Flaring and Venting Guidance - June 2021 Final
Flaring and Venting Guidance - June 2021 Final
Transition
Authority
Flaring and
venting guidance
Contents
1. Introduction 3
4. Operational guidance 7
4.1 General 7
4.6 Terminals 9
6. Consent variations 12
8. Definition of terms 14
Flaring and venting guidance 3
1. Introduction
Flaring and venting are controlled processes to The OGA will drive for reductions in flaring and
dispose of gas, essential for emergency and safety venting and associated emissions through its:
purposes on oil and gas installations, and in situations
where it may not be feasible for the gas to be used, • Principles: the principles that the OGA expects
exported or re-injected. Flaring is the ignition of industry to follow in relation to flaring and venting
gas, and venting is the release of unignited gas. • Regulatory approach: the OGA will use its
The OGA Strategy, which came into force in consenting regime to drive continuous reduction,
February 2021, incorporates a range of new net and where possible, elimination of flaring and venting
zero obligations for the UK oil and gas industry. The • Stewardship: the OGA will engage with operators
Central Obligation of the OGA Strategy requires, regularly to encourage continued reductions in
amongst other things, that relevant persons, in flaring and venting as part of Flaring and Venting
securing that the maximum value of economically Management Plans and Greenhouse Gas Emissions
recoverable petroleum is recovered from the strata Reduction Action Plans (as described in Net Zero
beneath relevant UK waters, take appropriate Stewardship Expectation 111), through short term
steps to assist the Secretary of State in meeting
operational optimisation as well as longer term
the net zero target including by reducing, as far as
investment plans to minimise or, where possible,
reasonable in the circumstances, greenhouse gas
eliminate the practice of flaring and venting
emissions from sources such as flaring and venting.
• Data: supported by updated industry reporting
requirements, benchmarking of flaring and
venting data, including through the OGA’s annual
flaring and venting benchmarking report and
the monthly flaring and venting data published
through the OGA Open Data Portal2
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https://www.ogauthority.co.uk/exploration-production/asset-stewardship/expectations/
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https://data-ogauthority.opendata.arcgis.com/
4 Flaring and venting guidance
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https://www.ogauthority.co.uk/licensing-consents/consents/flaring-and-venting/
4
Note that for flaring and venting, there are slightly different definitions of the gases emitted. For vent consents under the Energy Act 1976, both the inert gas and hydrocarbon fraction obtained
from the licensed area should be given, and the combined rate for both will be the basis for the consent. For flaring under the applicable licence, only the hydrocarbon fraction flared from the
licensed area requires consent, but the OGA will require the inert gas content of the flare to be provided.
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Flaring and venting guidance 5
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6 Flaring and venting guidance
The OGA will take the following regulatory approach in relation to flaring and venting:
1. OGA approach to decision making 2. Flare or vent consent variations will only be
considered in exceptional circumstances
• In making its decisions the OGA will, amongst
other things, take into account the Central • Flaring and venting consents must not
Obligation of the OGA Strategy, and the be exceeded
outcome of an OGA decision may therefore
result in curtailed or shut-in production • Any request for an increase to a flaring and
venting consent will be considered only as a
• The OGA may make a decision based on last resort
quantities of gas or on associated emissions,
including, for example, considerations • A request for increase in flare or vent consent
of flare combustion efficiency levels will need a very strong justification
and evidence that demonstrates a full
• The OGA may take into consideration other consideration to the Central Obligation
relevant matters, other than those related
to direct processes that result in flaring and • Further guidance can be found in the consent
venting, including for example, in the event of variation section
equipment failure, the history of maintenance
4. Operational guidance
4.1 General 4.3 Commissioning phase
Operators must minimise flaring and venting by During the commissioning of production facilities,
planning and implementing best practice at an early flaring and venting consents will usually be restricted
stage in development planning and design and through in duration to between one and three months and will
continuous improvements during the subsequent be for a fixed quantity of gas based on an auditable
operational phase. The operator should consider programme. Once commissioning is complete and
carefully all operational activities in accordance with stable operating conditions have been achieved, the
good oil field practices, taking into consideration duration of the flaring or venting consent (for new
plant uptime, efficient processing, handling, uses and issued consents) may be increased and will be subject
transportation of gas. Operators should prepare Flaring to an agreed cumulative maximum for the period.
and Venting Management Plans and the approach
should be considered and incorporated as part of The following principles shall be followed:
Greenhouse Gas Emissions Reduction Action Plans. Commissioning philosophy
These plans should be kept up to date and should be Gas flaring and venting during commissioning
made available on request from the OGA or OPRED. should be kept to the lowest level that is consistent
In addition to the high-level expectations and principles with the safe and efficient commissioning of oil/gas
set out above, this guidance also makes it clear, among related plant.
a number of technical revisions, that the OGA will: Installation and hook-up
• consider all flaring and venting consent requests, All gas plant must be complete, fully leak tested
regardless of quantity and otherwise tested and commissioned as far as
is practicable, and able to receive gas, before first
• have a presumption against granting multi-year production. A gas flaring or venting consent will not
consents be issued until the OGA is satisfied that the plant is
ready to receive gas. Emissions abatement technology
• require both annual and short-term consent should be operational at the earliest possible stage.
applications to provide, where applicable, full 12
months historical data to the date of application Commissioning and planning
If there is a significant delay in commissioning
• require consistent quantification and reporting due to plant breakdown or malfunction, the
of flaring and venting across all UKCS areas OGA may need to consider limiting production
• apply revised flaring and venting source categories until gas plant commissioning can proceed.
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8 Flaring and venting guidance
The OGA will consider this documentation and if Commissioning flaring and venting consent
satisfied that the commissioning plan achieves the application process
lowest level of flare/vent that is consistent with the Commissioning flaring and venting consents issued by
safe and efficient commissioning of oil/gas related the OGA are ‘short term’ consents, normally between
plant, then the flaring and venting figures may one and three months in duration. The commissioning
then be used as the basis for the commissioning consent is intended to cover the period from first
flaring and venting consent application. production to achieving and sustaining high uptime
stable plant operations. It is normally a requirement
Supporting documentation should be submitted of these consents that the operator shall provide
six months before expected production start- weekly reports to the OGA detailing the following
up. Depending on the complexity of the facilities information relating to the previous week’s activity:
to be commissioned and/or the size of the
project, the requirements of the supporting • a short technical summary of the performance
documentation may differ. Advice on the level of of the gas handling plant, highlighting any
detail required should be sought from the OGA. As features which have affected or could
a minimum, the documentation should contain: affect the operation of the plant
• a brief overview of the field and associated main • an update on commissioning activity progress and
facilities main works planned
• a detailed description of the plant commissioning • daily rates of oil production, gas production, gas
philosophy and procedure, including gas export export, gas used for fuel and of gas flare and/or vent
line commissioning should this be applicable,
setting out steps to minimise flaring and venting • cumulative plots of production and flaring and
venting compared to consented quantities for
• the commissioning schedule that period and a plot of associated emissions
• a summary of the main flaring and venting • gas compression plant uptime
assumptions and the greenhouse gas emission
profiles of different commissioning strategies
considered
Category A: Streams for the safe operation of the – During start up activities
asset based on its current design and operating at – Off spec product
optimum efficiency (excluding Category C). Streams
in this category are generally inherent in the design – Export route temporarily unavailable
of a facility and therefore reductions to flaring and • Gas disposed of during spurious
venting allocated to this category will generally require depressurisation events – spurious activation
facility modifications. Aligns with the World Bank Zero of a depressurisation system e.g. as a result
Routine Flaring Initiative routine flaring category. Gas of instrument fault, planned blowdowns
streams to be reported in this category include: carried out to facilitate plant maintenance.
• Metering packages reject streams Category C: Emergency disposal and gas streams
• Stabilisation/separation process off gas streams required specifically for the operation of safety critical
equipment/elements. Aligns with the World Bank
• Crude oil tank (COT) vents Zero Routine Flaring Initiative safety flaring category.
Gas streams to be reported in this category include:
• Reject gas from treatment units e.g. amine, glycol
• Hydrocarbon purge gas streams
• Gas disposal on facilities with no export route (including blanket gas)
Category B: Flaring and venting occurring during • Pilot gas
normal operations beyond levels optimum for the
installation. Reductions in flaring and venting in this • Hydrogen Sulphide disposal (including assist gas)
category can be achieved through operational changes
and optimisation. Aligns with the World Bank Zero • Gas disposed of during Emergency
Routine Flaring Initiative non-routine category. Gas Depressurisation events – depressurisation
streams to be reported in this category include: for safety concern, any genuine demand on a
safety system leading to depressurisation
• Separators spill off
• Inert purge gas (vent consents only)
• Valves passing to flare (passing
above performance rating)
An illustration of how these categories may
relate to operations are shown below.
• Gas disposal
--
Emergency Shutdown
Categories
-
& blowdown
A
C
Off spec/ excess gas
produced during start-up
-2!Cl)
\
prior to resuming export
a:
e!Cl)
u:::
Time@
>--- - - - Facility Online - - -- ~- -~ ~ Offline -➔•-tl••-
Shutting
down
Illustrative flaring and venting profile with gas stream category allocations (not to scale)
12 Flaring and venting guidance
6. Consent variations
The OGA expects that operators will not exceed Where flaring or venting is forecast to be in
flare or vent consent levels. Breach of consent may excess of consented levels, the OGA may ask
result in sanction under the terms of the licence. for and consider the following information:
Any request for increased flaring and venting consent • a robust remediation plan and investment
should be considered as a last resort. The OGA will plan, with approved budget and timing,
take a robust approach to considering any increases to revert to original consent rates
and operator justifications will be heavily scrutinised.
OGA consideration may include the recent events • options for, or evidence of, curtailment of
and/or the long-term history of operations and production to minimise flare and vent quantities
stewardship. For example, this may include history and associated emissions – including scenarios
(planning, frequency, quality and investment) of that result in the temporary shut-in of production
maintenance practices. OGA decision making will • analysis on scenario emissions
be made on the balance of OGA Strategy Central
Obligations and other relevant matters, and it should • evidence that export outages have been
therefore be noted that the OGA may consider planned for and all other options have been
that the curtailment of production is a necessary appropriately considered by the operator,
action to reduce flaring and venting activity. such as but not limited to:
Operators must inform the OGA as soon as it becomes – sheltering annual maintenance activities – planning
clear that there is a risk of flaring or venting consent activities where periods of zero production are
breach; this includes notifying the OGA of new risks of, required (e.g. annual maintenance shut downs)
or unexpected increases in, flaring or venting. Requests to align with known downstream/export outages
for consent variations must be submitted in sufficient
time for the OGA to consider the relevant details and – line pack
respond accordingly. Failure to notify the OGA in good
– evidence of UK Managing Director (or
time of a likely breach of consent may be taken as equivalent) awareness of the issue, and
evidence of poor management of emissions and the operator request for variation request
OGA may deny requests for consent variations and/
or pursue sanction action. As a result, operators may
have to curtail or stop production in order to remain
within consented flaring and venting quantities.
Flaring and venting guidance 13
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14 Flaring and venting guidance
8. Definition of terms
Cold Flare Net Zero
Gas passing through the flare without ignition – Means the net UK carbon account for the
effectively venting of gas through the flare system. year 2050, as set out in section 1 of the
This refers to a period of time where there is Climate Change Act 2008 (as amended).
no combustion (or zero combustion efficiency)
i.e. it is not the non-combusted component of OGA Strategy
a flare gas stream where combustion efficiency The revised Oil and Gas Authority Strategy
less than 100% but greater than 0%. that came into force on 11 February 2021.
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