Bulletin 2011-32

Bulletin 2011-32: Amendments to Directive 060: Upstream Petroleum Industry Flaring, Incinerating, and Venting, the Oil and Gas Conservation Regulation, and the Pipeline Regulation

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Amendments to Directive 060: Upstream Petroleum Industry Flaring, Incinerating, and Venting, the Oil and Gas Conservation Regulation, and the Pipeline Regulation

Nov 03, 2011

The Energy Resources Conservation Board (ERCB) has made the following amendments to Directive 060: Upstream Petroleum Industry Flaring, Incinerating, and Venting, the Oil and Gas Conservation Regulations (OGCR), and the Pipeline Regulation to remove discrepancies and improve consistency and clarity.

1) Compliance Assurance

The ERCB is making an effort to consistently communicate information on compliance in its directives in accordance with Directive 019: Compliance Assurance. Within Directive 060, this section has been amended to better reflect the ERCB’s compliance assurance process and clarify the circumstances under which licensees, operators, and approval holders will be assessed compliance in accordance with the newly added Sections 7.035 and 1.3 of the OGCR and Pipeline Regulation respectively, and the amendment to Section 7.040(1) of the OGCR.

The previous 2006 edition of Directive 060 also contained a list of noncompliant events and risk ratings within Section 12.2 that are now on the ERCB website www.ercb.ca under Industry Zone : Compliance and Enforcement : Risk Assessed Noncompliance.1 The ERCB determined that the tables within Directive 060 were redundant and required removal.

See Section 1.5: Compliance Assurance in this edition of Directive 060.

2) Flaring Notification Requirements

The ERCB identified a discrepancy between the flaring notification requirements in Section 7.060(9.5) of the OGCR, which are based on the type of well, either oil or gas, and those in
Table 2 of Section 3.9 in Directive 060 , which are based on hydrogen sulphide (H 2 S) content. Since flaring notification distance requirements in Directive 060 are based on H 2 S content and both oil and gas wells are capable of producing H 2 S, the ERCB will apply the notification requirements in Table 2 of Section 3.9 to flaring. Section 7.060(9.5) of the OGCR has now been repealed.

Information on addressing concerns of nearby residents prior to commencing proposed and existing flaring or incinerating activities have also been clarified (see Section 3.9.1).

3) Definition of “sour gas”

Directive 060 and Directive 071: Emergency Preparedness and Response Requirements for the Petroleum Industry contained different definitions for the term “sour gas.” The definition of “sour gas” in Appendix 4 of Directive 060 now reflects the definition of “sour gas” as defined in Directive 071 .

4) Removal of references to “Public Health” or “Health Impact” from Directive 060

Directive 060 requires that the heating value of gas being flared meet ERCB requirements to maximize the combustion efficiency and destruction of waste gas and encourage the proper dispersion of emissions from flaring. Directive 060 requirements aim to reduce or eliminate any potential and observed impacts associated with these activities and ensure that public safety concerns and environmental impacts are addressed prior to commencing flaring, incinerating, and venting activities. Potential effects on public health from flaring are addressed under Alberta Environment’s Alberta Ambient Air Quality Objectives (AAAQO) . The ERCB has adopted these objectives within its Directive 060 requirements. 2

As licensees must meet the requirements of Directive 060 and must not exceed the AAAQO, references to “public health” and “health impacts” in the decision trees of Sections 2 through 6 have been removed. Directive 060 and the AAAQO together protect health and address potential public concerns before permitting flaring, incinerating, or venting.

5) Measurement and Reporting Requirements

After the release of the previous edition of Directive 060 , the ERCB discovered two errors within the metering requirements and guidelines of Section 10.1(1). This requirement has now been amended to

  • include intermittent flare and vent sources to have metering if volumes exceed 0.5 10 3 m 3 /day and
  • exclude cold heavy oil and crude bitumen to have metering if volumes exceed 0.5 10 3 m 3 /day. (See Section 12.3.2 of Directive 017: Measurement Requirements for Oil and Gas Operations for cold heavy oil and crude bitumen flaring requirements).

In addition to the above, the definition of and/or references to Directive 060 within the OGCR and the Pipeline Regulation have also been reviewed and amended. Efforts to remove discrepancies and improve consistency and clarity have also resulted in other updates to the content of Directive 060 , including references to the ERCB as the EUB. See Section 1.2 of the new edition of Directive 060 for a detailed list of changes.

Future Amendments to Directive 060

Future updates to Directive 060 are anticipated, including technical revisions. These revisions will go through stakeholder consultation and be phased in over time.

Directive 060 is available from ERCB Information Services, 250 – 5th Street SW, 10th Floor; telephone: 403-297-8311 or 1-855-297-8311 (toll free); fax: 403-297-7040; e-mail: infoservices@ercb.ca. The directive is also available on the ERCB Web site www.ercb.ca.

Amendments to the OGCR have already been released and copies are available on the Queen’s Printer website at www.qp.alberta.ca. Copies of the Pipeline Regulation that include the new amendments will follow later this year and also be available from the Queen’s Printer.

For questions on Directive 060 contact James Vaughan, ERCB Production Operations, by e-mail at james.vaughan@ercb.ca or by telephone at 403-297-7530. Questions on Directive 019 can be directed to ERCB Compliance Assurance by e-mail at compliancecoordination@ercb.ca or by telephone at 403-297-8316.

<original signed by>

Robin King
Executive Manager
Field Surveillance and Operations Branch

1 The Risk Assessed Noncompliance spreadsheet is a list of noncompliant events and risk ratings that can be used as a tool for identifying ERCB requirements that have been risk-assessed in accordance with Directive 019 . The ERCB makes every effort to keep this spreadsheet current for informational purposes; however, if a specific noncompliant event is not on this list it does not preclude industry from understanding ERCB requirements and does not exempt industry from a Directive 019 enforcement response if not in compliance with an ERCB requirement.

2 See ERCB Decision 2011 ABERCB 002: West Energy Ltd./Daylight Energy Ltd., Review Application No. 1647499 , A Section 39 Review of Linda McGinn’s Status under Section 26 of the ERCA re. Hearing of Application No. 1623169, Pembina Field, paragraphs 19–23.