-297-8311 or (toll free) at 1-855-297-8311, by fax at 403-297-7040, or by e-mail at infoservices@ercb.ca.

Any feedback or questions may be directed to the ERCB Flaring and Venting Team by e-mail at Directive060Inbox@ercb.ca .

The ERCB plans to hold information sessions about the new Directive 060 requirements and ERCBflare once all of the changes have been incorporated into the document. Details about these sessions will be posted on the ERCB website once they are finalized.

<original signed by>

Robin King
Executive Manager
Field Surveillance and Operations Branch