Notes (M015 released Dec 2020)

Tuesday, February 9, 2021 8:57 AM

Section 1.
- This document explains
○ How to report vent gas and fugitive emissions to the AER
○ How to quantify vent gas and fugitive emissions
○ The relationship between facility IDs and sites

Section 2.
- When reporting vent gas to Petrinex, the GAS product code with the VENT activity code is used
- Vent gas reported to Petrinex includes all types of vent gas, including
○ Routine sources
 DVG
 Pneumatic Devices
 Compressor Seals
 Glycol Dehydrators
○ Non Routine Sources
○ Note: fugitive emissions are excluded from Petrinex reporting
- VENT volumes reported to Petrinex are in 103 m3 and rounded to one decimal place, meaning any
volume less than 49 m3 in a month is rounded to zero.

Section 4.1 General Emission Estimation

- Unless otherwise required to measure or test a vent gas stream through Directive 017 or Directive
060,
emissions may be estimated using emission factors or rates, the equations included within this
document,
or engineering estimates as described in Canada (2016).
- Site- and equipment-specific data should be used when quantifying and reporting emissions.
While not a
requirement, continuous direct measurement or periodic testing of individual emission sources is
encouraged where possible and where these solutions would result in more accurate reporting of
emissions than the methods discussed in this document.
4.4 Pneumatic Devices
- If not metered, vent gas emitted from pneumatic devices is calculated using equation 9, where the
emission rate used is specific to the make, model, and operating conditions of the instrument or
pump
(m3 vent gas/hour) and time use is number of hours the device was in operation each month
(hours/month).
-

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Notes (D060 released July 2020)
Tuesday, February 9, 2021 9:16 AM

- Defined vent gas (DVG) is vent gas from routine venting, excluding vent gas from pneumatic
devices, compressor seals, and glycol dehydrators

1.2 What's new in this edition

- Requirements around flaring and incineration in section 2.6 have changed. For any site with first
gas disposition after January 1, 2020, that is not conserving and is between 100 and 500 metres of
a residence, flaring is limited to no greater than 900 m3/day per site. Any flare gas above that limit
must be incinerated or conserved.
○ Requirements that are already exist in other instruments have either been removed
(sections 3.9, 6.4, and 9.1) or altered to point to the source document (section 2.13.1).
○ Parts of section 7.12.5 were changed to eliminate outdated exceptions.

1.3 Flaring, Incineration, and Venting Management Hierarchy and Framework

- In accordance with the objective hierarchy, licensees, operators, and approval holders must
evaluate the following three options:
• Can flaring, incineration, and venting be eliminated?
• Can flaring, incineration, and venting be reduced?
• Will flaring, incineration, and venting meet performance standards?

2 Solution Gas Management (Crude Oil / Bitumen Battery Flaring, Incineration, and Venting)
- The AER’s goal is to have the upstream petroleum industry continue to reduce the volume of
solution gas routinely flared, incinerated, and vented. The AER expects that the upstream
petroleum industry will pursue continuous improvement in reducing solution gas flaring,
incineration, and venting in Alberta, and, in consultation with stakeholders, will monitor progress
to determine the need for additional requirements to facilitate increased solution gas
conservation.
- Combustion of solution gas in incinerators is not considered an alternative to conservation.
- For solution gas management and disposition reporting, incinerated gas must be reported as
flared.
- Conservation is defined as the recovery of solution gas for use as fuel for production facilities, for
other useful purposes (e.g., power generation), for sale, or for beneficial injection into an oil or gas
pool (e.g., pressure maintenance, enhanced oil recovery). Conservation opportunities are
evaluated as economic or uneconomic based on the criteria listed in section 2.9.
- In this section, for the “combined flared and vented volumes” the vented volumes must not
exceed the vent gas limits in section 8.

2.2 Solution Gas Venting Reductio

- The AER does not consider venting an acceptable alternative to flaring. If venting is the only
feasible alternative, the requirements in section 8 must be met.
- In 2005, 59 per cent less solution gas was vented than in 2000. The CASA Flaring and Venting
Project Team considered solution gas venting in the report, Gas Flaring and Venting in Alberta:
Report and Recommendations for the Upstream Petroleum Industry by the Flaring/Venting
Project Alberta Energy Regulator 12 Directive 060: Upstream Petroleum Industry Flaring,
Incinerating, and Venting (July 2020) Team, which it released in 2004. 2 The AER accepts these
recommendations and has incorporated them into Directive 060.

2.3 Solution Gas Flaring and Venting Decision Tree

- The AER adopted the solution gas flaring/venting management framework (figure 1) and endorses
the solution gas flaring and venting decision tree process (figure 2) as recommended by CASA. The

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 the solution gas flaring and venting decision tree process (figure 2) as recommended by CASA. The
licensee or operator must apply this decision tree to combined flaring and venting of more than
900 m3 /day and be able to demonstrate how each element of the decision tree was considered
and, where appropriate, implemented.

2.6 General Conservation Requirements at all Condensate Producing Sites and Crude Oil and Crude
Bitumen Batteries
- These requirements apply to all condensate producing sites and crude oil and crude bitumen
batteries unless otherwise specified.
○ 1) The licensee or operator must conserve gas at all sites3 where
 a) the combined volume of flare gas and vent gas is greater than 900 m3 /day per
site and the decision-tree process and economic evaluation (see section 2.9) result in
a net present value (NPV) greater than –Cdn$55 000;
 b) the gas:oil ratio (GOR) is greater than 3000 m3 /m3 . All wells producing with a GOR
greater than 3000 m3 /m3 at any time during the life of the well must be shut in until
the gas is conserved;
 c) the AER directs the licensee, operator, or approval holder to conserve flare gas and
vent gas, regardless of economics.
○ 2) Conserving facilities within 500 m of a residence with first gas disposition before January
1, 2020, must continue conservation if gas production volumes are greater than 900 m3
/day, regardless of economics. After January 1 2020, where unconserved gas volumes
greater than 900 m3 /day are combusted within 500 m of a residence, licensees or
operators must use an incinerator (a flare is not permitted within 500 m of a residence).
○ 3) For any site that has with a combined volume of flare gas and vent gas greater than 900
m3 /day and is not conserving, an economic evaluation must be completed every 12 months
using the criteria in section 2.9.
○ 4) On a case-by-case basis, the AER may still require an economic evaluation for any site that
is not conserving and has a combined volume of flare gas and vent gas less than 900 m3
/day if we believe that conservation may be feasible.
○ 5) Conserving facilities must be designed for 95 per cent conservation with a minimum
operating level of 90 per cent.
○ 6) The licensee or operator may apply to discontinue conservation if annual operating
expenses exceed annual revenue. See section 2.6(7).
○ 7) The licensee or operator must get approval from the AER to discontinue conservation
once it has been implemented at any facility, and must
 a) complete a decision tree to evaluate alternatives to discontinuing conservation,
 b) provide information on actual annual operating expenses and revenues,
 c) notify the appropriate AER field centre and residents within 500 m of its intention
to discontinue conservation and initiate flaring or venting at a site, and
 d) if conservation facilities are not operational, comply with table 1 until such time as
approval from the AER to discontinue conservation is granted.

4 Gas Battery, Dehydrator, and Compressor Station Flaring, Incinerating, and Venting
- This section addresses gas battery, dehydrator, and compressor station flaring, incinerating, and
venting and includes
○ routine flaring and incineration, and
○ nonroutine flaring, incineration, and venting for equipment depressurization for
maintenance; process upsets; and emergency depressurizing for safety reasons.
- 4.1 Gas Battery, Dehydrator, and Compressor Station Flaring, Incinerating, and Venting Decision
Tree
1) The licensee or operator must use the decision tree analysis shown in figure 5 to evaluate all
new and existing gas battery, dehydrator, and compressor station flares, incinerators, and
vents regardless of volume except for intermittent small sources (less than 100 m3 per
month) such as pig trap depressurizing

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month) such as pig trap depressurizing

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Notes (may 12, 2020)
Tuesday, February 9, 2021 11:14 PM

Section 1.1
- The current standards are stated as "maximum uncertainty of monthly volume" and/or "single
point measurement uncertainty"
- The uncertainties are to be applied as "plus/minus"
- Measurement at delivery/sales points must meet the highest accuracy standards as they have a
direct impact on royalty determination
Section 1.2
- The AER used the uncertainty levels contained in this section to develop many of its requirements
for equipment and/or procedures relating to measurements, accounting, and reporting for various
other aspects of oil and gas production and processing operations, which are explained in further
detail in other sections.
- If those requirements are being met, the AER considers a licensee to be in compliance without
the need to demonstrate compliance with the applicable uncertainty requirements contained in
this section. In other words, licensees need not have any concern about the stated uncertainty
limits for operations that meet minimum requirements, exception requirements, or specific AER
approval requirements as set out in this directive. AER inspectors and auditors do not look for
compliance with the stated uncertainty limits in conducting inspections and audits.
- In some cases a licensee may wish to deviate from the minimum requirements for equipment
and/or procedures that are stated in this directive. That may be acceptable if it is in accordance
with the following:
○ …
1.7.2 Gas Systems
i. Gas Deliveries (sales gas)
a. Single point measurement uncertainty = 2.0 %
ii. Hydrocarbon liquid deliveries
a. Delivery point measures > 100 m3 /d = 0.5%
b. Delivery point measures ≤ 100 m3 /d = 1.0%
iii. Plant inlet or total battery/group gas
a. Maximum uncertainty of monthly volume = 5.0%
b. Single point measurement uncertainty = 3.0%
iv. Plant inlet or total battery/group condensate (recombined)
a. Single point measurement uncertainty = 2.0%
v. Fuel gas
a. Single point measurement uncertainty:
i. > 0.50 103 m3 /d = 3.0%
ii. ≤ 0.50 103 m3 /d = 10.0%
b. Maximum uncertainty of monthly volume (M):
i. > 0.50 103 m3 /d = 5.0%
ii. ≤ 0.50 103 m3 /d = 20.0%
c. For all upstream oil and gas facilities such as well sites, gas plants, batteries, and compressor
sites, operators may estimate fuel gas use volumes for sites with an annual average fuel
gas use of 0.50 103 m3 /d or less. Therefore, the maximum uncertainty of the monthly
volume is set at 20.0 per cent. For any site that was constructed after May 7, 2007, and that
was designed for annual average fuel gas use exceeding 0.50 103 m3 /d or for any site
where annual average fuel gas use exceeds 0.50 103 m3 /d, fuel gas must be metered and
the maximum uncertainty of the monthly volume is set at 5.0 per cent. For information on
metering and reporting fuel usage at sites with more than one reporting facility, see section
4.2.2.
d. Gas used for pneumatic devices must be reported as fuel gas

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 d. Gas used for pneumatic devices must be reported as fuel gas
i. Effective January 1, 2020, gas used for pneumatic devices that is vented or flared must
be reported as vented or flared, respectively. For facilities with first production
before January 1, 2022, the volume of gas emitted by pneumatic devices may be
estimated and then subtracted from the metered fuel gas volume in the case where
the metered fuel gas provides the pneumatic gas supply.
e. Pilot, purge, sweep, blanket, and makeup gas consumption must be reported as fuel gas.
i. Effective January 1, 2020, gas used for pilot, purge, sweep, blanket and makeup gas
must be reported as flared. For facilities with first production before January 1, 2022,
the volume of gas used as pilot, purge, sweep, blanket, and makeup gas may be
estimated and then subtracted from metered fuel gas in the case where metered fuel
gas also provides the pilot, purge, sweep, blanket, and makeup gas supply. The
volume that is subtracted from fuel gas does not contribute to the allowance of 0.50
103 m3 /d that may be estimated for flare gas.
f. The equipment and/or procedures used to determine the measured gas volumes (if
measurement is required) must be capable of meeting a 3.0 per cent single point
measurement uncertainty. Due to the difficulty associated with measuring very low gas
rates, the equipment and/or procedures used in determining GORs or other factors to be
used in estimating gas volumes if rates do not exceed 0.50 103 m3 /d are expected to be
capable of meeting a 10.0 per cent single point measurement uncertainty.
vi. Flare and vent gas
a. Maximum uncertainty of monthly volume = 20.0%
b. Single point measurement uncertainty = 5.0%
c. Flare gas may be clean processed gas or it may be unprocessed gas, depending on the point
in the system from which gas is being flared. Continuous and intermittent flared and vented
volumes at all oil or gas production or processing facilities (including thermal in situ facilities,
but see section 12.2.2 for cold heavy oil and crude bitumen requirements) where annual
average total flared and vented volumes per facility exceed 0.5 103 m3 /d (excluding pilot,
purge, or dilution gas) must be metered.
d. Pilot, purge, sweep, blanket, and makeup gas consumption must be reported as fuel gas.
e. Effective January 1, 2020, gas used for pilot, purge, sweep, blanket, and makeup gas must
be reported as flared. For facilities with first production before January 1, 2022, the volume
of gas used as pilot, purge, sweep, blanket, and makeup gas may be estimated and then
subtracted from metered fuel gas in the case where metered fuel gas also provides the pilot,
purge, sweep, and blanket gas supply. The volume that is subtracted from fuel gas does not
contribute to the allowance of 0.50 103 m3 /d that may be estimated for flare gas.
f. Effective January 1, 2020, uncombusted gas released to the atmosphere that is not fugitive
emissions must be reported as vent gas.
g. Sites requiring flare/vent gas metering may estimate up to 0.50 103 m3 /d. Flare lines
usually operate in a shut-in condition and may be required to accommodate partial or full
volumes of gas production during flaring conditions. In some cases if flaring is infrequent
and no measurement equipment is in place, flare volumes must be estimated (such as
flaring at southeastern Alberta gas wells in a proration battery where there is no on-site
measurement equipment). Therefore, the maximum uncertainty of the monthly volume is
set at 20.0 per cent, to allow for the erratic conditions associated with flare measurement.
4.1 General requirements (for gas measurement)
- Monthly gas volumes must be reported in Petrinex in units of 103 m3 and rounded to one
decimal place as per Directive 007.
- Annual methane emission reports must be reported to the AER and include kg of methane
(CH4) and m3 of gross gas volume as per Directive 060.
- Standard or base conditions for use in calculating and reporting gas volumes are 101.325
kPa(absolute) and 15o C.

4.2.2 Gas Batteries/Facilities

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 4.2.2 Gas Batteries/Facilities
- All wells in a multiwell battery must be subject to the same type of measurement. If there
are mixtures of measured and prorated wells (mixed measurement) within the same
battery, AER exception criteria in section 5, “Site-specific Deviation from Base
Requirements,” under “Measurement by Difference” must be met, or AER site-specific
approval must be obtained, and the measured wells must have their own separate battery
code(s) to deliver gas into the proration battery. Conversely, wells with no phase-separated
measurement, including effluent wells, are not allowed to tie into a multiwell group battery
unless there is a group measurement point before the tie-in
4.3.7 Vent Gas Measurement Requirements
- Compressor seal vent gas must be tested according to Directive 060.
- Other vent gas sources may be estimated. See Manual 015: Estimating Methane Emissions for
guidance.

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Thursday, August 19, 2021 5:39 AM

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Developing and Maintaining an Effective FFV inventory
Tuesday, September 14, 2021 2:18 PM

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Some D017 tips
Wednesday, September 15, 2021 2:08 PM

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Measurement by difference
Wednesday, September 15, 2021 2:11 PM

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Measurement Uncertainty
Wednesday, September 15, 2021 2:15 PM

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Measurement schematics
Wednesday, September 15, 2021 2:21 PM

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