GUIDANCE NOTE

Monitoring and Reporting of Flare Emissions

under the EU ETS II (UK Offshore Oil & Gas)

www.tuvnel.com

Monitoring and Reporting of Flare Emissions

under the EU ETS II (UK Offshore Oil & Gas)

Introduction
This guidance note has been prepared to assist industry in the
monitoring and reporting of flare emissions for the purpose of
complying with Phase II of the EU Emissions Trading Scheme
(ETS). It summarises the key findings of TUV NEL research report
2008/162(1).

Measurement Based Methodology: Based on Continuous

Emissions Measurement Systems (CEMS). These systems are
deemed inappropriate for measuring emissions from flares (Ref 1).
Calculation Based Method: Employed by all UK offshore
installations for determining flare emissions, this method involves a
combination of direct and indirect measurement and factors. The
approach uses 3 variables and the following equation to calculate
the total emissions from an installation:
CO2 Emissions = Activity Data * Emission Factor *
Oxidation Factor

Background
The EU ETS (EU Directive 2003/87/EC2) is the main environmental
legislation controlling emissions from offshore flares. The
guidelines for monitoring and reporting these emissions are set out
under Commission Decision of 18/VII/20073, otherwise referred to
as MRG2007. These guidelines are a revision of the guidelines used
during Phase 1 of the EU ETS.
The EU ETS provides a carbon dioxide (CO2) emissions trading
scheme for Europe. The main aim of the scheme is to assist
member states in achieving the targets set out under the Kyoto
Protocol. Phase 1, treated as a learning period, ran from 1 Jan
2005 until 31 Dec 2007. The current phase, Phase 2, was timed
to coincide with the Kyoto Protocol commitment period; this
commenced on 1 Jan 2008 and will run until 31 Dec 2012. Phase
3 is presently in the final planning stages and will follow Phase 2.
Offshore flaring was exempt from Phase 1 of the EU ETS due to
the perceived difficulties in achieving the associated measurement
targets. Although the monitoring and reporting guidelines have
been revised under Phase 2 to reflect some of these difficulties,
the unique conditions experienced offshore mean that the oil and
gas industry still face serious challenges in meeting the current
measurement requirements and targets in MRG2007.

Summary of EU ETS Monitoring &

Reporting Requirements
Methodology Options: MRG2007 permits the use of a
measurement based method, calculation based method or a
combination of both methods to determine emissions from flares.

(1)

Activity data: measurement of the gas flared.

Emission Factor: measurement of the carbon content of the
flare gas.
Oxidation Factor: proportion of carbon oxidised to form CO2.

The calculation based methodology utilises a tiered approach

system for each of the above variables. The highest tier (Tier
3) requires more comprehensive and accurate monitoring and
reporting. Although all operators are required to meet the highest
tier, minimum targets have been established for each installation
category.
Three installation categories have been set based upon the amount
of emission allowances awarded to a particular installation by
the UK government under the UK National Allocation Plan (NAP),
and as documented in the installations EU ETS permit. The three
installation categories are:
Installation categories

Amount of CO2 emissions

50

50 to

> 500

emitted per annum (k tonnes)

500

The total emission allowances outlined above include all reportable

combustion CO2 emissions on the installation (i.e. flare emissions
and fuel emissions). It should be noted that the majority of UK
offshore installations are currently Category B.
It is the responsibility of each member state to implement the
requirements of MRG2007 at the highest level and, where
this cannot be achieved for justifiable reasons, ensure that
improvement plans have been put in place by the operator. The UK
regulator for the offshore sector is
the Department of Energy and Climate Change (DECC) (formerly
BERR, formerly DTI). In recognition of the current difficulties
associated with determining emissions from flares DECC has
allowed, where appropriate, lower interim requirements.

September 2008

Activity Data Tiers The tier level assigned to activity data sets
the maximum permitted measurement uncertainty on the annual
quantity of gas flared (Nm3). A minimum reporting tier has been
set for each installation category (covering major source streams).
The specified tier requirements are outlined below in Table 1.
Table 1 - Activity Data Measurement Uncertainty Targets
Tier 1
Tier 2
Tier 3

Minimum tier for each installation category

(for major source streams)

17.5%

A = Tier 1, B = Tier 2, C = Tier 3

12.5%

7.5%

UK Regulator Expectations (BERR EU ETS 2 Guideline4)

For all offshore installations, a Tier 1 target has been set for
2008 with a Tier 2 target to be met by the end of 2009.
To date many operators have been unable to meet Tier 1 and
have requested a no-tier for 2008, with improvement plans.
Emission Factor Tiers The tier levels describe the process
required for determining the emission factor.
Table 2 - Emission Factor Tiers
Tier 1
Tier 2a
Tier 2b
Tier 3

Minimum tier for

each installation
category

Reference
UNFCCC
Installation-
Activity-
A = Tier 1
E.F. of
country
specific EF
specific
0.00393 t
specific EF
derived from EF applying
B = Tier 2 a/b
CO2/m3
estimating
MRG Section

molecular
13, Annex 1
C = Tier 3
Using
weight of
ethane as a
the flare gas
(for major
conservative
stream using
source streams)
flare gas
process

proxy
modelling

category

UK Regulator Expectations (BERR EU ETS 2 Guideline)

BERR has set a Tier 2b target for the offshore sector, whereby
using process modelling to estimate the gas composition of

General Requirements: MRG2007 requires all measurement

equipment and tools to be appropriately applied, maintained,
calibrated and checked. Operators are also required to submit
written proof of the measurement uncertainty levels reported for
activity data and to take into account the cumulative effects from
all components in the measurement system using the error
propagation law given in specified standards. These include ISO/
TAG 45, ISO-5168:20056 and Annex1 of the Revised 1996 IPCC
Guidelines7.

Key Findings of TUV NEL Report 2008/162

Activity Data
In order to meet the highest measurement uncertainty targets
operators may be required to use a combination of methods to
determine the amount of gas flared. Some limitations of applying
a single method are listed below;

By-difference calculations may prove extremely inaccurate

when the amount of gas flared is low compared to the other
measured gas streams. Measurement uncertainty can be in
excess of 100%. Conversely, measurement uncertainty can be
relatively small when the amount of gas flared is high
compared with the other measured gas streams.
Flare gas meters may prove inaccurate in the upper and lower
operating ranges.
Limited redundancy in the monitoring system should one
method fail (i.e. failure of flow meter).

Ultrasonic time-of-flight meters are currently the state-of-the-art in

flare gas metering technology and used widely for both offshore
and onshore applications. Other metering technologies may be
suitable for given applications.

the flare gas stream.

Emission Factor
Oxidation Tiers Tier 1 uses a factor of 1.0 which assumes a fully
efficient combustion process with complete oxidation of carbon
to form CO2. Tier 2 involves the use of a country-specific factor as
reported by the UK in its latest UNFCCC inventory report.
Table 3 - Oxidation Factor Tiers
Tier 1
Tier 2


Factor
1.0

Minimum tier for each

installation category (for
major source streams)

UNFCCC
A, B & C = Tier 1
country
specific factor

UK Regulator Expectations (BERR EU ETS 2 Guideline)

BERR has assigned the offshore sector a Tier 2 target for
flaring activities.

It is recognised that there are serious difficulties in determining

gas composition of the gas flared using direct means. These
include but are not limited to; accessing the flare, scheduling,
personnel health and safety, production interruptions, suitability
of sampling equipment for offshore environments (see TUV NEL
report 2008/162). For these reasons process modelling is generally
accepted as the only practicable method for determining gas
composition and emission factors.
Process modelling tools used for determining gas composition and
emission factors should be verified and demonstrated to be accurate
and suitable for modelling such gas compositions.
Where ultrasonic time-of-flight meters are in use, consideration
should be given to utilising the speed of sound feature to derive
average molecular weight of the gas stream in order to assist other
methods in estimating gas composition and emission factors.

Monitoring and Reporting of Flare Emissions

under the EU ETS II (UK Offshore Oil & Gas)

Calibration and Verification

In the absence of flare gas meter laboratory calibrations, which
are generally impracticable and ineffective at matching true flare
operating conditions and installation effects, it is recommended
that operators undertake in-situ calibration of flow meters. This
can involve the use of tracers and meters which feature other
methods for performing calibrations and checks (all methods
subject to agreement with regulator).
All instruments and monitoring equipment should be subject to
periodic checks. Self-checking functions may also be available with
some meters to allow checking of algorithms and electronics.
Secondary instruments, such as pressure and temperature
transducers should be calibrated to national standards.
Meter verification should be undertaken post installation to ensure
that meters are installed in accordance with the manufacturers
instructions and to obtain other relevant pipe data information.

Standards and Guidelines

Although the EU ETS specify the use of recommendations and
guidelines, there is a current lack of recognised standards and
guidelines that specifically address flaring. It is recommended
that operators refer to HM58 Energy Institution Guidelines8. This
document is at present the most comprehensive document for
undertaking emissions monitoring of offshore flares.
A number of other standards exist which may assist industry in
conducting measurement uncertainty calculations and gas sampling.
These are listed in Appendix 1 of TUV NEL Report 2008/1621.

References

Directive 2003/87/EC of the European Parliament and of

the Council of 13 October 2003 establishing a scheme for
greenhouse gas emission allowance trading within the
Community and amending Council Directive 96/61/EC.

Commission Decision of 18/VII/2007 - establishing guidelines

for the monitoring and reporting of greenhouse gas emissions
pursuant to Directive 2003/87/EC of the European Parliament
and of the Council.

EU Emissions Trading Scheme Guidance to Operators on the

requirements for installations to achieve the highest applicable
monitoring tiers (as defined within Commission Decision of 18
July 2007 establishing guidelines for the monitoring and
reporting of greenhouse gas emissions known as MRG2)
Guidance to Operators of Offshore Installations (Incorporating
Frequently Asked Questions) Final Version -September 2007.

Guide to the Expression of Uncertainty in Measurement,

ISO/TAG 4 - Published by the International Standardisation
Organisation (ISO), Geneva in 1993 (corrected and reprinted,
1995) in the name of the BIPM, IEC, IFCC, ISO, IUPAC, IUPAP
and OIML.

6 ISO-5168:2005 Measurement of fluid flow procedures for

the evaluation of uncertainties. International Standardisation
Organisation (ISO), Geneva.
7 Revised 1996 IPCC Guidelines for National Greenhouse Gas
Inventories Annex 1, Managing Uncertainties.
8 Energy Institute Guidelines HM 58 Guidelines for the
determination of flare quantities from upstream oil and gas
facilities (May 2008).

1 TUV NEL Report No: 2008/162, July 2008 - A study of flow

measurement issues relating to the determination of flare
emissions.

The purpose of this Guidance Note is to provide, in condensed

form, information on measurement methods and technologies.
It was produced as part of the UK Governments National
Measurement System.
For further information, contact:
TUV NEL, East Kilbride, GLASGOW, G75 0QF, UK
Tel: + 44 (0) 1355 220222

Email: info@tuvnel.com

www.tuvnel.com

TUV NEL Ltd 2010

Re-issued 2010
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