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AOGCC to review gas flaring regs Agency has RFP out for process engineering assistance to do scoping to identify issues to be addressed in regulation rewrite Kristen Nelson Petroleum News
The Alaska Oil and Gas Conservation Commission is beginning work on revising its regulations on gas disposition — how oil and gas field operators account for and report natural gas which is flared or vented or used in pilot lights and other field uses, and when such gas use is waste.
The commission has a request out for proposals, looking for “engineers who have extensive experience in large-scale natural gas production processing design and operation to assist in examining gas disposition” including field use, flaring or venting and pilot or purge gas.
The estimated $30,000 project will produce a scoping study which the commission will use to “plan and seek more detailed engineering contract support for AOGCC’s rewrite of gas disposition regulations.”
“We expect this scoping study to lead to and help us prepare for a significant revision of our gas disposition regulatory procedures,” AOGCC Commissioner Cathy Foerster told Petroleum News in an e-mail.
Travel to Cook Inlet platforms, Kenai Peninsula onshore facilities and the North Slope “may be necessary to assess the current flaring practices and equipment unique to each location and to fully understand the variations involved in gas handling throughout the state,” the RFP said.
Tied to prevention of waste The commission’s regulation of gas disposition is part of its mandate to prevent physical waste of oil and gas.
“In accordance with this mandate,” the commission said in its RFP, “the AOGCC seeks to evaluate and assess current gas disposition practices specific to flaring, venting, pilot-purge and lease uses throughout Alaska hydrocarbon fields.”
The commission last assessed gas disposition practices in 1995 and did “an extensive rewrite of the procedures and decision criteria used for gas disposition decisions,” it said.
The commission said current trends in the volume of gas used in field production activities warrants “a thorough review of the equipment volumes of consumed gas associated with particular operations, and what triggers reporting of gas disposition to the AOGCC.”
The commission said its current regulations for reporting of gas consumed in the field “are too interpretive, based on out of date operator field management practices, and based on criteria driven by equipment, operational, and environmental considerations known to the operator but not always understood by the regulating agency.”
Another factor in the commission’s desire to study gas disposition practices is an increase in inconsistencies in what triggers gas disposition reporting.
Timing factor in reporting Currently the commission looks at gas volumes that are flared or vented in events lasting more than an hour, and looks at trends in events that last less than an hour. Pilot-purge gas is reviewed based on historical trends, but “without any baseline to assess what is necessary for facility operation.”
The commission said there is no engineering review by its personnel of the systems in use, “essentially forcing gas disposition decisions to be made based on historical trends and without any way to validate the actual flaring/venting needs for an efficiently running production processing system.”
It cannot currently “determine what constitutes an acceptable volume of gas released (flared or vented), what volume of gas is necessary for the efficient operation of the flare system, and what is necessary for proper lease use.”
What the commission wants from this contract is “a scoping study of natural gas disposition practices and their regulation.”
It said the goal is “to outline a detailed plan for evaluating and potentially revising the AOGCC’s gas disposition regulations.”
Equipment capabilities to be studied The commission said the evaluation “will include identification of equipment and equipment capabilities involved, delineation of reasons for flaring and venting, and the assessment of operational considerations, such as leak detection, process safety valve performance, measurement of gas diverted to flare, etc., that are integral to the gas disposition decisions.”
It expects the scoping report to include an assessment of the effectiveness of gas disposition practices used by operating companies.
The commission said it expects the contract to be awarded in March and to be completed by the end of August.
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