The Liza-1 Environmental Permit does not include the 14 billion cubic feet flaring allowance that government says ExxonMobil has used to justify its emissions but makes it clear to the company that there should not be routine flaring and that there should be provision for spares and plant-turn down protocols if there are breakdowns on its production platform (FPSO).
“In the event of an emergency or equipment breakdown on the FPSO, or when facility upset conditions arise, excess gas should not be vented but rather should be sent to an efficient flare gas system. Efforts should be made to prevent equipment breakdowns and plant upsets which could result in flaring and provisions should be made for equipment sparing and plant turn-down protocols where practical,” the Liza-1 Environmental Permit states, under Section 3 which deals with air quality.
Further, it adds, “FPSO flaring volumes for the initial commissioning/startup period and for steady state production operations of Liza Phase 1 should be estimated so that appropriate flaring targets can be developed. The volumes of gas flared for all FPSO flaring events should be recorded and reported.
With flaring offshore estimated to reach 14 billion cubic feet (cu ft.) of gas by the time Exxon-Mobil expects the problem with its compressor to be resolved – hopefully in April of this year – government on Tuesday said that it is “hamstrung” in instituting penalties since the company has argued that it is within the limit allowed by the Environmental Protection Agency (EPA).
“Exxon is flaring, using about 16 million to 18 million cubic feet of gas per day. The EPA has worked this out and has said that is about 1.3 kilotonnes of carbon emitted. Most people didn’t understand [that] Exxon submitted an Environmental Impact Assessment for the project,” Vice President Bharrat Jagdeo told a Tuesday press conference that was hosted at the Arthur Chung Conference Centre. He also stressed that the level of flaring was “unacceptable”.
“The document was, from what I gather, made public by the EPA that the EIA, which was approved by the EPA at that time and referred to by the Minister in the licence, Exxon was given an allowance to flare or to use 14 billion cubic feet of gas. Fourteen billion! Right now, they have flared 12.5 billion cu ft. At the current rate of flaring, by the end of April, they would have flared the entire 14 billion cubic feet,” he added.
Jagdeo said that he has asked the EPA to undertake a detailed analysis of all the documents and he will also be doing so.
The Stabroek News’ analysis of the Liza-1 Permit sees no provision for a 14 billion cu ft. flaring allowance.
And while ExxonMobil has repeated that it “remains in compliance with all our environmental permits and regulatory requirements and we continue to work with the relevant government agencies to find the right balance for the country while constantly seeking to minimize flaring,” former Director of the EPA, Vincent Adams says the 14 billion allowance should not be referred to at all.
Dr Adams said that he is appalled that the company is disingenuously using the EIA figures as the operations limitations document, when in fact they fully well know that the Permit is the only document that defines the limits for operations.
In addition, Adams said that it was the very same EIA which evaluated the three alternatives for the gas disposal and concluded that flaring will only occur in routine operation, and only in such instances as maintenance, emergencies and startups; so if they claim to be following the EIA, why are they not following this specific guideline. This was the same guideline incorporated into the permit.
Given ExxonMobil’s figures that it is producing at its highest capacity of 120,000 bpd (barrels of oil per day), Adams reasoned that they would know that this has to be regarded as normal operations and cannot be counted as an emergency, maintenance, or startup.
This newspaper reached out to Acting Director of the EPA Sharifah Razack on the agency’s position but was told that she was in a meeting. An email was sent with questions on the issue but up to press time she had not responded. Over several months, Razack has not responded once to Stabroek News.
Practicable
As it pertains to emissions and flaring, the Permit says that the company has to annually quantify aggregate greenhouse gas (GHG) emissions from all facilities and offshore support activities which are directly owned or controlled by the Permit Holder or its dedicated contractors, in accordance with internationally recognised methodologies.
“Adopt measures as far as practicable in keeping with the Global Gas Flaring and Venting Reduction Partnership when considering venting and flaring options under emergency or upset conditions,” the document states, as it lists conditions that should be complied with when flaring from the FPSO is necessary, particularly under emergency and or upset conditions.
“Ensure flare equipment are properly inspected, well maintained, monitored, certified and function\tested, prior to and throughout operations. Ensure flare is installed a safe distance from storage tanks containing flammable liquids or vapours and accommodation units. Ensure that combustion equipment is designed and built to appropriate engineering codes and standards certified. Flare must not be operated outside design operating ranges. Use efficient flare tips and optimize the size and number of burning nozzles. Minimize risk of pilot blowout by ensuring sufficient exit velocity and providing wind guards. Ensure use of a reliable pilot ignition system,” it states.
“Install high-integrity instrument pressure protection systems, where appropriate, to reduce overpressure events and avoid or, reduce flaring situations. Operate flare to control odour and visible smoke emissions, where practicable. Ensure the volumes of hydrocarbons flared are recorded and submitted to the Agency annually. Implement burner maintenance and replacement programs to ensure continuous maximum flare efficiency. Maximize flare combustion efficiency by controlling and optimizing flare fuel, air, and stream flow rates to ensure the correct ratio of assist stream to flare stream. Minimize liquid carryover and entrainment in the gas flare stream with a suitable liquid separation system, with sufficient holding capacity for liquids that may accumulate and which must be designed in accordance with good engineering practice,” it adds.
Ensuring that there is a liquid separation system (e.g., knockout drum) equipped with high level facility shut down or high level alarms and emptied as needed to increase flare combustion efficiency, is also a requirement under the Permit.
Stated too is that the company has to “Implement source gas reduction measures [i.e., gas re-injection into reservoir] to the extent possible to avoid or reduce flaring from FPSO. Minimize flaring from purges and pilots without compromising safety through measures such as installation of purge gas reduction devices, vapor recovery units, inert purge gas, and softseat valve technology where appropriate, and installation of conservation pilots.”
The company has to also 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 maximise energy efficiency and design facilities for lowest energy use. “The overall objective is to reduce air emissions,” the document emphasises. “Cost-effective and technically feasible options for reducing emissions should be evaluated and adopted as far as practicable,” it says.
“Operate all mechanical equipment in accordance with the manufacturer’s specifications. Additionally, ensure that mechanical equipment, vehicles, vessels, and helicopters, utilized during Project works, are regularly maintained and operated at their optimal levels to minimize atmospheric emissions. Submit and comply with the Ship Energy Efficiency Management Plan (SEEMP) as required by IMO. Submissions will be part of the final vessel documentation provided two (2) months prior to initiation of operations. Utilize low Sulphur fuels for major vessels, where available and commercially viable.”
And as it pointed out that routine flaring does not include flaring related to FPSO startup and emergencies and maintenance events, it said that the company must adopt risk assessment processes. “For example hazard and operability routine flaring and venting are prohibited on the FPSO (excludes tank flashing emission, standing/working /breathing losses). Gas is to be re-injected into the reservoir or utilized as fuel gas on the FPSO during normal operations. However, all feasible alternatives for gas utilization should be evaluated and adequately documented.”
The EPA is to be notified within 24 hours after “process upset events or unplanned maintenance occur which result in a flaring event on the FPSO sustaining a volume of at least 10 MMSCFD and lasting 5 days or longer.”
Volumes from minor flaring events not requiring notification should be captured in aggregate in annual emissions reporting.
Government says that data on flaring will be provided by the Department of Energy.
