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AOGCC wraps petition on issue of non-emergency venting, flaring
Kristen Nelson Petroleum News
The Alaska Oil and Gas Conservation Commission has issued two documents stemming from an October petition by Kate Troll asking that the commission “prevent all non-emergency venting and flaring from Alaska oil and gas wells.” The petition was signed by 46 people.
In November Troll requested a hearing, which was held Dec. 18. At that hearing, Troll submitted another petition with the names of nearly 300 individuals, urging AOGCC to “fully enforce and strengthen existing statutes requiring Alaska’s oil and gas industry to stop all non-emergency venting and flaring from Alaska’s oil and gas wells.”
One of the two documents issued by the commission is a Jan. 18 order, signed by Commissioners Cathy Forester and Dan Seamount, which said that at the hearing Troll and other witnesses asked a number of questions about the commission’s practices relating to enforcing its venting and flaring statutes and regulations.
“All witnesses were open about their root concern, the reason the hearing was requested, which is climate change,” the order says. “They acknowledged, and the AOGCC reiterated at the hearing, that while the AOGCC regulates to prevent waste, it has no authority to act regarding that subject matter.”
In the findings in that order the commissioners said that there was no specific example or claim of waste raised at the hearing.
“Both the testimony and the questions raised during the hearing appeared to stem from a general lack of familiarity with how the AOGCC addresses issues related to venting and flaring,” the order said, and noted that the appropriate way to obtain information would be to schedule a meeting with AOGCC’s technical staff, and said that if any of the hearing participants desired, “AOGCC staff is willing to meet the answer their questions.”
Separate statement The second document was a statement by Commissioner Hollis French, the commission’s chair, who did not sign the commission’s order. He said while his statement wasn’t a quorum order of the commission (that would require agreement of two of the three commissioners) it did provide answers to questions submitted at the hearing.
French said that a review of available information on flaring shows “the Alaska oil and gas industry is, with the watchful eyes of AOGCC upon it, performing well or better than any other jurisdiction in the United States when it comes to conserving the state’s valuable resources.”
He also said there is room for improvement in how the agency handles venting and flaring information.
French also said, “it is perfectly appropriate for citizens to ask questions of their public servants, and it is not unreasonable for them to expect answers.”
Questions answered French provided answers to questions raised at the hearing.
He said vented and flared gas is held to about 0.2 percent of the total gas produced in Alaska - for fiscal year 18 it was 0.23 percent, for FY 17, 0.2 percent - compared to Texas, which flared about 1 percent of its gas in 2016 and North Dakota, which flared 20 percent of its gas in October 2018.
In response to a query based on the assumption that more methane would be flared on the North Slope as temperatures rise, French said: “Daily temperature swings can create flaring events when the facilities’ compressors ‘bog down’ in the higher temperatures and internal pressures rise. The vast majority of these temperature swings do not produce any flaring events, however, due to the alertness of the operators who can reduce the flow into the plant from high gas content wells.”
He said the commission meets with operators “when their flaring practices warrant extra attention,” but said AOGCC has not conducted a workshop with industry on the issue, “although the hearing held on this petition was an opportunity for industry to hear from concerned citizens.”
French said the commission has devoted resources to enforcement, with efforts beginning in the 1970s “when AOGCC took action to end wasteful flaring practices in Cook Inlet.” He said the agency’s files contain “voluminous records” on venting and flaring enforcements.
“Recently, citizen complaints about flaring on the Kenai Peninsula resulted in a day long visit from one of the agency’s field inspectors to a land-based production facility,” he said.
Flared or vented gas is reported to AOGCC on Form 10-422, French said, accessible from the agency’s website (http://doa.alaska.gov/ogc/) by selecting the data tab, and then data list from the drop-down menu. Then select data extract, which produces two files, a small one with a descriptive key, and a 25-megabyte file, with a list of tables on the left side. The table “tblFacDisp_Alt” is a link to monthly data extracted from Form 10-422 back to 1995, he said, adding that a recommended reform would be to make completed Form 10-422s available directly from the agency’s website.
One question related to how the commission feeds data into the state calculation of greenhouse gas emissions.
“It does not appear that AOGCC has a responsibility to report emissions to the EPA under the greenhouse gas reporting rule,” French said. Quoting the Environmental Protection Agency, he said emitters of emissions are responsible.
Thirty-five flaring events were cited by petitioners who wanted to know if those emissions fell under authorized emergency and normal operations and asked what AOGCC was doing to analyze Form 10-422s and determine if there should be enforceable actions.
“Each Form 10-422 and any supporting documentation submitted along with it is reviewed by members of the agency’s professional engineering staff and a commissioner to determine how to classify the flared or vented gas” under agency regulations, French said, and suggested that Form 10-422 be modified “to accommodate two commissioner signatures to ensure each determination of how to classify flaring events exceeding one hour is a quorum decision by the AOGCC.”
Asked if AOGCC spot checks reports to see if claims for exemptions are legitimate, he said, each form is reviewed. “Staff gathers data, including the volumes of gas involved and an explanation from the facility regarding the cause of the flaring event.”
Asked about enforcement actions for waste gas over the past 10 years, French cited two: An enforcement action against Cook Inlet Energy for failure to shut-in a well at Redoubt when the Kustatan Production Facility was undergoing a major overhaul in late 2013 and early 2014, with 24,668 mcf (thousand cubic feet) of natural gas flared.
The commission initially imposed a $294,834 civil penalty on Cook Inlet Energy, but finally settled on requiring corrective actions so such flaring would not recur (see Other Order No. 100).
The other was an enforcement action involving BlueCrest Alaska Operating which was flaring as a result of starting up production processing equipment in 2016. After a “full-day visit to the facility from one of the agency’s field inspectors,” with the inspector conducting tests on the facility’s measurement devices to make sure gas flowing to the flare was measured accurately, the commission notified BlueCrest that it would “not initiate enforcement proceedings for amounts flared in April and May 2016. However, two months is more than sufficient to conclude commissioning efforts.”
Beyond the 10-year period, French said, there were enforcement actions for flared gas in 2004 and 2006, both resulting in the imposition of fines.
- KRISTEN NELSON
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