Alberta Landowners Guide, Air Emissions
 3rd edition | |
| Authors: | Duncan Kenyon, Nikki Way, Andrew Read, Barend Dronkers, Benjamin Israel, Binnu Jeyakumar, Nina Lothian |
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| Publisher: | Pembina Institute |
| Publish Date: | October 2016 |
| PDF Download: | [Landowners' Guide] [Landowners' Primer] |
| Initiation Phase | |
| Exploration Phase | |
| Development Phase | |
| Pipelines and Other Infrastructure | |
| Environmental Impacts Emergencies Oil and Gas Operational Impacts, Conservation and Reclamation Air Emissions Drilling Wastes Water Other Impacts | |
| Abandonment and Reclamation | |
| Compensation, Rights, and Hearings | |
| Appendices | |
Flaring and venting from wells, gas plants and other facilities and the associated smoke, odour, and potential exposure to hazardous air pollutants have long been a source of concern for those living and working near oil and gas operations.[1]
Flaring and Venting
There are several types of flaring:
- Well test flaring occurs during the initial tests to find out a well’s capability (see Well Testing).
- Coalbed methane flaring takes place when coal seams that contain water are dewatered to reduce the pressure and release the methane gas. During this dewatering phase it may not be economic to pipe small volumes of gas, especially if an exploratory well is at some distance from an existing pipeline, so a company may want to flare it for several weeks or months.
- Hydraulic fracture flaring occurs during well testing of hydraulically fractured wells. Similar to conventional well test flaring, the rate of oil and gas production is measured to infer future oil and gas production. The gas that is produced during testing must be managed either through flaring or venting. As with conventional wells, it is possible to use an incinerator instead of a flare stack at a hydraulically fractured well. More discussion on hydraulic fracturing operations is provided in About Hydraulic Fracturing.
- Solution gas flaring (and venting) occurs at batteries, where oil from one or more wells is processed and stored. The solution gas is a by-product in oil production, separating out from the oil at the lower pressures present at the Earth’s surface. These flares burn constantly. In some cases where there is insufficient gas to sustain a flare, the AER may allow direct venting of the solution gas. However, if an operation is within 500 m of a residence and solution gas volume produced is more than 900 m3 a day, the operator must conserve solution gas.[2]
- Gas processing plants use flares to burn off by-products for which there is no market. They also burn off gas during emergency conditions.
- Temporary flares are sometimes used at facilities and wells during pipeline maintenance operations and servicing.
- Continuous flares, although not preferred, may be permitted by the AER if an operator demonstrates that is not economically feasible to capture solution gas. Continuous flaring may also be permitted if the operation will flare less than 900 m3 a day, but the AER still has the discretion to require a company to assess the economic viability of conserving the solution gas.
- Emergency flares are used when a well or facility faces operational challenges, and pressures reach potentially dangerous levels. In these cases, excess gas is flared to drop equipment pressures.
| Background information on flaring is given in Flaring: Questions + Answers.[3] |
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Research done by the former Alberta Research Council showed that a flare can release a
large number of air pollutants, including unburned hydrocarbons and other harmful
substances that result from incomplete combustion. The products of incomplete
combustion depend on the constituents in the gas that is burned but can include BTEX
aromatics,[4] polycyclic aromatic hydrocarbon compounds and, if the gas is sour,
hydrogen sulphide (H2S). When H2S is burned, it produces sulphur dioxide, which is also
harmful (see Risks of sour gas).
If problems are occurring with flares, you should first contact the company and make
them aware of the situation. You can also call the AER’s emergency and complaint line
to register your complaint, asking them to investigate and take action.[5] Signs of
problems with flaring include visible black smoke or plumes, frequent or long-lasting
flares, continuous flaring for projects that have not been approved for such, or
abnormally intense flames. If you experience health issues that seem to be correlated
with flaring activity, take detailed notes about flaring activity nearby.
You should document issues, especially if they are ongoing: take photographs of flares
and smoke, and keep records of the date, nature of the occurrence and length of time
that the problem persists. Be sure to include something in the photograph to provide
scale and to identify the location where it was taken — such as the company sign
adjacent to the site. Ideally, you should use a camera that includes a date and time
stamp on the image. This is especially important in cases where the flaring event may
conclude before a field inspector can come to the site to investigate.
| Ensure you document any issue you have with an operation, including the time you spent investigating the problem, associated damages, and other relevant details. See the example in Appendix D at the end of the guide for ideas of what you should document. |
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Venting of gases can also pose problems. Venting occurs when solution gases from oil
wells, batteries or tanks are released unburned to the air. Some venting may also occur
from compressor vents, instrument gas stations, pneumatic devices, dehydrators and
storage tanks. This release of unburned hydrocarbons to the atmosphere creates odours
and exposure to potentially harmful substances. Vented gas also contributes to global
climate change and wastes a non-renewable resource. Current AER regulations set
standards for venting and allow venting of small volumes of gas where it is not
considered practical to recover or flare it. For example, continuous venting of gas
containing H2S must not exceed Alberta Ambient Air Quality Guidelines[6] for H2S or result
in odours outside the lease boundary. There are also limits on the total amount of
benzene that may legally be released.[7]
| Venting of natural gas or methane from oil and gas operations is a significant contributor to climate change. Methane is 86 times more potent as a greenhouse gas than carbon dioxide, over a 20-year period. The Government of Alberta has announced as part of its Climate Leadership plan that methane emissions will be reduced by 45% below 2014 levels by 2025. |
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Flaring and venting can be eliminated in various ways, such as by piping the gases for
other processing, using the gas on-site to drive equipment or provide heat, or pooling
gas from several small sources and sending via pipeline to processing plants. When
deciding about flare reductions, a company must consider economic, social and
environmental factors, including the proximity of nearby residents.
While emissions from solution gas flares and gas plant flaring have received most of the
attention, there is also concern about flaring and venting from pipeline maintenance.
Pipeline maintenance is often preceded by purging the line and flaring or venting the
gas directly to the atmosphere. To inspect the condition of pipeline walls, a cylindrical
device known as a “smart pig” is sent along the pipe; it detects and sends back data on
cracking and corrosion.
| Background: Flaring in Alberta The Alberta Research Council study led to a review of flaring and subsequent efforts to reduce flare emissions. At the request of the oil and gas industry, a multi-stakeholder project team of Alberta’s Clean Air Strategic Alliance (CASA)[8] was formed to develop recommendations to manage solution gas flaring in the province. The initial recommendations adopted were successful in substantially reducing emissions, but due to a lack of consensus over measures that would generate further reductions, the CASA team was disbanded in 2010. |
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| Flared volumes reached an all-time low in 2009 but have subsequently returned to early 2000s levels due to lower natural gas prices and increasing pipeline and compression costs.[9] Despite the initial success, the regulations related to solution gas flaring were never intended to remain static over the long term. It was recognized that alterations may be necessary to account for new technologies, new production methods, and new economic conditions. The approach has not been comprehensively reviewed since 2010 when the CASA team provided their final report. |
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Incinerators
In some circumstances using an incinerator may be preferable to flaring. Some types of incinerator can burn with high efficiency and thus minimize odour and air pollution, including greenhouse gas emissions.[10] Unlike flares, the efficiency of well-designed incinerators is not affected by cross-winds. Additionally, an incinerator reduces the noise and eliminates the light associated with flare.
A company will consider a variety of factors when determining whether to use a flare or
incinerator, including cost, volume of gas flow, proximity of houses and land
topography. Although the emissions from an incinerator may be less than a flare, they
are released closer to the ground and may not disperse as effectively. Thus, if a well is
close to a dwelling located in a hollow, a flare stack may be considered preferable to an
incinerator.
Well Testing
After a company has drilled a well, it must be tested to determine characteristics about the oil or gas being produced, rate of production, and other factors for production. During this testing, reservoir fluids and gas can be produced and must be managed accordingly. The reservoir fluids can be stored on site before being transported for waste management. The produced gas, after it is separated from the fluids (see Drilling Wastes), can be transported in a pipeline for processing or can be flared or vented at a well site. If flaring or venting is used, air quality might be affected.
The recommendation for producers is to first try to avoid any gas emissions at all. If
they cannot be avoided, the emissions should be minimized, and any emissions that do
occur should meet the performance requirements. Gas capture is preferred to flaring,
and flaring is preferred to venting.
The AER allows 21 days to complete well testing. Although a company can apply to the
AER for a longer test period under specific circumstances, any flaring and venting
during well testing must not exceed 72 non-consecutive hours.[11] Flaring approved by
the AER must conform to Alberta Ambient Air Quality Objectives and Guidelines.[12] The
challenge is that there are no requirements for ongoing air monitoring at wells that do
not contain H2S, and in some instances it will not be known if these guidelines are
exceeded. If you believe these operations are exceeding these standards, it is important
to inform the AER immediately so that they may be able to respond to the complaint in
time to measure the air quality event. Even in an instance where the individual project
may still be in compliance, it can be helpful to register your complaints with the AER so
they can see over time that this may be an area of concern.
| Flaring intensity during oil and gas well testing has increased consistently since 2005; in 2014 well test flaring per well drilled was over 90% greater than in 2005. This is related to the increasing number of horizontal, multistage-fractured wells being drilled.[13] |
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Well test flaring may emit pollutants that can damage vegetation and affect human and
animal health. As explained in Site Selection and Setbacks, setbacks are intended to protect people from
exposure, but people may wish to be alerted during well tests. The AER requires a
company to notify its local field centre, the local municipality, and rural residents
before testing an oil well or sour gas well using a flare that will last more than four
hours in a 24-hour period.[14] The requirements are different for oil wells and gas wells,
but the minimum notification radius ranges from 0.5 km to 3 km depending on the
composition of the gas being flared, duration of the flare and the gas volume
discharged.[15]
Companies are not automatically required to notify adjacent landowners or occupants
when they test flare for a shorter duration. However, the AER suggests that companies
conduct “good neighbour” operations, where residents have identified themselves as
being sensitive to or interested in emissions from a facility.
You may want to arrange for livestock to be located upwind or away from the flare. If
you or others suffer from respiratory illness, you can negotiate with the company to
ensure that it notifies you when it plans to carry out its well-test flaring so you can
leave the area at that time. You may want to make arrangements for the company to
delay the start of a well test or to stop a test if meteorological conditions are
unfavourable and would result in pollution concentrating at ground level. Although
regulations require companies to ensure ground level concentrations do not exceed
maximum allowable levels, general ambient monitoring is not always required.
In an established area where pipelines are already nearby, a company may be able to
greatly reduce well test flaring by conducting an in-line test through a pipeline to a
processing facility. However, a short period of flaring will probably be required to
remove any remaining fluids from the well after it is drilled, since the fluids could cause
corrosion if released into the pipeline.
If small quantities of solution gas are measured in an oil well, it may not be economic
for the company to collect and pipe the gas. Instead, a company may want to install a
permanent flare stack or incinerator for production from such a well. Operators with
continuous solution gas flares, incinerators or vents are expected to provide public
information packages with the following information:[16]
- the definition of solution gas, and information on its conservation and use
- an explanation of solution gas flaring, incineration, and venting management options and the decision process
- a summary of analysis completed to determine that flaring, incineration, or venting is needed
- information on general flare/vent performance requirements and reduction targets
- descriptions of specific actions the licensee or operator will take to eliminate or reduce flaring, incineration, or venting or improve the efficiency of the flare, incinerator, or vent source based on the evaluation
- a list of industry, AER, and government contacts that are related to public consultation and relevant to the project.
Total solution gas flared and vented reached an all-time low in 2009, while the overall conservation rate has remained relatively stable at 95 percent through this period.[17]
| Air emission issues at compressor stations are described in Compressor Stations. Dehydrators, which may be located at well sites, are described in Sour gas plants. |
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Odour
In most years, odour is the most frequent cause of complaints to the AER.[18] Venting of gases (especially from crude oil and bitumen batteries), tank venting, leaking tank seals or ineffective vapour recovery units on storage tanks can cause odours. If there is an odour it is important to notify the company and AER at once and ask that action be taken to locate and stop the source. If the odour is caused by H2S see What to Do in a Sour Gas Emergency for information on evacuation in emergency situations. If you are concerned that you or individuals in your household might be affected by the emissions, you may wish to leave the area. If you leave because of odours when there is no general emergency, you should notify the AER as to the reason that you left.
If you are troubled by a recurring odour, notify the AER of each event or on a regular
basis. Keep a record of when events occur, noting the wind direction, wind strength,
ambient temperature, and any other weather conditions that may be present during the
event. You should also document your description of the odour during each event, as
that may reveal details to assist finding the cause of the odour.
As indicated in Risks of sour gas, Alberta Health has reviewed the health effects associated
with short-term exposure to low levels of H2S.[19] There are still many gaps in our
knowledge about the long-term effects of exposure, but “there is evidence that
cumulative health effects of repeated low-level H2S exposure exist.”[20] The specific risk
of low-level exposure to H2S for the general population or sensitive people is not
known.
The AER has two mobile monitoring units to measure H2S and sulphur dioxide, as well
as infrared cameras that detect leaks of hydrocarbons.[21] The AER uses these units to
monitor locations where there have been odour complaints. If you have a problem, ask
the AER to set up the monitoring unit in your area. Sometimes the AER will require a
company to conduct its own air monitoring when they have received a complaint, or the
AER may work with Alberta Environment and Parks and partner airshed organizations
to conduct further monitoring, as they may have mobile monitoring equipment that can
measure for more substances at lower concentrations.[22]
It is important that any monitoring equipment is properly located in an area where the
air pollution is high and where conditions lead to bad air. Thus, the equipment should
be downwind, where the emissions seem to be the worst when the wind speed is low or
during air inversion conditions. Landowners or occupants can suggest what they
consider to be the best monitoring location based on their experiences.
References
- ↑ This material is from the Pembina Institute publication 'Landowners' Guide to Oil and Gas Development, 3rd edition (2016)'
https://www.pembina.org/pub/landowners - ↑ AER, Directive 060: Upstream Petroleum Industry Flaring, Incinerating, and Venting (2015), section 2.6.
- ↑ Robert D. Bott, Flaring: Questions + Answers (Canadian Centre for Energy Information, 2007).
http://www.ccacoalition.org/en/resources/flaring-questions-answers-2nd-edition-canadian-centre-energy-information - ↑ Mel Strosher, Investigations of Flare Gas Emissions in Alberta, Special Report 005 (1996).
http://ags.aer.ca/publications/SPE_005.html - ↑ The AER’s Energy and Environmental Emergency 24-Hour Response Line is 1-800-222-6514. You can report an energy or environmental emergency or complaint, and the each call is triaged and forwarded to the appropriate filed centre for a response.
- ↑ Alberta Environment and Parks, Alberta Ambient Air Quality Objectives and Guidelines Summary (2016). https://open.alberta.ca/publications/9781460134856. This link has been updated since the 2016 publication; the updated link may no longer contain the original information.
- ↑ AER, Directive 060, section 8.3.
- ↑ The Clean Air Strategic Alliance (CASA) is a multi-stakeholder partnership of industry, government and non-government organizations. CASA’s mandate is to bring together diverse stakeholder groups to solve air quality problems on a consensus, rather than adversarial, basis. See Clean Air Strategic Alliance.
- ↑ AER, Upstream Petroleum Industry Flaring and Venting Report, ST60B-2015, 4, 6.
https://www.aer.ca/providing-information/data-and-reports/statistical-reports/st60b.html. This link has been updated since the 2016 publication; the updated link may no longer contain the original information. - ↑ See, for example, Questor Technology Inc. at http://www.questortech.com/ Some so-called incinerators are similar to low-level shielded flares and do not achieve the high combustion efficiency of refractory incinerators. An efficient, well-designed incinerator should not require the addition of propane to the gas to ensure continuous burning.
- ↑ AER, Directive 060, section 3.2.
- ↑ Alberta Environment and Parks, “Ambient Air Quality Objectives.”
https://open.alberta.ca/publications/9781460134856. This link has been updated since the 2016 publication; the updated link may no longer contain the original information. - ↑ Upstream Petroleum Industry Flaring and Venting Report, 10.
- ↑ AER, Directive 060, table 2.
- ↑ AER, Directive 060, table 2.
- ↑ AER, Directive 060, section 2.10.1.
- ↑ Upstream Petroleum Industry Flaring and Venting Report, 3.
- ↑ Field Operations Provincial Summary 2012, 3.
- ↑ Alberta Health and Wellness, Health Effects Associated with Short-term Exposure to Low Levels of Hydrogen Sulphide — A Technical Review (2002). https://open.alberta.ca/dataset/e7287172-b3b6-4a78-a8f4-1419e6487209/resource/c1f782b8-8195-4d90-ac1e-34e6a9bf20ae/download/health-hs2-exposure-2002.pdf. This link has been updated since the 2016 publication; the updated link may no longer contain the original information.
- ↑ S. Roth and V. Goodwin, Health Effects of Hydrogen Sulphide: Knowledge Gaps, prepared for Alberta Environment (2003), vi. http://www.assembly.ab.ca/lao/library/egovdocs/2003/alen/141128.pdf. This link has been updated since the 2016 publication; the updated link may no longer contain the original information.
- ↑ Field Operations Provincial Summary 2012, 2.
- ↑ The former Alberta Environmental Monitoring, Evaluation and Reporting Agency (AEMERA) was disbanded in 2016, and Alberta Environment has reassumed the roles of environmental monitoring and reporting.
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