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Assessment
According to Title 30 CFR § 250.1163, offshore facilities processing more than an average of 2,000 barrels of oil a day must install flare or vent meters. NTL No. 2012-N03 provides guidance on the BSEE procedures and requirements for installing meters. Measurements must be within 5 percent accuracy. Operators must use and maintain meters for the facility’s life. Meters must be calibrated regularly according to the manufacturer’s recommendation, or at least once every year, whichever is more frequent. All hydrocarbons produced from a well completion, including all gas flared or vented and liquid hydrocarbons burned, must be reported to the ONRR on Form ONRR-4054 (Oil and Gas Operations Report [OGOR]), per Title 30 CFR § 1210.102. Since September 15, 2010, leaseholders must specify the volumes of gas flared and vented separately in OGOR Part B. They must use different disposition codes for flared oil-well gas, flared gas-well gas, vented oil-well gas, and vented gas-well gas. The 2016 GAO report found that the ONRR’s guidance on reporting emissions from lost gas, whether flared or vented, lacked specificity. In reports, operators may classify gas used to operate lease equipment as lease-use gas. Where required, the amounts of gas flared and vented at each facility must be reported separately from that of facilities that do not require meters and separately from other facilities with meters. Flaring and venting from multiple facilities on a single lease or unit may be reported together.
According to NTL-4A , “the volume of oil or gas produced, whether sold, avoidably or unavoidably lost, vented or flared, or used for beneficial purposes must be reported.” The definition of beneficial purposes in NTL-4A is superseded by Title 43 Subpart 3178 , which primarily defines conditions for qualification as lease-use gas. Operators must also report to the regional supervisor “the volume and value of all oil and gas which is sold, vented or flared without the authorization” [of the supervisor], or those volumes deemed by the supervisor to be avoidably lost. All hydrocarbons produced from a well completion, including all gas flared, vented, and liquid hydrocarbons burned, must be reported on Form ONRR-4054, per Title 30 CFR § 1210.102. As with federal offshore, since September 15, 2010, leaseholders must specify flaring and venting volumes separately in the Oil and Gas Operations Report (OGOR) Part B. They must use different disposition codes for flared oil-well gas, flared gas-well gas, vented oil-well gas, and vented gas-well gas. According to NTL-4A, if the amounts of oil or gas involved have been measured, the measured volumes must be reported. Estimation criteria are provided. Metering is not required, but the BLM’s regional supervisors may require the installation of additional measuring equipment if the goals of NTL-4A are not met with existing equipment or estimation methods. Separately, operators must follow the guidance of Title 43 Subpart 3175 on gas measurement. This subpart has clauses on gas metering technology, hardware, and software requirements for metering, performance standards, and record-keeping requirements to ensure accurate royalty calculations.
NDAC Section 43-02-03-52.1 requires reporting of the amounts of gas associated with oil wells from the first day of production, including flowback and production test gas and flared volumes, using Gas Production Report Form 5B. NDAC Section 43-02-03-44 mandates all measurement equipment and volume determination used for reporting casinghead gas to be compliant with American Gas Association standards. DAQ requires operators to submit an Incinerators or Flares Annual Emission Inventory Report. Oil and gas operators may be responsible for submitting additional environmental reports to both DAQ and the EPA. Operators must use air quality models or formulas included in different chapters of NDAC Article 33.1-15 when reporting air emissions data.
Operators must report volumes of gas flared to the RRC using the monthly production report (Form PR). This report must include metered gas volumes from both gas wells and casinghead gas from oil wells at the lease level . The RRC updated instructions for completing Form PR and instructed operators to report flaring and venting separately and remark on the status of the RRC exception for each flaring or venting event. The RRC also developed an online system for the flare and vent program. This system includes information on flaring and venting applications. Texas SIP Vent Gas Control regulations require the operator of each affected flare or vent gas stream to adhere to reporting and record-keeping requirements, which include the development and implementation of a quality assurance plan for the monitoring requirements, including installation, calibration, operation, and maintenance of continuous emissions monitoring systems. Separately, operators must submit written notification to the regional office of the EPA at least 45 days before conducting any flare and vent gas stream testing, as required by Texas SIP.
Article 13 of Decree 638/1995 states that the composition of emissions from flaring must be analyzed using a minimum of three samples at each selected collection point when the study is carried out for the first time and a minimum of two samples after that. The runs should be carried out when the production volume is greater than the annual average. Article 26 requires operators to submit details of the composition of their emissions to MINEC at least annually. Article 28 of Decree 1257/1996 requires submission of an environmental supervision plan to MINEC for each project, together with a request for environmental authorization. In the case of hydrocarbons, the plan will be incorporated in the corresponding environmental impact study. The environmental supervision plan should include measures to mitigate the impacts of gas flaring and venting as well as the reporting of volumes and emissions.