FRAMEWORK
Sour Non-Routine Flaring
November 15th, 2013
Publication Number 2014-0006
2100, 350 – 7 Avenue S.W. Calgary, Alberta Canada T2P 3N9 Tel 403-267-1100 Fax 403-261-4622
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www.capp.ca [email protected]
The Canadian Association of Petroleum Producers (CAPP) represents 130
companies that explore for, develop and produce natural gas, natural gas liquids,
crude oil, oil sands, and elemental sulphur throughout Canada. CAPP member
companies produce more than 90 percent of Canada’s natural gas and crude oil.
CAPP also has 150 associate members that provide a wide range of services that
support the upstream crude oil and natural gas industry. Together, these members
and associate members are an important part of a $120-billion-a-year national
industry that affects the livelihoods of more than half a million Canadians.
Disclaimer
This publication was prepared for the Canadian Association of Petroleum
Producers (CAPP). While it is believed that the information contained herein is
reliable under the conditions and subject to the limitations set out, CAPP does
not guarantee its accuracy. The use of this report or any information contained
will be at the user’s sole risk, regardless of any fault or negligence of CAPP or
its co-funders.
November 15, 2013 Non-Routine Flaring Framework Page ii
Overview
The document here within is supported by both industry and government. It is a
historical account of what has been seen in Alberta Environment and Sustainable
Resource Development’s modelling guidelines and section 7.12 in the Energy
Resources Conservation Board (ERCB) Directive 060 (D060). In 2004 a
partnership team between government and industry was formed to develop a
comprehensive management plan for non-routine flares. This team was named the
Non-routine Flaring Task Team (NRFTT).
Flaring can occur during routine and non-routine situations. Routine events occur
as a result of the normal operation of a facility or process while non-routine
events are considered as outside the normal operation of a facility. Non-routine
flaring occurs during events such as planned maintenance activities, and
unplanned upsets and emergencies, and are usually both infrequent and of short
duration.
Although a comprehensive flare management plan was deemed necessary to
address the compliance and enforcement of non-routine flaring, it was necessary
to find ways of simplifying this plan as much as possible in order to regulate it
practically. As such, to avoid confusion over what flare events are considered
upsets or emergencies, both of these flare events were grouped into unplanned
flare events.
Industry recognizes the importance of not exceeding Alberta Ambient Air Quality
Objectives (AAAQOs). Historically, regulatory dispersion modelling for
continuous sources were applied to non-routine flares and did not account for the
infrequent, short term nature of non-routine flaring events. The approach
proposed and supported by industry and government recognizes the distinction
between Risk Based Criteria modelling versus Risk Based Criteria observations.
The approach taken by the NRFTT is based on an equivalent level of risk and
reflects regulatory requirements. Monitored exceedances of the AAAQOs must be
reported and may be subject to enforcement action.
Prior to adopting the non-routine flaring management framework, air dispersion
modelling for non-routine flaring was performed assuming a continuous source
operating at all hours in the modelling period, which is usually a five year period
as outlined in Section 4. This is considered the correct modelling approach as
non-routine flaring includes unplanned events in which non-routine flaring could
take place at any time and regulators need to know the potential impacts that non-
routine flaring can cause under all possible meteorological conditions. The
problem with this approach is that up to now there has not been a way to address
the infrequent nature of these events. Prior to adopting the non-routine flaring
management framework, the way for determining compliance of non-routine
flares from an air dispersion modelling perspective was the same as a continuous
source or well test as outlined in Section 2.1. Essentially, it has been assumed that
non-routine flares operate continuously for compliance purposes.
November 15, 2013 Non-Routine Flaring Framework Page iii
Risk considers both the chance of a predicted exceedance of the AAAQOs and the
frequency of events. The chance of a predicted exceedance is determined from air
dispersion model predictions as the number of predicted exceedances divided by
the duration of the meteorological data file used. The frequency of events is how
often a source emits over a year
Directive 060 outlines the low risk criteria (2011) that was developed for well test
flaring and can be applied to modelling results for all non-routine sour gas flaring
events. The ERCB low risk criteria considers exceedances based on each hour of
the modelling period rather than on a receptor basis like the ESRD modelling
criteria. Therefore, it is not possible to do a comparative analysis of the two
methods.
This document outlines the new regulatory approach and comprehensive plan for
managing non-routine flaring as developed by the NRFTT, and the process that
lead to its development.
This document is also a historical account of the work done by the NRFTT. As
such, the document uses the previous name of the newly created Alberta Energy
Regulator, that being the Energy Resources Conservation Board. This was simply
done for continuity purposes within the historical record.
November 15, 2013 Non-Routine Flaring Framework Page iv
Non-routine Flaring Task Team List of Acronyms
AAAQOs Alberta Ambient Air Quality Objectives
AENV Alberta Environment
AER Alberta Energy Regulator
AQMG Air Quality Model Guideline
AQMP Air Quality Management Plan
AUPRF Alberta Upstream Petroleum Research Fund
BMP Best Management Practices
CAPP Canadian Association of Petroleum Producers
D060 Directive 060
D071 Directive 071
EPEA Environmental Protection and Enhancement Act
ERCB Energy Resources Conservation Board
ESRD Alberta Environment and Sustainable Resource Development
EUB Energy and Utilities Board
FMSF Flare Management Strategy Flowchart
GUI Graphical User Interface
H2S Hydrogen Sulphide
NRFTT Non-routine Flaring Task Team
PSV(s) Pressure Safety Valve(s)
PTAC Petroleum Technology Alliance Canada
RBC Risk Based Criteria
SEPAC Small Explorers and Producers Association of Canada
SO2 Sulphur Dioxide
TOR Terms of Reference
November 15, 2013 Non-Routine Flaring Framework Page v
US EPA United States Environmental Protection Agency
November 15, 2013 Non-Routine Flaring Framework Page vi
Contents
Overview ............................................................................................................................. ii
1 Introduction ..............................................................................................................1
2 Background ..............................................................................................................3
2.1 Previous Regulatory Approach ....................................................................3 2.2 Formation of Non-routine Flaring Task Team .............................................4 2.3 Potential Solutions .......................................................................................5 2.4 Comprehensive Non-Routine Flaring Framework.......................................5
3 Best Management Practices for Facility Flare Reduction ........................................7
4 Air Dispersion Modelling Guidance ......................................................................12
4.1 Sources to be Modelled ..............................................................................14
5 Meteorological Data Improvements ......................................................................15
6 Risk-Based Modelling Criteria for Non-routine Flaring .......................................16
6.1 Calculation of Risk ....................................................................................16 6.2 AQMG Routine Emission Source Modelling Criteria ...............................17
6.3 ERCB Low Risk Criteria ...........................................................................17 6.4 Risk-Based Modelling Criteria for Non-Routine Flares ............................18
6.4.1 Planned Flaring ..............................................................................19
6.4.2 Unplanned Flaring .........................................................................19
6.5 Discussion ..................................................................................................20
7 Pilot Initial 2007-08 Test of Concept Program ......................................................22
8 Comprehensive Management for Non-Routine Flaring ........................................23
9 Development of Dispersion Modelling Tools ........................................................27
10 Timelines – Implementation ..................................................................................28
11 Next Steps ..........................................................................................................2928
References ..........................................................................................................................30
November 15, 2013 Non-Routine Flaring Framework Page vii
Figures
Figure 3.1 Flare Management Strategy Flowchart ................................................................. 11 Figure 6.1 Graphical Representation of Non-Routine Modelling Hourly Risk Criteria ........ 21 Figure 8.1 Comprehensive Management for Non-Routine Flaring of Sour Gas ................... 26
Tables
Table 2.1 Potential Solutions Identified and Evaluated .......................................................... 5 Table 6.1 Summary of Non-Routine Modelling Hourly Risk Criteria ................................. 21
November 15, 2013 Non-Routine Flaring Framework 1
1 Introduction
Flaring is a controlled combustion process used to dispose of natural gases (sweet
gas, sour gas, acid gas or other hydrocarbon vapour) through a vertical stack.
Facilities in the oil and gas industry may routinely flare small volumes of natural
gas that are technically difficult and/or uneconomic to conserve. Flaring is also an
important safety measure, used to safely dispose of natural gas that would
otherwise pose a hazard to workers, nearby residents and facility equipment
during non-routine occurrences like emergencies, process upsets, equipment
failure and power failure conditions. Flaring is recognized as an important issue
for the upstream oil and gas industry for health, safety and environmental impacts,
as well as conservation of energy resources.
Sour gas flaring is a concern to the environment as it results in the emissions of
sulphur dioxide (SO2) that on both a short-term and long-term basis, and at high
enough concentrations and exposure durations can have adverse impacts on
humans and animals and can cause damage to vegetation. Additionally, on a long-
term basis, SO2 emissions can also contribute to acidification of soils and water
bodies. For these reasons, flaring is a strictly regulated process of the oil and gas
industry.
Flaring can occur during routine and non-routine situations. Routine events occur
as a result of the normal operation of a facility or process while non-routine
events are considered as outside the normal operation of a facility. Non-routine
flaring occurs during events such as planned maintenance activities, and
unplanned upsets and emergencies, and are usually both infrequent and of short
duration.
Energy Resources Conservation Board (ERCB) Directive 060: Upstream
Petroleum Industry Flaring, Incinerating, and Venting (D060) (ERCB2011) is the
regulatory document (as amended from time to time) that outlines requirements,
guidelines and recommendations for flaring, incineration and venting in the
upstream oil and gas industry in Alberta. D060 was first introduced in 1999 with a
subsequent clarification document released in 2001. Part of the flare performance
requirements in D060 is that all existing and proposed permanent stacks that
flare sour gas must be designed to meet the requirements set by Alberta
Environment and Sustainable Resource Development (ESRD), formerly Alberta
Environment, mainly the Alberta Ambient Air Quality Objectives (AAAQOs)
(ESRD 2013) for SO2. Compliance with the SO2 AAAQO is usually evaluated by
completing an air dispersion modelling assessment for the possible flaring events.
Flare stacks used for non-routine situations were required to be evaluated as
continuous sources and there was no consideration given to the frequency or
duration of the flaring event. It should be noted that all flaring from temporary
stacks (e.g. well test flaring) needs an approval from the AER unless exempt as
outlined in D060.
Compliance with the flare performance requirements in D060 were to be
completed for all facilities by the end of 2004. In the process of completing this
work, industry determined that for many existing facilities with permanent flares
November 15, 2013 Non-Routine Flaring Framework 2
used for non-routine purposes, there was no practical or economic solution to
comply with these requirements using existing air dispersion modelling
methodologies. The problem was most pronounced in areas of complex terrain,
predominantly in the foothills areas. A number of possible solutions such as
increasing stack height or adding fuel gas were examined by industry. However,
none were found to adequately address the problem. The Canadian Association of
Petroleum Producers (CAPP) formed the Non-Routine Flaring Task Team
(NRFTT) comprised of government and industry members to look into this
problem. This document outlines the new regulatory approach and comprehensive
plan for managing non-routine flaring as developed by the NRFTT, and the
process that lead to its development.
November 15, 2013 Non-Routine Flaring Framework 3
2 Background
2.1 Previous Regulatory Approach
Prior to development of the Risk Based Criteria the previous regulatory approach
for addressing non-routine flares was found at that time in D060 and stated:
“Devices for combustion of sour or acid gas must be designed and evaluated to
ensure compliance with the Alberta Ambient Air Quality Objectives for SO2 in all
cases including short-duration non-routine cases. Evaluations must be conducted
using methodologies acceptable to the EUB Operations Group and Alberta
Environment. One of the methods described in Section 3.6, Section 7.12, or
Alberta Environment’s Emergency/Process Upset—Flaring Management
Modelling Guidance must be used.”
Air dispersion modelling predictions of SO2 from non-routine sour gas flares were
to meet the ESRD requirements for continuous sources or the ERCB requirements
for well test flaring. Both the ESRD and ERCB requirements had risk-based
criteria, that is, modelling predictions were allowed a chance of exceeding the
AAAQOs. As outlined in ESRD Air Quality Model Guideline (AQMG) (ESRD
2013), the ESRD criteria for non-routine emission sources based on requirements
for a continuous source were:
99.9th percentile predicted hourly SO2 concentration at each receptor must
meet the 1-hr AAAQO for SO2.
As outlined in D060, the ERCB Low Risk Criteria for non-routine flaring based
on requirements for well test flaring or incineration were:
99th percentile predicted hourly SO2 concentration for all hours of the
modelling period must meet the 1-hr AAAQO for SO2, and
maximum predicted hourly SO2 concentration must not exceed 900 µg/m3.
Due to the short duration and infrequent nature of non-routine flaring, impacts for
averaging periods longer than 1-hr are not usually evaluated; however, operators
have to be duly diligent in ensuring compliance with all AAAQOs for SO2.
The ESRD Emergency/Process Upset Flaring Management: Modelling Guidance
(ESRD 2003) identified a need to account for the likelihood of whether flaring
will occur during a period of worst-case meteorology.
If modelling results show compliance with the AAAQOs within the currently
accepted risk levels then the facility is considered to be in compliance.
Conversely, if modelling results for an existing facility indicate exceedances of
the AAAQOs beyond the currently accepted risk levels, the facility is considered
to be out of compliance. As a result, the facility will need to be modified to meet
the regulations or a plan to manage non-routine flaring will be required to ensure
the AAAQOs are not exceeded. For proposed facilities, redesign is required to
meet the regulations if modelling predicts exceedances.
November 15, 2013 Non-Routine Flaring Framework 4
2.2 Formation of Non-routine Flaring Task Team
Compliance with the flare performance requirements including non-routine events
in D060 were required by December 31, 2004. In the process of completing this
work, it was found that for many existing facilities with permanent flares that
were used for non-routine purposes, there was no practical or economic solution
to comply with D060 given the current modelling requirements. However, the
ERCB and ESRD would accept a management plan to deal with flaring during
non-routine situations as was done in well test flaring or other planned flaring
situations but it was found that certain aspects of this type of flare management
was not practical either. The facilities in question range from small facilities along
a pipeline or at a wellsite, to larger compressor stations, to large sour gas
processing plants.
It was industry’s position that given the great expense required to retrofit existing
facilities to ensure compliance, the low risk involved with non-compliance for
such isolated and short flare durations, the resources could be better targeted to
projects yielding far greater gains environmentally. Further, flaring is already
minimized at these sites, as it is an economic disadvantage to flare gas that could
otherwise be sold. If other options are available, such as sending gas down the
line to a plant, then gas is not flared. However, there are some cases when there is
no other option to flaring.
Industry also put forth that the requirements in D060 for non-routine flares to be
modelled as a continuous source regardless of actual flaring frequency or duration
were not representative of whether a particular facility would be in compliance
with the AAAQO for SO2. For example, even if flaring at a facility occurs only
five times a year for an hour at a time, it would need to be designed as if it were
operating every second of the year.
In response to the issue of non-routine flaring, CAPP formed the SO2 Dispersion
Modelling Task Force in early 2004. In September 2004, CAPP approached the
ERCB (formerly the Alberta Energy and Utilities Board) and ESRD and formally
presented their view of the issues. The ERCB and ESRD representatives both
agreed that there was a potential problem in the way non-routine flaring at
facilities with permanent flare stacks were being assessed and that more work
needed to be done to properly understand all the issues.
In December 2004, the ERCB formally acknowledged to CAPP that work needed
to be done regarding the assessment of non-routine flaring from permanent stacks.
The ERCB provided a letter to CAPP informing them that enforcement action will
not be applied on unplanned non-routine flaring at facilities that disclose potential
non compliance due to modelling exceedances or where modelling had not yet
been completed. However all requirements for meeting the AAAQOs are still in
place. The relaxation on enforcement would remain in effect while the task group
was working toward a solution. This letter is shown in Appendix A. At this time,
the task group was known the CAPP Non-Routine Flaring Task Team (NRFTT),
and was compromised of representatives from CAPP, ESRD, and the ERCB.
November 15, 2013 Non-Routine Flaring Framework 5
2.3 Potential Solutions
The main underlying point emphasized within the NRFTT from its inception
was that reduction in flare volumes was paramount. This was shared by both
industry and government members. The development of a dataset containing non-
routine flaring modelling results from a large number and varied types of facilities
was commissioned and the results evaluated. A dataset of approximately 130
facilities was created, most of which failed the current non-routine flaring
modelling requirements as outlined previously, and contained a wide range of
facilities from small field facilities to large gas plants. The objective of this
exercise was to demonstrate the scope of the issue, obtain buy-in from all
members on the task team and to provide a measuring stick in which to evaluate
potential solutions.
A number of potential solutions to the non-routine flaring assessment issue were
identified by the NRFTT. The task team considered a number of factors when
evaluating solutions including reduction in flare volumes, practicality, economics,
and technical issues. The potential solutions can be divided into three categories:
Physical or operational modification of facilities; changes to modelling approach;
and changes to regulatory approach. Table 2.1Table 2.1 presents the alternatives
identified and evaluated by the task team. A detailed discussion of each of the
alternatives is shown in Appendix B.
Table 2.1 Potential Solutions Identified and Evaluated
Physical or operational
modification of facilities
Changes to modelling
approach
Changes to regulatory
approach
Increase stack height
Fuel gas addition
Installing more block valves
on pipelines
Sweetening or filters
Nitrogen purging
Giant fans
Incinerators
Relocating flare stacks
Eliminate or reduce flaring
Modelling adjustments
Alternate models
Consider parallel airflow only
Improved meteorological data
Spill assessments
Ambient monitoring
Risk Based Criteria approach
Applicability of the AAAQO
Approach in British Columbia
Real time modelling
2.4 Comprehensive Non-Routine Flaring Framework
It was understood that at some facilities it was possible to implement one or more
of the physical or operational modifications and achieve compliance with the
current regulations; however, this was not true for every facility and consistency
is required for practical regulation. The NRFTT agreed that a comprehensive
solution is necessary to address emissions and air dispersion modelling for non-
routine flares. A restructured non-routine flaring management framework and
modelling methodology is therefore proposed by the NRFTT that will allow the
November 15, 2013 Non-Routine Flaring Framework 6
regulators to make a decision about the acceptability of the existing or proposed
flare system to handle non-routine flaring emissions. The solution should address
minimization of non-routine flare events through physical or operational
modifications to facilities, as well as updating the modelling and regulatory
approach to reflect the nature of these emission sources, and be applicable for new
and existing facilities.
By addressing flare management, duration, magnitude and intensity of non-
routine flare events, their impacts will be reduced, which will minimize the stress
on the environment. And by addressing the modelling methodology, both the
probability of occurrence and margin of error in modelling SO2 from these types
of flare events will be reviewed and acceptable approaches will be identified. It
was agreed that non-routine flares cannot be modelled as continuous sources and
a risk-based approach should be considered. The current ESRD 99.9th percentile
criteria used for continuous routine sources and the ERCB Low Risk Criteria used
for well test flaring could be used as the basis for risk-based modelling for non-
routine flares. The following four main tasks were identified for the task team to
accomplish in developing a comprehensive framework to manage non-routine
flaring:
1) Develop a Best Management Practices for facility flare reduction.
2) Provide improved meteorological data in the province.
3) Provide a guidance document to ensure consistency on modelling non-routine
flares.
4) Develop Risk Based Criteria approach to evaluate modelling results that
considers the frequency of flaring.
From these points a terms of reference (TOR) were developed that outlined the
goals of the NRFTT and identified the tasks needed to be completed to satisfy
those goals. The full TOR is provided in Appendix C.
November 15, 2013 Non-Routine Flaring Framework 7
3 Best Management Practices for Facility Flare Reduction
The main emphasis from the NRFTT was that a reduction in flaring volumes was
a necessary part of the comprehensive management plan for dealing with non-
routine flaring. Each operator had their own protocol or guide on flare reduction;
however, there wasn’t a standard document that could be applied to every
operator and facility that regulators could use as a benchmark to evaluate a
company’s effort to reduce flaring.
The NRFTT commissioned the development of a Best Management Practice for
Facility Flare Reduction (BMP) (CAPP 2006). The NRFTT agreed that the BMP
needs to clearly state that refined modelling using risk-based criteria to interpret
the predicted SO2 ground level concentrations must not pre-empt the flare
reduction/elimination assessments from being done and implemented. The goal of
this team is to reduce the amount of flaring, not to justify non-routine flaring
through refined modelling. The BMP was developed for upstream oil and gas and
is not directly transferable to other industries but it may have applicability to
downstream sectors.
The BMP would provide facility design and operating staff with a recommended
approach to identify routine and non-routine flare sources and quantities, and
assesses the opportunity for reduction of flare volumes and frequency at their
operated facility. In addition, the document could be used as a performance
indicator by regulators to ensure that an effort was being made to reduce flaring
volumes. The thought was not to make this document a regulatory requirement
but to use it as a regulatory standard that could be used in conjunction with the
other non-routine flaring management plan sections for compliance and
enforcement. Although it arose from issues around non-routine flaring of sour
gas, the BMP would be applicable for reducing flaring at all upstream facilities
during any type of event: routine or non-routine, sweet or sour, and can also apply
to venting and incineration. The BMP is a CAPP publication that is available on
the CAPP website1.
The primary objective of the BMP is to provide a process for enabling facilities to
reduce flare volumes and events with an overall Flare Management Strategy.
Although it is recognized that flare stacks are an essential part of safe facility
design and operation, all operators are expected to work towards the elimination
of routine flaring and reduction of non-routine flare events when economically
and technically feasible. A process is also required for the operators to
demonstrate to the regulators that the BMP was followed.
The long-term industry objective is to eliminate routine flaring and minimize non-
routine flaring. Although BMP modifications in procedures and design can reduce
the frequency of non-routine flaring, emergency flaring is still the most fail-safe
operational measure available to prevent equipment overpressure, catastrophic
equipment failure and loss of human life.
1 http://www.capp.ca/getdoc.aspx?DocId=114231&DT=NTV
November 15, 2013 Non-Routine Flaring Framework 8
However, flaring simply because it is convenient to do so or because it has
been a long-standing industry operating practice is unacceptable.
By identifying flare sources and gaps between facility design and BMP design
principles, design staff will be able to identify equipment and process
modifications necessary for reducing flare volumes and frequency for both
existing and new facilities. Similarly, operations staff will be able to identify new
operating practices needed for flare reduction by reviewing current flare sources
and identifying gaps between current operating practices and BMP operating
practices
This BMP is based on current available technology, current regulatory
requirements and accepted industry practices. As technology advances, the BMP
will be updated and there will be more opportunities for routine and non-routine
flare reduction. Although the BMP process outlined in this document may be used
to achieve compliance with regulated design, operating and air quality
requirements, its main focus is on continuous improvement. As technologies
improve and market conditions change, operators should re-evaluate the
feasibility of reducing flaring beyond regulatory requirements on a continuous
basis. The main sections of the BMP are briefly described below.
Flare Management Strategy provides a discussion of the regulatory elements
of developing a facility flare management strategy and introduces the concept
of continuous improvement in flare reduction. Flare reduction and continuous
improvement are discussed in detail in subsequent sections.
Determine Flare Properties provides guidance on locating actual and potential
flare source events, classification of the flare source as routine or non-routine,
quantification of flare volume and duration, and determining flare causes.
Flare Reduction Assessment provides guidance on identifying and assessing
options to reduce flaring, and includes identifying gaps between current
design/operation versus BMPs, economic assessments of reduction projects,
and the prioritization, implementation and documentation of reduction
projects.
BMP Design Considerations provides guidance on design considerations to
prevent, reduce or partially eliminate routine and non-routine flare volumes
and frequency.
BMP Operating Considerations provides guidance on operating considerations
to prevent, reduce or partially eliminate routine and non-routine flare volumes
and frequency.
Flare Quantification Requirements provides guidance on quantifying all
sources of flares.
Industry members expressed concern with requiring implementation of the BMP
through regulation. The BMP is an industry-developed voluntary guidance
document focused on continuous improvement; if linked to regulation, it will
become a standard operating practice over which industry will no longer have
November 15, 2013 Non-Routine Flaring Framework 9
control or ownership. Conversely, the regulators expressed concern that there
needed to be a process the regulators can use during audits to determine that
facilities are being duly diligent in minimizing flaring. It was agreed that linking
the BMP into regulation was not required however, a regulatory decision tree, as
shown in Figure 3.1, the Flare Management Strategy Flowchart (FMSF) was
developed that is reflective of the practices described in the BMP and will give
the regulators a field tool for compliance and enforcement. Triggering the flare
reduction analysis in the BMP will be based on exceeding the AAAQOs from a
modelling perspective; however, D060 still requires that all facilities go through a
decision tree analysis to eliminate or reduce flaring whenever possible.
One of the main points of the NRFTT was the need for consistent definitions for
topics relating to non-routine flaring. The BMP provided the following definitions
to ensure a consistent understanding of the different terms and topics related to
non-routine flaring:
Routine Flaring - “Routine” applies to continuous or intermittent flaring,
venting and incinerating that occurs on a regular basis due to normal
operation. Examples of routine flaring include: glycol dehydrator reboiler still
vapour flaring; storage tank vapour flaring; flash tank vapour flaring; and
solution gas flaring.
Non-routine Flaring- “Non-routine” applies to intermittent and infrequent
flaring.
Planned flaring – Flare events where the operator has control over when
flaring will occur, how long it will occur, and the flow rates. Planned flaring
results from the intentional de-pressurization of processing equipment or
piping systems. Examples of planned flaring include: pipeline blowdowns;
equipment depressurization; loss of normal control during start-ups; facility
turnarounds; and well tests.
Unplanned flaring - emergency or upset operational activities closely
associated with facility health and safety. Flare events where the operator has
no control of when flaring will occur. There are two types of unplanned
flaring: upset flaring and emergency flaring.
Upset flaring occurs when one or more process parameters fall outside
the allowable operating or design limits and flaring is required to aide
in bringing the production back under control. Examples of upset
flaring include: off-spec product; hydrates; loss of electrical power;
process upset; and operation error.
Emergency flaring occurs when safety controls within the facility are
enacted to depressurize equipment to avoid possible injury or property
loss resulting from explosion, fire, or catastrophic equipment failure.
Examples of emergency flaring include: pressure safety valve (PSV)
overpressure; and emergency shutdown.
Although a comprehensive flare management plan was deemed necessary to
address the compliance and enforcement of non-routine flaring, it was necessary
November 15, 2013 Non-Routine Flaring Framework 10
to find ways of simplifying this plan as much as possible in order to regulate it
practically. As such, to avoid confusion over what flare events are considered
upsets or emergencies, both of these flare events were grouped into unplanned
flare events.
November 15, 2013 Non-Routine Flaring Framework 11
Figure 3.1 Flare Management Strategy Flowchart
November 15, 2013 Non-Routine Flaring Framework 12
4 Air Dispersion Modelling Guidance
Regulatory air dispersion modelling is designed to be conservative (i.e. over
predict concentrations). Compliance with the AAAQOs is measured against
ground-level concentrations predicted to occur during worst case dispersion and
emissions conditions. The previous air dispersion modelling requirements for
non-routine sources are consistent with those for continuous sources and do not
account for the infrequent, short-term nature of non-routine flaring events and as
such are even more conservative. Industry had identified difficulties in meeting
these requirements for non-routine flaring using current modelling approaches,
especially in areas of complex terrain. Air dispersion modelling of non-routine
flaring presents many challenges:
In many instances non-routine flaring occurs as a result of depressuring of
equipment or pipelines so the flow rate would be transient in nature. Most
regulatory models assume constant stack parameters for each hour and cannot
explicitly account for the transient nature of a blowdown Non-routine flaring
events can be less than 1-hour in duration; however, models simulate on an
hourly basis and model predictions need to be adjusted appropriately; and
Non-routine events are infrequent and models cannot explicitly consider when
flaring will or won’t occur.
The NRFTT undertook a review of non-routine flaring air dispersion modelling
tools available, and the results from various companies and consultants showed
inconsistencies in approach and a failure to account for the short-term nature of
the event being modelled. By using a consistent air dispersion modelling
methodology with required emission scenarios defined, the modelling of non-
routine flaring will be better understood and regulated. Therefore, a modelling
guidance document was commissioned by the NRFTT for ESRD. Where required
by regulatory requirements, modelling must be carried out to show due diligence
to protect the environment for non-routine flaring applications.
The ESRD Non-Routine Flaring Management – Modelling Guidance (ESRD
2013) outlines a methodology for air dispersion modelling that should be used to
determine appropriate non-routine flaring management practices. The
methodology has been developed to:
Ensure that consistency is maintained in the modelling for each facility;
Ensure all facilities are evaluated on the same predictive basis; and
Refine dispersion modelling to more realistically predict ground level SO2
concentrations from non-routine sour gas flaring.
There are differing scientific views on the many methods of modelling, and all
facilities are designed differently. However, it is essential that the overall
methodology for assessment is consistent to allow for simple comparison between
different facilities. A refined modelling methodology is therefore proposed. The
objective of refining the sour gas flaring modelling approach is not to change the
target and therefore make it "easier" for industry to demonstrate compliance. The
November 15, 2013 Non-Routine Flaring Framework 13
guidance document can be found on the ESRD website and is summarized in the
following paragraphs:
A tiered modelling approach is proposed:
1) Screening: The purpose of the screening modelling is to determine maximum
predictions in parallel airflow (simple terrain) and complex terrain. Screening
modelling is performed using a spreadsheet tool that defines the source
parameters for dispersion modelling and runs ERCBflare-v1.0 (or its
subsequent versions). If there are no predicted exceedances of the AAAQOs,
the modelling is complete; otherwise Risk Based Criteria modelling (refined
or advanced modelling) is required.
2) Refined: AERMOD or CALPUFF with continuous source modelling option
switches shown in the Modelling Guidance document. Modelling uses five
years of refined meteorological data as required by the AQMG.
3) Advanced: CALPUFF with steady puff or multiple puffs for transient releases
switches shown in the Modelling Guidance document. Modelling uses five
years of refined meteorological data as required by the AQMG.
Refined air dispersion models described in AQMG do not have the capability to
model flares directly; therefore, pseudo stack parameters (e.g. height, diameter)
should be calculated for the flare, to compensate for the flame height, and initial
dispersion from the flame. The following parameters are required as input into the
dispersion models and must be calculated using ERCBflare-v1.0 (or its
subsequent versions):
Effective Stack Height (m);
SO2 Emission Rate (g/s);
Pseudo-Stack Exit Temperature (K);
Pseudo-Stack Exit Velocity (m/s); and
Pseudo-Stack Diameter (m).
The scenarios to be considered for modelling will be identified through the
application of the BMP. All modelling will be conducted using parameters
determined from licensed or approved rates from ERCB and/or Environmental
Protection and Enhancement Act (EPEA) approvals. Maximum expected rates
may be used if the facility is not operating at the rates specified in the license.
Operators need to ensure that worst case scenarios are identified.
As discussed above, there are some challenges associated with non-routine flaring
due to the nature of the events. The following simplifications were determined to
be appropriate:
When determining the flow rate from a transient release, an average flow rate
can be used equal to the volume of the release divided by the duration of the
event. If deemed appropriate, a more rigorous approach using the advanced
November 15, 2013 Non-Routine Flaring Framework 14
model can be undertaken using the time steps of less than 1-hour that
characterize the transient blowdown.
If the flaring model period is more than 1-hour, the flare will be modelled as a
continuous source and the model predictions are directly compared with
AAAQOs. However, if the flare duration is less than 1-hour the predicted
ground level concentrations must be first converted to 1-hour equivalent and
then compared with AAAQOs.
Due to the short duration and infrequency of most non-routine flaring, all
modelling results will be compared to the AAAQOs without considering
baseline concentrations or overlap with other sources.
Another issue identified with modelling was to have the inputs to the models as
accurate or representative as possible. In any modelling assessment, high quality
input data is very important. Maximizing the certainty and validity around the
inputs to the models is the best way to ensure the accuracy of predictions. The
modelling guidance has attempted to provide a consistent and accurate way of
modelling non-routine flaring as well as provide direction on the source inputs to
the model and the meteorology which is discussed in the Section 5.
4.1 Sources to be Modelled
Although it is important to ensure all non-routine scenarios are considered in the
modelling, the focus of this process is on environmental protection and preventing
impacts on human health. This was not intended to be a modelling exercise for
each and every event, so small volume and low SO2 emission non-routine flaring
scenarios (such as releases from PSVs) were considered to be exempt from
modelling as these pose a very low risk. The basis for the exemption is from D060
that requires operators to evaluate impacts of sour gas flaring, incinerating, or
enclosed burning on ambient air quality if it is proposed to burn sour gas
containing more than 10 mol/kmol H2S (1% H2S) or 1 t/d of sulphur (S).
However, for consistency it is proposed that for non-routine flaring the 1 t/d is not
an instantaneous rate but the mass released during the event or the day (for
multiple releases). The modelling exemption for non-routine flaring is
summarized as follows:
1. The licensee, operator, or approval holder must evaluate impacts of non-
routine sour gas flaring on ambient air quality if
a) it is proposed to burn sour gas containing 10 mol/kmol H2S (1 per
cent H2S) or more,
b) 1 tonne of sulphur mass release during the event or the day (for
multiple releases).
Single non-routine flare events that are predicted to be less than or equal to 15
minutes in duration and predicted to emit less than 1 tonne of sulphur over a
rolling 24-hour period are exempt from modelling requirements
November 15, 2013 Non-Routine Flaring Framework 15
5 Meteorological Data Improvements
In any air dispersion modelling assessment, meteorology representative of the
study area is important to ensure the magnitude and distribution of predicted
concentrations are as accurate as possible. This is extremely important in complex
terrain as the frequency of winds blowing towards elevated terrain usually plays a
large role in determining compliance of a facility. It is not practical for every
facility to collect or have collected meteorological data over a number of years
since meteorological data for dispersion modelling requires a great deal more data
than wind speed, wind direction and temperature to adequately characterize the
atmosphere’s ability to disperse a plume. Atmospheric turbulence parameters and
mixing heights are required by air dispersion models and although there are many
ways of determining these parameters, collecting the data required to calculate
these parameters is not trivial or inexpensive.
The lack of representative meteorological data in areas of complex terrain for air
dispersion modelling was identified as a deficiency since the challenges of
assessing non-routine flares were most prevalent in these areas. However, locating
surface or upper air meteorological data that has been collected in complex terrain
area like the foothills, ensuring that these data meet regulatory monitoring
standards and methods, and are consistent was not considered practical. Further,
setting a meteorological monitoring network in the province specifically for this
endeavor was not considered feasible. An alternative methodology to using
measurements from surface stations is the use of modelled mesoscale data to
create dispersion model meteorological data.
ESRD provides a standard data set of five years of meteorological data for use in
refined and advanced modelling. Information on how to obtain this data set can be
found at ESRD’s modelling website.
November 15, 2013 Non-Routine Flaring Framework 16
6 Risk-Based Modelling Criteria for Non-routine Flaring
Risk is defined as the function of the probability of an event and the severity of
the consequence. For the purposes of the NRFTT, risk is a measure of the
probability of an exceedance of the AAAQOs at a receptor on an annual basis. A
risk-based dispersion modelling criteria would account for the likelihood of non-
routine flaring and how often predicted concentrations exceed the AAAQOs. Both
the current ESRD modelling criteria for continuous sources and the ERCB
modelling criteria for well tests are risk-based, that is, there is an allowance for
predictions to exceed the AAAQOs and therefore there is an accepted risk of the
AAAQOs being exceeded. The essential modelling requirement for non-routine
flaring is that an equivalent (or lower) level of risk be maintained as compared to
a continuous source. The risk level from a continuous source as determined from
the modelling criteria is considered to be “acceptable” by the regulators.
Predicted risks from dispersion modelling that meet or are lower than the
“acceptable” risk level would be considered compliant and predicted risks that
exceed this “acceptable” risk level are considered unacceptable and not
compliant.
Prior to adopting the non-routine flaring management framework, air dispersion
modelling for non-routine flaring is performed assuming a continuous source
operating at all hours in the modelling period, which is usually a five year period
as outlined in Section 4. This was considered the correct modelling approach as
non-routine flaring includes unplanned events in which non-routine flaring could
take place at any time and regulators need to know the potential impacts that non-
routine flaring can cause under all possible meteorological conditions. The
problem with this approach is that up to now there has not been a way to address
the infrequent nature of these events. Prior to adopting the non-routine flaring
management framework, the way for determining compliance of non-routine
flares from an air dispersion modelling perspective is the same as a continuous
source or well test as outlined in Section 2.1. Essentially, it has been assumed that
non-routine flares operate continuously for compliance purposes. The section
proposes a Risk Based Criteria air dispersion modelling criteria for non-routine
flaring that considers how often flaring occurs.
For the purposes of the non-routine flaring of sour gas, a Risk Based Criteria is
applicable to SO2 modelling results only. Ambient monitoring must meet the
AAAQOs at all times.
6.1 Calculation of Risk
Risk considers both the chance of a predicted exceedance of the AAAQOs and the
frequency of emissions. The chance of a predicted exceedance is determined from
air dispersion model predictions as the number of predicted exceedances divided
by the duration of the meteorological data file used. The frequency of emissions is
how often a source emits over a year.
Risk = (Frequency of Emissions) × (Chance of an Exceedance of the AAAQOs)
November 15, 2013 Non-Routine Flaring Framework 17
For example, if a continuous emission source (i.e. operating 100% of the time) is
predicted to exceed the 1-hr SO2 AAAQOs 876 hours in one year (8760 hours) at
a receptor, then the annual risk of exceeding the 1-hr SO2 AAAQO at that
receptor associated with this source would be as follows:
Risk = 100% × 876/8760 = 0.1
A reduction in the chance of an exceedance or the frequency of emissions would
reduce the risk.
6.2 AQMG Routine Emission Source Modelling Criteria
The modelling criteria for routine emission sources, in the AQMG, was taken
into account by the NRFTT in developing criteria for non-routine sources
and is presented here for comparative purposes. However, changes to the
modelling criteria for routine emission sources were not considered by the
NRFTT.
Routine emissions include continuous or frequent emissions that occur on a
regular basis due to normal operation of a plant process. Event durations range
from several hours to one year (8760 hours) with emissions occurring more than
one month per year (720 hours per year). The ESRD modelling criteria for routine
continuous SO2 sources and the equivalent risk levels are:
99.9th percentile (9th highest) predicted hourly SO2 concentration at each
receptor for each year must meet the 1-hr SO2 AAAQO. This equates to an
annual risk of exceeding the 1-hr AAAQO of 1×103, (i.e. 8 predicted
exceedances are allowed per 8760 hours and the source is emitting 100% of
the time) at each receptor.
For all other averaging periods the eight highest predicted concentrations (that
were disregarded for the 1-hour averaging period), must be included when
calculating the 99.9th percentile value.
6.3 ERCB Low Risk Criteria
ERCB D060 (2011) outlines the low risk criteria that was developed for well test
flaring and can be applied to modelling results for all non-routine sour gas flaring
events. The ERCB low risk criteria considers exceedances based on each hour of
the modelling period rather than on a receptor basis like the ESRD modelling
criteria. Therefore, it is not possible to do a comparative analysis of the two
methods. The ERCB low risk modelling criteria and the equivalent risk levels are:
99th percentile of the maximum predicted hourly SO2 concentrations at each
hour of the modelling period must meet 1-hr SO2 AAAQO. This equates to a
risk of exceeding the 1-hr AAAQO of 1×10-2 (1% of meteorological
conditions cause exceedances of the 1-hr SO2 AAAQO) in each hour at any
receptor.
The maximum predicted hourly SO2 concentration must not exceed
900 µg/m3. This equates to a negligible risk of exceeding 900 µg/m3, in each
hour at any receptor.
November 15, 2013 Non-Routine Flaring Framework 18
As a result of the work of the NRFTT, the time based ERCB low risk criteria will
be replaced by a new receptor based risk criteria. The criteria is outlined in
section 6.4.1 and the most current version of D060.
6.4 Risk-Based Modelling Criteria for Non-Routine Flares
The proposed non-routine flaring modelling criteria has been developed to ensure
that the predicted risk during non-routine flaring does not exceed that of a
continuous source consistent with the ESRD modelling criteria. The proposed
criteria have limits on hourly modelling predictions. Non-routine flaring is
acknowledged to be infrequent and usually short-term. Therefore, daily, monthly
and annual average criterion are not required for these infrequent, non-continuous
emissions as limits have been placed on the amount of flaring that can occur in a
year.
With a modelling criteria based on risk, there is an acknowledgement that there
could be predicted modelled concentrations that exceed the AAAQOs. To prevent
situations or scenarios that could compromise the safety of the public, a cap or
limit was put on predicted concentrations. The hourly SO2 prediction for non-
routine flaring cannot exceed the SO2 evacuation criteria of 5 parts per million
(ppm) for a 15 minute average as per ERCB Directive 071: Emergency
Preparedness and Response Requirements for the Petroleum Industry (D071)
(ERCB 2008). This equates to a 1-hr SO2 concentration of 9923 µg/m3. These are
criteria for predicted concentrations. To be consistent with the AQMG,
compliance will be tested by considering the 9th highest 1-hour prediction for each
single year of modelling.
The implications of future changes to the SO2 evacuation criteria will need to be
considered. During any non-routine flaring event, any actual measured SO2
concentrations exceeding the AAAQOs directly caused by that event will be
considered a contravention under EPEA.
As outlined in Section 3.0, non-routine flaring is divided to two categories:
planned and unplanned. The risk of exceeding the AAAQOs is dependent on not
only the modelling predictions but also how often flaring will occur. For
simplicity of compliance and enforcement, a maximum allowable frequency of
flaring was determined for each category. Planned emissions occur more
frequently than unplanned emissions. The allowable amount of flaring in each
category was determined in consultation with industry members and are
considered as reasonable for compliance and operations. Once the allowable
amount of flaring was determined, the modelling prediction percentile that would
determine compliance was chosen to ensure that the risk of exceeding the
AAAQOs for a non-routine flare does not exceed that of a continuous routine
flare:
At the worst case receptor, the annual risk of an exceedance of the 1-hour
SO2 AAAQO cannot exceed 1×10-3.
November 15, 2013 Non-Routine Flaring Framework 19
6.4.1 Planned Flaring
Planned flaring includes scheduled intermittent maintenance activities including
well tests and are by definition, events that the operator has control over for the
most part and can choose when to flare, the duration, and the flow rate. Event
durations can range from less than an hour to about 1 week and flaring will be
allowed up to 720 hours (approximately 1 month) per year at a flare. The
following modelling criteria are proposed for planned flaring:
The 99.9th percentile (9th highest of 8760 predictions) predicted hourly
concentrations at each receptor cannot exceed a 1-hr SO2 concentration of 900
µg/m3.
The 99th percentile (e.g., 88th highest of 8760 predictions for modelling of a
full year) predicted hourly concentration at each receptor must not exceed the
1-hour SO2 AAAQO. Flaring cannot occur more than 720 hours in a calendar
year. This equates to a maximum risk of exceeding the 1-hr AAAQO of
8.2×10-4 at each receptor (the risk calculation formula is shown in Table 6.1).
An Air Quality Management Plan (AQMP) can be implemented for planned
flaring events. An AQMP identifies times, operational instructions,
meteorological restrictions, and/or ambient monitoring so that the AAAQOs
are not exceeded during flaring.
6.4.2 Unplanned Flaring
Unplanned flaring includes unscheduled intermittent activities including upsets
and emergencies and are by definition, events that the operator does not have
control over and cannot choose when to flare, the duration, or the flow rate. Event
durations range from minutes to four hours and flaring will be allowed up to 88
hours per year at a flare. The following criteria are proposed for unplanned
flaring:
The 9th highest predicted 1-hr SO2 concentration for each single year of
modelling cannot exceed the SO2 evacuation criteria from ERCB D071 which
equates to a 1-hr SO2 concentration of 9923 µg/m3.
The 90th percentile (876th highest of 8760 predictions) predicted hourly SO2
concentration at each receptor must meet the 1-hour SO2 AAAQO. Flaring
cannot occur more than 88 hours in a calendar year. This equates to a risk of
exceeding the 1-hr AAAQO of 1.0×10-3, at each receptor (the risk calculation
formula is shown in Table 6.1).
Due to their unexpected nature of the cause of the flaring, AQMPs with
restrictions based on meteorology or time of day, or ambient monitoring
cannot be implemented for unplanned flaring events. However, unplanned
flaring can be managed to reduce the predicted SO2 concentrations to meet the
risk-based criteria.
November 15, 2013 Non-Routine Flaring Framework 20
6.5 Discussion
Figures 6.1 illustrates the relationship between the current Risk Based Criteria for
a continuous source and the criteria proposed for non-routine flares (planned and
unplanned events), for the hourly objective. On the x-axis is the chance of
predictions exceeding the AAAQOs (hours of predicted exceedances/hours of
emissions modelled). A minimum of one year (8760 hours) of meteorological data
is required as the risks are on an annual basis. On the y-axis is the fraction of the
year the source is emitting (hours of emissions/hours in a year). The green
diagonal line represents the equivalent level of risk as a continuous source, is the
product of the two axes and is the annual risk of exceeding the AAAQOs. It can
be seen on the figures that the annual risk of exceeding the hourly AAAQOs is
1.0×10-3 which is based on a continuous source. The highest risk is in the upper
right hand corner (shaded red) and the lowest risk is in the lower left hand corner
(shaded green). As you move toward the upper right portion of the graph the risks
increase and as you move toward the bottom left portion of the graph the risks
decrease. Areas on the graph with risks less than the ESRD modelling criteria for
continuous sources are shaded green and are considered as areas of acceptable
risk. Areas on the graph with risks greater than the ESRD modelling criteria for
continuous sources are shaded red and are considered as areas of unacceptable
risk.
The premise behind the proposed criteria for non-routine flares is to ensure that
the risk of exceeding the AAAQOs is equal to or lower than the risks acceptable
for a continuous source. The non-routine flaring categories are limited within each
category to a maximum allowable number of hours of flaring per year (y-axis)
and to a chance that a predicted concentration exceeds the AAAQOs assuming the
source was operating continuously (x-axis). The maximum percentiles of
predicted concentrations allowable are shown on the graphs in red font. Table 6.1
shows the calculations for determining the risk of exceeding the hourly AAAQOs.
For planned non-routine flaring events, the flare would be considered to have an
annual risk of exceeding the AAAQOs that is equal to or lower than that of a
continuous source if:
the 99th percentile hourly SO2 concentration is less than the hourly
AAAQO;
the 99.9th percentile hourly SO2 concentration is less than 900 ug/m3; and
the flaring does not occur for more than 720 hours per year.
Under the above circumstances, from a modelling perspective, the flare would be
in compliance.
For unplanned non-routine flaring events, the flare would be considered to have
an annual risk of exceeding the AAAQOs that is equal to or lower than that of a
continuous source if:
the 90th percentile hourly SO2 concentration is less than the hourly
AAAQO;
November 15, 2013 Non-Routine Flaring Framework 21
the 99.9th percentile hourly SO2 concentration is less than 9923 ug/m3; and
the flaring does not occur for more than 88 hours per year.
Under the above circumstances, from a modelling perspective, the flare would be
in compliance.
Table 6.1 Summary of Non-Routine Modelling Hourly Risk Criteria
Flaring
Category
Fraction
of Year
Source is
Emitting
Hours
per Year
Source
Emitting
Chance of
Hourly
Prediction
Exceeding
Air Quality
Threshold
Percentile
Hourly
Prediction
Meeting
Air
Quality
Threshold
Annual
Risk of
Exceeding
Air Quality
Threshold
Maximum
Acceptable
1-hr Air
Quality
Threshold
Years per
Predicted
Exceedance
Continuous
Routine 100% 8760 0.10% 99.9% 1.0E-03 450 µg/m3 1,000
Planned
Non-routine 8.2% 720
1%
0.10%
99.0%
99.9%
8.2E-04
8.2E-05
450 µg/m3
900 µg/m3
1,217
12,167
Unplanned
Non-routine 1.0% 88
10%
0.10%
90.0%
99.9%
1.0E-03
1.0E-05
450 µg/m3
9,923 µg/m3
1,000
100,000
Formula Input A
Y axis A×8760
input B
X axis P=1-B R=A×B
AAAQO &
RBC =1/R
Figure 6.1 Graphical Representation of Non-Routine Modelling Hourly Risk Based Criteria
November 15, 2013 Non-Routine Flaring Framework 22
7 Pilot Initial 2007-08 Test of Concept Program
Discussions on the Risk Based Criteria modelling criteria was an ongoing
endeavour and before coming to a consensus on the proposed criteria, a pilot
study was undertaken to help understand the consequences of the new approach
such as feasibility, practicability, frequency of events, capacity of enforcement
from a regulator’s perspective, and administrative issues.
A number of existing facilities in complex terrain where non-routine flaring of gas
with an H2S content > 10 mol/kmole (1%) has occurred were identified. The BMP
was applied to identify all possible non-routine flaring events and the potential to
reduce flaring. Air dispersion modelling was undertaken using the proposed
modelling refinements with probable worst-case scenarios for both planned and
unplanned events categorized by the application of BMP. The proposed Risk
Based Criteria was applied to the modelling results. As well, data was gathered on
the number of flaring events and volumes during the pilot program at the pilot
sites.
The results of pilot study showed that the proposed changes to the regulatory
approach for dealing with non-routine flaring were reasonable and that the
NRFTT could move forward and develop a recommended approach for the
regulating of non-routine flaring.
November 15, 2013 Non-Routine Flaring Framework 23
8 Comprehensive Management for Non-Routine Flaring
Operators must ensure compliance with all provincial regulatory requirements in
regards to flaring and ambient air quality. Requirements for flaring and venting
activities in Alberta can be found in D060. D060 requirements also work to
ensure compliance with the AAAQOs.
The main regulatory issue with non-routine flaring is that the AAAQOs are to be
met during any actual non-routine flaring event on a monitoring basis, where it is
occurring. Monitored exceedances of the AAAQOs must be reported and may be
subject to enforcement action by ESRD or ERCB. Figure 8.1 illustrates the
proposed regulatory approach to non-routine flaring and is described below:
1. Performing Screening Level Assessment of Non-Routine Flaring using
ERCBflare-v1.0 spreadsheet (or its subsequent versions):
If these results show compliance with AAAQO then follow requirements
in D060 for flare reduction. Otherwise, follow the Comprehensive
Management for Non-Routine Flaring, below (Steps 2 through 7, as
applicable); and
If screening modelling for 99.9th percentile meets AAAQO’s, operate
according to D060.
2. Apply FMSF (Figure 3.1) (Applicable for all sweet and sour facilities);
Applies only to the facilities that do not meet the AAAQOs from a
modelling perspective;
Needs to be done before refined non-routine Risk Based Criteria
modelling is performed;
Companies should have on file a description of how the FMSF was
applied (Figure 3.1) which must be provided to ESRD and ERCB upon
request; and
Re-apply FMSF upon significant operational or design changes.
3. Perform air dispersion modelling for non-routine flaring;
Applicable to all facilities with permanent flares with H2S > = 1% OR > =
1 t/d of sulphur EXCEPT if < = 15 minutes AND < = 1 t/d of sulphur
over a roiling 24-hour period (see section 4.1);
Follow Modelling Guidance (ESRD 2013); and
Provide justification that worst-case scenario identified is worst case with
regard to magnitude and frequency of predicted concentrations.
4. For new facilities, modelling of non-routine flaring must meet the Risk Based
Criteria.
5. For existing facilities, the following procedure is proposed:
a. If modelling of worst case scenario(s) at licensed or approved conditions
shows compliance with AAAQOs:
November 15, 2013 Non-Routine Flaring Framework 24
Facility can continue to operate as is;
Re-apply FMSF as directed by the regulator or if any changes at the
facility would result in changes to flaring scenarios; and
Re-assess modelling if any changes at facility.
b. If modelling of worst case scenario(s) at licensed or approved conditions
shows compliance with Risk Based Criteria:
Company must log the number of hours of flaring in each category
(planned and unplanned) per calendar year. Information to be provided
to ESRD and/or ERCB upon request.
c. If the allowable number of hours of flaring in any category is exceeded in
a calendar year, the operator must disclose this to ESRD and/or ERCB.
Any exceedances of AAAQOs predicted from the post event modelling
would be considered as an actual monitored exceedance of the AAAQOs
unless ambient air monitoring (if available) did not record exceedances at
the location of the predicted exceedances:
If non-compliance with Risk Based Criteria is due to modelling at
licensed or approved values at which the facility historically does not
operate, then the facility may consider modelling at maximum
expected conditions and remodelling if these conditions change.
Company must log the number of hours of flaring in each category
(planned and unplanned) per calendar year. This information to be
provided to ESRD and/or ERCB upon request.
For planned events (maintenance, etc), it is expected that operators
will develop AQMPs to ensure that exceedances do not occur, and
implement them during flaring. It is acceptable for modelling to be
based on actual flows and gas composition and not on licensed values.
It is acknowledged that in certain situations, modelling may show
compliance with AAAQOs for less than worst-case conditions, and
therefore AQMPs may not be required in all cases. Flare logs and
AQMPs for planned flaring events must be provided to ESRD and/or
ERCB upon request.
For unplanned events:
i. If modelling of worst case scenario(s) show predicted
concentrations in excess of the ERCB SO2 Evacuation Criteria
from D071, then facility has three years to implement design or
operational changes such that Risk Based Criteria is met or else
shutdown the facility. In the interim, for each unplanned flaring
event at the facility, the operator must perform post event
modelling using actual conditions that occurred during the event.
Operators must notify the ERCB immediately upon realizing that
facility design or operational changes cannot be completed within
the three year implementation period.
November 15, 2013 Non-Routine Flaring Framework 25
ii. If modelling of worst case scenario(s) show predicted
concentrations are greater than the AAAQO but less than ERCB
SO2 Evacuation Criteria, then for each unplanned flaring event at
the facility, the operator must perform post event modelling using
actual conditions (source and meteorology) that occurred during
the event.
iii. Any exceedances of AAAQOs predicted from the post event
modelling would be considered as an actual monitored exceedance
of the AAAQOs unless ambient air monitoring (if available)
confirms no actual exceedances at the location of the predicted
exceedances.
6. For situations triggering post-event modelling, the assessment is due two
months from the non-routine flaring event. Up to a two month extension may
be granted upon submission of a letter to the ERCB stating reason for
extension.
7. All existing facilities not meeting the modelling Risk Based Criteria for
unplanned flaring would have to re-assess with the FMSF of each flaring
event and provide documentation to ESRD and ERCB upon request.
November 15, 2013 Non-Routine Flaring Framework 26
Figure 8.1 Comprehensive Management for Non-Routine Flaring of Sour Gas
November 15, 2013 Non-Routine Flaring Framework 27
9 Development of Dispersion Modelling Tools
The ERCBflare-v1.0 dispersion modelling tool was originally intended for
screening purposes, specifically for well test permit applications. The Excel
tool was based on the SCREEN3 dispersion model and it is most suitable for
steady flow rate scenarios. During the development of the Risk Based Criteria,
the United States Environmental Protection Agency (US EPA) changed its
preferred model to AERMOD. This announcement in conjunction with the
need to incorporate the Risk Based Criteria into publicly available tools
prompted the need to develop new dispersion modelling Graphical User
Interfaces (GUI).
Several members of the NRFTT are also members of the Petroleum
Technology Alliance Canada (PTAC) committee called Alberta Upstream
Petroleum Research Fund (AUPRF). AUPRF is an industry-sponsored fund
supported by CAPP and Small Explorers and Producers Association of
Canada (SEPAC). The objective of AUPRF is to provide an efficient and
effective mechanism to coordinate, initiate, fund, complete and communicate
on environmental research needed by the industry and government regulators
enabling a prosperous upstream oil and gas industry achieving socially and
environmentally responsible recovery of Canada’s petroleum resources
through effective, market-driven collaboration. The AUPRF Fund supports
practical science-based studies that develop credible and relevant information
to address knowledge gaps in the understanding and management of high
priority environmental and social matters related to oil and gas exploration
and development in Alberta. Research reports are shared broadly with the oil
and gas industry as well as regulators, government agencies, and other
stakeholders. PTAC works closely with CAPP to align AUPRF priorities and
criteria to CAPP policy objectives. The resulting research has and continues to
be used by governments and regulators to set or revise environmental
guidelines based on solid scientific evidence and by industry to establish best
practices. In 2009, a proposal to develop a new dispersion modelling tool was
approved by CAPP and PTAC.
The CALPUFF Excel based GUI called ABflare was the first dispersion
modelling tool developed. ABflare was selected first due to CALPUFF’s
ability to model sub hourly scenarios. A consultant, Zeltpsi in association with
Exponent (developers of the original CALPUFF dispersion model) developed
ABflare to be made available to the public free of charge. The original intent
of the NRFTT was to continue using existing screening tools (then
ERCBflare-v1.0) and to use ABflare as the refined model of choice. The US
EPA’s announcement to adopt AERMOD as their preferred model caused
ESRD to update the AQMG. ESRD will no longer accept SCREEN3 for
EPEA approval and amendment applications. This change created a need to
develop a new screening tool based on AERMOD. In 2011, a proposal to
develop a new screening dispersion modelling tool (ERCBflare-v2.0 or its
subsequent versions) was approved by CAPP and PTAC.
November 15, 2013 Non-Routine Flaring Framework 28
A main focus of the dispersion modelling tools was to standardize how source
input parameters are calculated. The new tool includes transient blowdown
source modelling and updated algorithms to predict flare conversion
efficiency. Flare conversion efficiency is based on the University of Alberta
Flare Research Project © 2000, 2004 by Larry Kostiuk, Matthew Johnson, and
Glen Thomas. The new models were designed to predict conversion
efficiencies which prompted the developer to consider H2S as part of the air
quality assessment. In cases, where plume momentum is low and in high wind
conditions, combustion conversion efficiencies are low enough such that the
AAAQO for H2S is of concern and cannot be ignored. The decision to include
predicted ground level H2S concentrations in ABFlare and AERFlare-v2.0 (or
their subsequent versions) was initiated by the regulators where there was
limited time to analyze all of the implications of adding this layer of
modelling. The need for ongoing evaluation of modelling methodologies and
the risk-based criteria has been acknowledged by both industry and the
regulators. Therefore, the Non Routine Flaring Task Team will continue to
work under a new Terms of Reference in order to address and resolve any
identified issues or concerns surrounding the risk-based criteria, supporting
guidance and modelling approach.
10 Timelines – Implementation
A phased in approach for this regulation based on facility type is the most
effective method because facility type offers a reasonable surrogate for
prioritization based on level of risk of exceeding AAAQOs due to flow rate and
flow volumes. The relative ease in identifying facilities based on type provides
administrative simplicity for regulatory inspectors and companies, and offers a
consistent and standardized identification throughout the province. Hence, the
following timelines to assess non-routine flaring are proposed:
1) Where previous modelling of non-routine flare events shows 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 respective facility
or if the AER requests new dispersion modelling be conducted for any reason, the
operator will apply the flare management strategy flowchart and will re-assess
dispersion modelling using current modelling methodology and tools.
2) For permanent flare stacks the licensee, operator, or approval holder must
assess non routine flaring dispersion modelling criteria within the following
timelines where facilities lack dispersion modelling or where facilities are unable
to satisfy the AAAQO for non-routine flaring events using tools and methods no
longer accepted by ESRD:
a) Sour Gas Processing Plants: Within one year upon sanctioning of the
Framework.
November 15, 2013 Non-Routine Flaring Framework 29
b) Compressor stations and oil and gas batteries: Within two years following
sanctioning of the Framework.
c) Well sites and pipeline risers: Within four years following sanctioning of the
Framework.
d) If emissions change at existing AER licensed facilities the licensee, operator
or approval holder must reassess non routine flaring dispersion modelling criteria
when a renewal or amendment is required.
All processing facilities subject to Environmental Protection Enhancement Act –
Activities Designation Regulation must re-model upon renewal.
11 Next Steps
CAPP has indicated to the ERCB that the proposed non-routine flaring
management modelling guidance documentation, modelling tools and regulations
should be reviewed on an ongoing basis. This approach would provide the
NRFTT the opportunity to address and discuss possible resolution to identified
issues or concerns while evaluating the effectiveness of the new regulations to
address air quality related concerns.
The modelling requirements and Risk Based Criteria developed for non-routine
flaring are potentially transferable to almost any short duration and infrequent
emission event in any industry. However, the comprehensive plan to manage
these events developed by the NRFTT is specific to the upstream oil and gas
industry at this time and would not be applicable in other industries. The
downstream oil and gas industry has not been involved with this endeavour and
there is a need to discuss any potential changes to make this process applicable to
that industry or other industries.
November 15, 2013 Non-Routine Flaring Framework 30
References
Alberta Environment and Sustainable Resource Development. 2003.
Emergency/Process Upset Flaring Management: Modelling Guidance.
Alberta Environment and Sustainable Resource Development. 2013. Alberta
Ambient Air Quality Objectives and Guidelines.
Alberta Environment and Sustainable Resource Development. 2013. Air Quality
Model Guideline.
Alberta Environment and Sustainable Resource Development. 2013. Using
Ambient Air Quality Objectives in Industrial Plume Dispersion Modelling
and Individual Industrial Site Monitoring.
Alberta Environment and Sustainable Resource Development. 2013. Non-Routine
Flaring Management; Modelling Guidance.
Canadian Association of Petroleum Producers. 2006. Best Management Practice
for Facility Flare Reduction.
Energy Resources Conservation Board. 2011. Directive 060: Upstream Petroleum
Industry Flaring, Incinerating, and Venting.
Energy Resources Conservation Board. 2008. Directive 071: Emergency
Preparedness and Response Requirements for the Petroleum Industry.
November 15, 2013 Non-Routine Flaring Framework i
Appendix A Letter from the EUB to CAPP on December 23, 2004
November 15, 2013 Non-Routine Flaring Framework ii
December 23, 2004
John Squarek
Canadian Association of Petroleum Producers (CAPP)
Suite 2100, 350 7 Avenue SW
Calgary, AB T2P 3N9
Re: SO2 Dispersion Modelling for Temporary Flaring Events at Permanent Facilities
Dear Mr Squarek:
Section 1.1 of Guide 60 (1999 – currently in effect) requires that flares at existing permanent
facilities meet the flare performance requirements outlined in the Guide by December 31, 2004.
As part of these flare performance requirements, Section 7.3.4 of Guide 60 (1999) requires that
emergency sour and acid gas flares be evaluated for compliance with the Alberta Ambient Air
Quality Objectives (AAQO). If exceedances are predicted, corrective actions must be taken.
These actions include increasing stack heights, adding fuel gas or developing management plans
for such events.
When modelling temporary flaring at these permanent facilities, some of the predicted results
raise the question of whether the modelling protocols, designed primarily for continuous
emission sources, are overly conservative for low-frequency, temporary events. Modelling
predictions show this issue is most prevalent in complex terrain. The Alberta Energy and
Utilities Board (EUB), Alberta Environment, and Canadian Association of Petroleum Producers
(CAPP) have formed a Task Group to review the dispersion modelling for planned and
unplanned temporary flaring events at permanent facilities, such as emergency situations,
pipeline blow downs, maintenance, pressure safety valve releases.
While the Task Group continues to review this subject, operators must disclose (in writing) by
December 31, 2004 or as soon as possible thereafter, all permanent facilities with unresolved
potential of exceedances for unplanned temporary flaring. The EUB will not apply enforcement
consequences where these disclosures have been received.
If dispersion modelling has already been conducted, this information should be used to provide
corrective actions which will minimize predicted exceedances during flaring. Mitigative options
such as operating procedures should be considered. Operators should consult with the EUB if
significant changes in facility design or use of supplemental gas are being considered. Wherever
possible, it is requested that operators provide one disclosure for all of their facilities with
unresolved exceedance predictions rather than submitting multiple disclosures. Disclosures can
be sent to:
Michael Brown, M.Eng. P.Eng.
Operations Group
Alberta Energy and Utilities Board
640 – 5th Avenue S.W.
November 15, 2013 Non-Routine Flaring Framework iii
Calgary, AB T2P 3G4
Disclosures for unplanned temporary flaring at permanent facilities should include:
Location and name of facility;
Summary of potential unplanned temporary flaring scenarios, including flow rates,
duration, and predicted frequency of flaring occurrence;
Predicted downwind SO2 concentrations, if available (provide dispersion modelling
results and management plans, if available);
Topographic map showing 7 kilometre radius surrounding flare stack location, indicating
location of flare stack.
For planned temporary flaring events operators must conduct dispersion modelling where
currently required, prior to flaring. If unresolved predicted exceedances exist, please contact
James Vaughan at (403) 297-7530.
In the event of any unplanned or planned temporary flaring, it should be clearly
understood that all requirements for AAQO compliance are still in place.
Michael Brown, M.Eng. P.Eng.
Senior Production Engineer
Production Section
Operations Group
Compliance and Operations Branch
MB/LD
pc: Heather Douglas, Small Explorers and Producers Association of Canada (SEPAC)
November 15, 2013 Non-Routine Flaring Framework iv
Appendix B Alternative Solutions
November 15, 2013 Non-Routine Flaring Framework v
B.1 Physical modification of facilities
Solution: Increase stack height
Benefits: Increases the likelihood that the plume will disperse more effectively before
reaching the ground. From a modelling standpoint this is an easy item to assess
and if the extra height required is small, would be a fairly easy solution to
implement
Drawbacks: In complex terrain, concentrations can increase with a higher stack. In many cases,
the extra height of the stack required to achieve compliance was not trivial.
Increasing stack heights would have no effect on flare volumes
Conclusion: Possible solution but from a construction, structural, forestry, aesthetics, and
economic standpoints, is not considered practical solution in all cases
Solution: Fuel gas addition
Benefits: Will provide energy to the plume without adding more SO2 emissions. This will
increase plume rise and therefore enhance dispersion.
Drawbacks: Not all facilities have a fuel gas source or enough fuel gas or there exists a
pressure difference between the sources. The addition of fuel gas would increase
flare volumes and increase greenhouse gas emissions
Conclusion: Possible solution though not practical in all cases.
Solution: Installing more block valves on pipelines
Benefits: Would likely reduce flare volumes
Drawbacks: May not influence predicted concentrations as flow rates may not change
appreciably and durations may still remain longer than one hour. An increased
footprint would occur as more surface more leases would be required. Would only
influence the non-routine flaring of gas from pipelines
Conclusion: Possible solution though not practical in all cases
Solution: Sweetening or filters to remove H2S from the gas prior to flaring
Benefits: This would reduce SO2 emissions and therefore predicted SO2 concentrations
Drawbacks: Would not reduce flare volumes. It would not likely work for large flow rates and
would be problematic for unplanned events at small facilities where an amine
system is not located
Conclusion: Possible solution though not practical in all cases
Solution: Purging system with nitrogen prior to flaring
Benefits: Would eliminate the need to flare
Drawbacks: Could work for planned events but not for unplanned events
Conclusion: Possible solution though not practical in all cases
November 15, 2013 Non-Routine Flaring Framework vi
Solution: Using giant fans to increase dispersion
Benefits: Theoretically could reduce predicted concentrations
Drawbacks: Would not reduce flare volumes. Need to conduct extensive tests to determine the
effectiveness
Conclusion: Not considered a practical solution in all cases
Solution: Using incinerators instead of flares
Benefits: May improve combustion and conversion efficiency
Drawbacks: Would not necessarily improve dispersion and could increase predicted
concentrations. Would not reduce flare volumes
Conclusion: Possible solution though not practical in all cases
Solution: Relocating flare stacks from areas of complex terrain
Benefits: Likely reduce impact on environment from SO2 emissions
Drawbacks: Would involve major design and operational considerations. Would likely have no
effect on flare volumes
Conclusion: Possible solution though not practical in all cases
Solution: Eliminate or reduce flaring
Benefits: Flare reduction is an important regulatory and public interest issue. Reduce impact
on environment from SO2 emissions
Drawbacks: Flaring is an important safety feature built into all oil and gas facilities where
applicable so it is not practical to eliminate flaring. Likely involves design and
operational considerations
Conclusion: Considered to be a reasonable solution in all cases
B.2 Changes to the modelling approach
Solution: Modelling standardization
Benefits: Ensure certainty in dispersion model predictions by providing guidance on how to
model non-routine flaring
Drawbacks: Prescriptive methodology lacks flexibility for unique situations
Conclusion: Considered to be a reasonable solution in all cases
Solution: Using alternate models due to current regulatory models overpredicting in
complex terrain
Benefits: Potentially give more realistic concentration predictions
Drawbacks: Using non-regulatory models would require further guidance and add complexity
to the regulatory process
Conclusion: It was determined that overprediction by the regulatory models is most likely
caused by the inputs to the model such as meteorological data or stack parameters
being less than representative. Using alternate models to those recommended by
AENV is not considered a practical solution
November 15, 2013 Non-Routine Flaring Framework vii
Solution: Improved meteorological data
Benefits: Ensure more certainty in dispersion modelling predictions
Drawbacks: Could be cost prohibitive. Collecting meteorological data now is not an option –
need historic data is get a suitable period to be used for modelling
Conclusion: Considered to be a reasonable solution if data sources are available
Solution: Assume parallel airflow in models
Benefits: May give more representative dispersion modelling predictions in complex terrain
where increased turbulence is not considered
Drawbacks: Difficult to verify results. Ignoring the negative effect of terrain on predicted
concentrations
Conclusion: It is documented that high predictions can occur on elevated terrain so ignoring
terrain is not conservative and goes against standard regulatory approaches. It is
not considered to be a reasonable solution
B.3 Changes to the regulatory approach
Solution: Use an approach similar to what AENV uses for on-land spills which is to assess
the risks to the environment after a spill occurs. This approach would incorporate
corporate or site specific strategy for emergency response
Benefits: Well known regulatory approach
Drawbacks: Potentially too many instances of non-routine flaring to regulate effectively.
Reactive response is not considered practical
Conclusion: It is not considered to be a reasonable solution
Solution: Ambient monitoring
Benefits: Potentially able to precisely determine the impacts of flaring
Drawbacks: Only practical for planned events. Due to infrequency of non-routine flaring, it is
not likely to have monitors in correct location to determine impacts. Not possible
or cost effective to have enough monitors to determine impacts with absolute
certainty
Conclusion: Possible solution though not practical in all cases
Solution: Consider the infrequency of non-routine flaring using a risk-based modelling
criteria
Benefits: Provide a realistic picture of the impacts of non-routine flaring
Drawbacks: Potential difficulties in regulation of the acceptable risk levels
Conclusion: It is considered to be a reasonable solution
Solution: AAAQO not applicable to non-routine flaring
Benefits: May be applicable to real emergencies
Drawbacks: Health and safety of the public and the environment may be compromised
Conclusion: The regulatory approach is that the AAAQO are applicable at all times from a
monitoring standpoint. The reasons for an exceedance would be considered in any
legal action. It is not considered to be a reasonable solution
November 15, 2013 Non-Routine Flaring Framework viii
Solution: Real-time modelling system
Benefits: Determine impacts from flaring during an event and proactively react to prevent
exceedances of the AAAQO
Drawbacks: Only economical at the large facilities with continuous emissions as well as non-
routine flaring
Conclusion: Possible solution though not practical in all cases
Solution: Use approach in British Columbia for post flare modelling and foliar injury
considerations
Benefits: Potentially could determine if any environmental damage occurred during a flare
event
Drawbacks: Foliar injury criteria is much higher than AAAQO and requires more resources to
regulate. Reactive rather than proactive approach
Conclusion: Post flare modelling is a reasonable consideration if it is part of an overall strategy
to deal with non-routine flaring. Foliar injury criteria is not considered to be a
reasonable solution
.
November 15, 2013 Non-Routine Flaring Framework ix
Appendix C Terms of Reference for CAPP Non-Routine Flaring Task Team
November 15, 2013 Non-Routine Flaring Framework x
Joint AENV/EUB/CAPP
Non-routine Flaring Task Team
Terms of Reference Background
CAPP has indicated that the current management options may be insufficient to address
predicted ground level SO2 exceedances for non-routine flaring when modelled according to the
current guidelines (EUB Directive 060 and AENV Emergency/Process Upset Flaring
Management Modelling Guidance). In numerous cases the predicted ambient SO2 ground level
concentrations in complex terrain are higher than the Alberta Ambient Air Quality Objectives
and in many situations, the Objectives may not be met by current management practices. It was
decided that a partnership between government and industry will develop a comprehensive
management plan for non-routine flares.
The Non-Routine Flaring Task Team agreed that a comprehensive solution is necessary to
address emissions and air quality modelling for non-routine flares. The solution should address
minimization of non-routine flare events as well as updating air quality modelling to reflect the
nature of these emission sources. Reducing duration, magnitude and intensity of non-routine
flare events will minimize the stress on the environment. Both the probability of occurrence and
margin of error in modelling SO2 from these types of flare events will be reviewed and
acceptable approaches will be identified. It was agreed that the non-routine flares cannot be
modelled as continuous sources and a risk-based approach should be considered. The current
AENV Outlier Criteria used for continuous routine sources and the EUB Low Risk Criteria used
for well test flaring could be used as the basis for risk-based modelling for non-routine flares.
Goals
1. Eliminate/reduce non-routine flaring events through technology review or Best
Management Practices Guidelines.
2. Update air quality modelling guidance documents that are part of regulatory
requirements.
3. Identify under which situations physical modifications to facilities/flare stacks and
operating procedures should be implemented.
Several tasks were identified to meet these goals.
Tasks
1. Develop risk-based modelling criteria for non-routine flaring that address the infrequent,
intermittent nature of non-routine flaring events. (Risk-Based Criteria)
2. Establish a partnership between government and industry to develop representative
meteorological data that can be used for dispersion modelling purposes, including non-
routine flaring assessments in areas that are lacking data such as the foothills. (Met Data)
3. Update air quality modelling guidance documents to reflect the nature of non-routine
flaring and determine if risk-based criteria are met. (Modelling Refinements)
4. Review current technologies and operating practices used in facilities and recommend
changes appropriate to eliminate/reduce the frequency, duration and intensity of flare
November 15, 2013 Non-Routine Flaring Framework xi
events, and develop a Best Management Practices document to assist operators in
reducing non-routine flaring. (BMP)
5. Provide recommendations on the development of an outreach program to help to
implement the findings of the Task Team.
6. Develop a report summarizing the above findings that will include the Task Team’s final
recommendations.
A schedule follows. Task Team members are assigned to one or more of the first four tasks, as
identified below.
Schedule
1. Finalize draft Task Team report by June 30, 2006. Finalize Best Management Practices
document by June 30, 2006.
2. Complete final review of report by AENV, EUB and CAPP by September 30, 2006.
The schedules for the following deliverables are listed for information only, as they do not fall
under the control of the Task Team:
3. Finalize draft changes to EUB Directive 060 and AENV Emergency/Process Upset
Flaring Management Modelling Guidance by August 2006.
4. Initiate public consultations for one month for EUB Directive 060 and AENV
Emergency/Process Upset Flaring Management Modelling Guidance by September 2006.
5. Review public comments and update EUB Directive 060 and AENV Emergency/Process
Upset Flaring Management Modelling Guidance by November 2006.
6. Implement by January 2007.