Atmospheric Emission - Flaring

• Petroleum Act 1998
• Petroleum Licensing (Exploration and Production) (Seaward and Landward Areas) Regulations 2004
• Petroleum Licensing (Production) (Seaward Areas) Regulations 2008

These Regulations consolidate with amendments the provisions of the Petroleum (Production) Regulations 1982 (as amended) in relation to (a) applications to the Secretary of State for petroleum production licences in respect of seaward areas and (b) applications to the Secretary of State for petroleum exploration licences in respect of seaward areas and landward areas below the low water line.

• The Petroleum (Current Model Clauses) Order 1999

An objective of the Petroleum Act 1998 is to conserve gas, a finite energy resource, by avoiding unnecessary wastage during the production of hydrocarbons from the UKCS. The actual Model Clause may vary depending on when the Block Licence was granted, but in recent licences flaring is covered by Paragraph 3 of Model Clause 21, and this states that the Licensee that not flare any gas from the licensed area or use gas for gas lift except with written consent.

• Climate Change Act 2008

The Act sets up a framework for the UK to achieve its long-term goals of reducing greenhouse gas emissions and to ensure steps are taken towards adapting to the impact of climate change. The Act enables a number of elements (see EU ETS Pending Legislation).

• Council Directive 2003/87/EC establishing a scheme for greenhouse gas emission allowance trading with the community

The Directive applies (amongst others) to installations with combustion facilities with a combined rated thermal input of >20 MW (th). This is a statutory scheme for those relevant installations. The aim of the Directive is to achieve reductions in GHG emissions as outlined by the Kyoto Protocol.

The EU Emissions Trading Directive covers the six greenhouse gasses that are included in the Kyoto Protocol. However to date only CO2 emissions are covered. The scheme may be expanded in future phases to the other greenhouse gases (See EU ETS Topic for further details).

• Energy Act 1976

Some flaring which has not been permitted under the licence model clauses is covered by this legislation, although it is mostly used for issue of vent consents (see Venting).

DECC Guidance Notes for the Completion of Flare and Vent Applications (Revised)

For EU ETS Guidance see EU ETS

Consent to Flare

Where a field is flaring > 50 tonnes per day the flare level will be reviewed and a flare consent issued annually. These applications will be subject to detailed review by DECC and operators must exercise a high level of technical and operational dilligence in estimating quantities. This level of flaring is considered to represent a potential opportunity for further reduction in levels. These applications will need full supporting details with medium and long term plans for flare reduction.

Where a field is flaring < 50 tonnes per day, a longer term flare consent may be applied for/issued (see Renewal). Less detailed (minimum) information may be provided on the application form for these flaring levels.

See Performance Standards for options for multiple fields producing across the same facility.

Note that at the field start-up a series of consents may be issued for short periods (usually for 28 days or a calendar month) to allow DECC closer control over the operation. As the commissioning programme progresses, DECC may issue consents for longer periods as greater plant stability is achieved.

EU Emissions Trading Scheme

See EU ETS Topic

Consent to Flare

For a new flare consent, contact should be made in the first instance with the appropriate Consents Unit within DECC (see below) approximately 3-4 months before start-up. This will kick off a series of meetings and request for background information (see below). Formal written application for the first flare consent should be made approximately 2 weeks prior to first oil. The consent will not be issued until the first oil date is confirmed.

The DECC Guidance Notes for the Completion of Flare and Vent Applications provide further information.

Information that will be required during initial discussions with DECC for a first flare consent application will include the following:

• A description of gas plant and flare equipment to be commissioned. · A description of how the wells will be brought on stream. · A detailed description of the plant start-up procedures and philosophy; the procedure for filling the gas export line should also be described.
• The commissioning schedule.
• Flaring calculations – to include flaring on a daily basis and total quantities. This should also show the target design flare levels for stable conditions once commissioning is complete.
• Sketches and figures should also be supplied for:
  • Overall commissioning programme;
  • Fuel gas system
  • Gas dehydration system;
• Gas compression system;
• Gas export system and pipeline; and
• Onshore facilities.

Initial consent application in the form of a letter, should include the following as a minimum:

• Flare level for consent being applied for (usually for a 28 day period);
• Justification of how this figure has been arrived at, including GOR rates etc.
• Description of the work being carried out during the 28 day period.

For an annual flare consent application (see Renewal for more information), information required includes

• A summary of the main points of the application.
• A summary of the main flaring assumptions, including any flare reduction projects planned through the year
• Flaring calculations – to include flaring on a monthly basis and total quantities.

EU Emissions Trading Scheme

See EU ETS Topic

Flare Consent

DECC Oil and Gas Office contacts for Consent to Flare applications are as follows:

Northern and Central North Sea
Carol Campbell
Tel: 01224 254052
Email: carol.campbelll@decc.gsi.gov.uk

Southern North Sea and Onshore
Ivor Newman
Tel: 020 7215 5163
Email: ivor.newman@decc.gsi.gov.uk

EU Emissions Trading Scheme

See EU ETS Topic

Flare Consent

First discussions with DECC should be held at least 3-4 months before “first oil”.  However, it is advised by DECC that the operator is in contact at all stages, from design through construction to commissioning planning and demonstrate that all reasonable steps have been taken to keep flaring to a minimum.

Application for a first consent should be made at least 2 weeks before “first oil”.  Consent will not be issued until the “first oil” date is confirmed.

See Renewal for more information on ongoing annual applications.

EU Emissions Trading Scheme

See EU ETS Topic

Consent will specify the flare volume that must not be exceeded over a specified time. If there is any possibility that the consented rate for the period may be exceeded, the operator must contact DECC immediately to discuss the difficulties encountered and if appropriate arrange for a revision of the consent.

DECC has an objective to reduce non-safety related flaring by 5% per year (see Snippets). Reductions in flaring are achieved through close cooperation between DECC and the operators, rather than prescriptive limits.

DECC has provided definitions for three categories of flare sources:

• Category 1 Base Load Flare - this includes all the gas used for safe and efficient operation of the process facility and flare system under normal operating conditions.
• Category 2 Flaring from Operational or Mode Changes - this includes gas flaring resulting from the start up and planned shut down of equipment during production amongst others.
• Category 3 Emergency Shutdown/Process Trip - this includes any gas flared during an emergency.
• Cateogry 4 Unignited Vents - note this would fall under the Vent Consent not the Flare Consent (see Venting)

More definition is provided in the DECC Guidance on the Completion of Flare and Vent Applications.

Note: Cold flaring is considered a venting activity and should not be included in flaring reports or against a flaring consent.

Where several fields tie-in to common facilities and flare is < 50 tonnes per day, and the fields have the same operator and licensees, the operator may apply for a single composite consent and the level of flaring permitted in this consent will be based on the sum of the individual field contributions to the total flare level.

Where the fileds have different operators and licensees, usually separate consents will continue to be issued. However, if all parties agree to apply for a single flare consent covering all the fields going into the facilities and the total flare level is < 50 tonnes per day then a combined 3-year flare consent will be considered.

See EU ETS Topic for EU ETS performance standards.

• Daily flare and cumulative flare volumes.
• Downtime/uptime of gas plant.

Note: Cold flaring is considered a venting activity and should not be included in flaring reports or against a flaring consent.

Reporting must be in mass units (water dry metric tonnes).

There are a number of methods to quantify gas volume flared and likewise a number of methods to convert this to a mass basis. Flare quantification is in accordance with the requirements for flaring associated with the EU-ETS Phase II. Operators should ensure that the methodology they have in place meets or exceeds the necessary levels of accuracy (see EU ETS).

See EU ETS Topic for EU ETS monitoring and sampling requirements

There are two types of reporting required for flaring. The first is statutory reporting to DECC the second is voluntary reporting of environmental emissions due to flaring which is used by Oil & Gas UK to report industry performance.

Flare Consent : the following shall be sent to DECC for the previous reporting period (as specified in the Flare Consent).

• Short technical summary of performance of gas handling plant, highlighting any features which have affected or could affect the operation of the plant.
• Rates in respect to oil production, gas production, gas export, gas used for fuel and of gas flare.
• Cumulative average production for production and flare.
• Calculations of gas compression plant efficiency.

Some consents may include the provision that specific monthly flare reporting is not needed and that flare volumes are reported in the routine field reporting into DECC Petroleum Production Reporting System (PPRS). In this case, specific flare reporting would be by exception only if flaring is out of consent.

EEMS Reporting : Complete relevant parts of applicable atmospheric emissions inventory EEMS pro forma that can be downloaded from the EEMS Website. Guidance notes are also available from the EEMS site.

See Above

Flare Consent : DECC’s Petroleum Production Reporting according to terms of consent.

EEMS Reporting : Completed reports should be submitted electronically to the EEMS website.

Statutory information: Frequency of reporting will be established through consent (e.g. weekly or monthly). It varies widely according to stage of field production and between fields and operators.

For fields on long-term flare consents, there will be no need for end of year flare reporting.

EEMS Reporting : Annually by 7th February.

If there is a possibility of exceeding the flare consent value, contact should be made with DECC to discuss the problems, and if appropriate to arrange for a revised consent.

It is unlawful to flare gas without a current consent and in extreme cases this could lead to withdrawal of the licence.

Non-compliances should be reported through the routine flare consent reporting or, if there is no specific routine flare reporting, then breach of exemption conditions should be reported at month end as they occur. Early phone contact with DECC is recommended before consent limits are exceeded.

A permit is no longer required for potential flare drop-out. However, if flare drop out does occur resulting in an oil sheen at sea, a PON1 report must be submitted.

Applications can be made for flare consents covering the remaining duration of Phase 2 of the EU-ETS (the period 1 January 2010 – 31 December 2012) or on an annual basis, depending upon the total daily hydrocarbon flare level from a field or a grouping of fields going through an installation(s).

Long term flare consents will not be permitted for any field or grouping of fields going through an installation(s) that seek permission to flare at rates in excess of 50 tonnes a day.

If a field is flaring less than 50 tonnes of hydrocarbon gas a day, and if, for the period 2010 to 2012 the flare application does not request any increase in the levels permitted in the extant flare consent, licensees can apply for a three year flare consent.  If this application is approved by the Department, a long term consent will be issued, subject to a number of conditions (see DECC Guidance on the Completion of Flare and Vent Applications)

Commissioning phases - re-application should be made approximately 2 weeks before the next consent period.

Annual ongoing flare consents. DECC will invite applications for renewal in September each year, with annual consents being issued in December for the following year. DECC Guidance on the Completion of Flare and Vent Applications is available on DECC website.

See EU ETS Topic

None known at present. Also see EU ETS.

This is considered to be a venting activity, and controlled under the venting consent (see Venting) . It should not be reported as flaring, or counted against the flaring consent.