Oct 27, 2021 News
…in the absence of national flaring standards
Kaieteur News – In light of the fact that Guyana has no standards for flaring to govern the oil and gas sector, ExxonMobil’s subsidiary, Esso Exploration and Production Guyana Limited (EEPGL) will be following its own rules for the Yellowtail Project.
Expounding on this front in its Environmental Impact Assessment (EIA) for the project, the subsidiary said it “considered” World Bank standards as well as the internal ExxonMobil environmental standards “as references.”
EEPGL was keen to note that the World Bank has established guidelines for offshore oil and gas development, which serve as “a technical reference document” with examples of good environmental practices. It said the offshore oil and gas development guideline states that new facilities should be designed, constructed, and operated, so as to avoid routine flaring of associated gas.
The guideline also stated that methods to control and reduce fugitive emissions should be considered and implemented in the design, operation, and maintenance of offshore facilities and LDAR (Leak, Detection and Repair) programmes should be implemented.
Furthermore, EEPGL said its parent company’s internal environmental standards establish a design approach to reduce flaring emissions, which provides guidance that facilities should be designed to avoid routine flaring of associated gas, and include an evaluation of the most advantageous use of alternatives for managing associated gas that would otherwise be flared.
EEPGL noted as well some of the provisions related to flaring in the Payara Environmental Permit, as issued by the Environmental Protection Agency (EPA) in 2020. Some of the provisions state that EEPGL must ensure all reasonable attempts are made to implement appropriate methods for controlling and reducing fugitive emissions in the design, operation, and maintenance of offshore facilities and to maximize energy efficiency and design facilities for lowest energy use, with the overall objective to reduce air emissions; operate all mechanical equipment in accordance with the manufacturer’s specifications; and note that routine flaring and venting is strictly prohibited (excludes tank flashing emissions, standing/working/breathing losses, low pressure streams) during any developmental drilling or production activities without EPA approval.
The permit also states that flaring is only permissible under the following conditions: Commissioning, Start-up, or Special Circumstances [these are further defined in the Permit].
It notes too that EEPGL must ensure associated gas brought to the surface with crude oil during oil production is re-injected into the reservoir, and used as fuel gas on the FPSO. However, all feasible alternatives for gas use must be evaluated and adequately documented to the EPA upon request.
The permit also calls for EEPGL to adopt risk management processes (e.g., hazard and operability study, hazard identification study, etc.) to assess risks associated with process upset and loss-of-containment events, which could impact the environment. It is also required to employ all reasonable efforts to prevent equipment breakdowns and plant upsets that could result in flaring, and provisions must be made for equipment sparing and plant turn-down protocols.
With the foregoing outlined, EEPGL said it has elected to follow a blend of the World Bank offshore oil and gas development guidelines (World Bank 2015), its internal environmental standards, and the conditions in the Payara Environmental Permit” for the design of the systems for flaring.
EEPGL was keen to note that the Flash Gas Compression system will be designed to minimize flaring of hydrocarbon gases from low-pressure systems during normal operations. It said low-pressure flash gas may be flared temporarily when a Flash Gas Compressor is down due to upset or maintenance. Kaieteur News understands that the installed spare compressors will be included to reduce flaring duration in these instances.
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