Country
Assessment
At the macroeconomic level, the MGS, implemented by Saudi Aramco and supported by the government via large upfront capital investments in the 1970s, resulted directly from the desire to meet the country’s growing energy demand with gas-fired electricity generation and to increase value-added production of petrochemicals, while freeing oil, previously combusted for electricity generation and industrial uses, for exports. Such economic assessment continues to drive investments to capture associated gas that could be otherwise flared and deliver it to industrial and electricity generation facilities across the country. At the facility and corporate level, monthly reports from the FMS help operators estimate the financial impacts of flaring, and its reduction (see section 13 of this case study).
SAES-A-102 mandates all Saudi Aramco facilities with flares to have an FMP, which must be updated annually and must cover: policies and procedures to minimize flaring, measuring, monitoring, and recording of flared gases to be reported monthly (daily volumes of vent, pilot, and purge gases), causes of flaring (safety, leaks, upset, mechanical failure, startup/shutdown, and process/fuel imbalance), and preventive measures implemented and to be implemented per FMP. SAEP-400 provides the guidelines for facility FMPs, which are to be developed based on the FMS, developed by Saudi Aramco’s Process & Control Systems Department. This standardized tool must be implemented at all flare systems across Saudi Aramco facilities. According to SAEP-400, all facilities must provide daily, monthly, and annual reports, with the goal of mitigating flare volumes by area and plant. These reports are to outline the sources and reasons for flaring as described in Section 8.4 of the guidelines. The FMS was granted a US patent and is described in Appendix 8, SAEP-400A . The guidelines call for identifying and monitoring all equipment that may cause flares to malfunction; offer detailed system design recommendations and engineering equations; and set key performance indicators. The FMS software allows for the collection of real-time data from all equipment. Monthly reports from the FMS help operators distinguish between routine and nonroutine flaring, identify volumes released from each piece of equipment, and estimate financial impacts, all of which inform each facility’s FMP and allow analysts to benchmark recent flaring data against each facility’s best historical performance. Stations in the Air Quality and Meteorology Monitoring Network (AMMNET) track ambient air quality. Saudi Aramco’s Emissions Monitoring Solution tracks greenhouse gas emissions across company operations. The company plans to include air emissions in this system according to Saudi Aramco’s 2021 sustainability report . SAES-A-100, Section 5.16, requires major new facilities to install at least one new AMMNET station, the location of which has to be approved by the Environmental Engineering Division. The Executive Regulation for Air Quality includes technical requirements for flare systems burning volatile organic compounds (VOCs) (Article 5, Section 7). These regulations apply to petroleum refineries and petrochemicals facilities not operated by Saudi Aramco as well as other industries. Reporting requirements are not included in the Executive Regulation for Air Quality but NCEC may develop such requirements in the future. According to RCER-2015 , Volume I (Regulations and Standards), Section 8, operators are to report the quantity and estimated composition of gases flared monthly, fugitive emissions annually, point source emission data annually, and an air emissions inventory for renewal of their environmental permit. Table 2D of RCER-2015 Volume I (Regulations and Standards) lists air emission sources subject to continuous monitoring, which include refineries. The monitoring focuses on opacity, carbon monoxide, and sulfur dioxide, and not explicitly on flaring, venting, or methane emissions.
According to SAEP-400 , all Saudi Aramco facilities must be required to monitor gases directed to flares using flow meters approved by the Process & Control Systems Department. Meters should be maintained and calibrated to ensure accuracy over time. Compliance with flare minimization plans is monitored by the relevant Saudi Aramco department. Monitoring of real-time operations is centralized at Saudi Aramco’s 4th Industrial Revolution Center in Dhahran per Saudi Aramco’s 2021 sustainability report. Outside Saudi Aramco, operators of industrial facilities must install digital recording devices to detect the presence of a flame at each flare and devices to measure the total volume of VOCs entering the flare under Article 5, Section 7, of the Executive Regulation for Air Quality . According to RCER-2015 , Volume I (Regulations and Standards), Section 2.4.4, “Flares shall be operated with a flame present at all times which is to be monitored by a thermocouple or an equivalent device to detect the presence of a flame. In addition, the continuous imaging (digital recording) of all new flares (the existing flares, if possible) with date and time shall be maintained. All facilities, having flares, shall install flare flow monitoring device (like Ultrasonic Flow Meter) on the vapor line after liquid knock-out drum.”
RCER-2015 Volume I, Section 2.11, allows for air emissions, including fugitive emissions, to be based on the United States Environmental Protection Agency (US EPA) AP-42: Protocol for Equipment Leak Estimates.
Saudi Aramco’s FMS aggregates facility-level flaring-related data at the corporate level. Specific requirements on how long the data are kept, either at facilities or at the corporate level, were not identified for this case study. According to RCER-2015 , Volume I (Regulations and Standards), Section 8.3, operators must maintain records “on site in an organized and legible fashion.” Records are required for all activities subject to the regulations, including flares. Records must be kept for at least three years and be made available for inspection. According to Article 6, Section 1, of the Executive Regulation on Air Quality , “All persons must keep data, records, and annual reports on the progress made and the status of fugitive emissions management for a period of no less than five (5) years, and must submit them to the center upon request, and the center may increase the period for some activities for another five (5) years.” According to Article 6, Section 2, of the Executive Regulation on Air Quality, operators are required to monitor all units and network components where the concentration of VOCs or methane exceeds 10 percent. Leaks of VOCs and methane can be determined using US EPA Method 21.
Historical data on Saudi Aramco facilities, in aggregate, can be found in various publications of the company, but no facility-level information on flaring, venting, or emissions is made publicly available on a regular basis.
Under Article 8 of the Executive Regulation for Air Quality , “failure to comply with the requirements of the design, installation and operation of flare systems” is subject to penalties from SRI 50,000 to SRI 500,000 based on the amount and duration of emissions. Under RCER-2015 Volume III (Penalty System), operators can be fined if, upon inspection by the Royal Commission, they are found to violate venting, flaring, and emissions regulations outlined in Volume I. Section C3 provides the formula used in calculating the penalty. The minimum fine is SRI 5,000.
Saudi Aramco engineering procedures and guidelines call for the deployment of flare systems that ensure the efficiency of hydrocarbon destruction and avoidance of nonroutine flaring during interrupted operations, under high gas line pressure, or for safety reasons. Article 5, Section 7, of the Executive Regulation for Air Quality , provides technical specifications of when the flaring of VOCs is allowed, as well as performance requirements for flare systems, such as expulsion velocity under various conditions.
No evidence of fiscal incentives to reduce emissions was found.
No evidence of market-based incentives was found. However, since the 1970s, the development of the MGS and its ongoing expansion is driven by the economic value of captured associated gas.