Flare & Vent Codes: Remarks and Authorizations

Flaring and venting of natural gas are heavily regulated activities in Texas, requiring proper authorization, documentation, and reporting. Understanding when to use flare versus vent codes and how to properly document authorizations is crucial for PR Form compliance.

Flare vs. Vent: Understanding the Difference

The distinction between flaring and venting is fundamental to proper reporting and environmental compliance.

When Flaring is Permitted

The RRC allows flaring under specific circumstances, but proper authorization is always required.

Acceptable Flaring Scenarios:

• Initial Production Testing: Well testing and completion operations
• Equipment Maintenance: Planned maintenance requiring gas disposal
• Pipeline Constraints: Temporary lack of pipeline capacity
• Processing Plant Outages: When processing facilities are unavailable
• Safety Operations: Emergency pressure relief situations
• Startup Operations: Initial facility commissioning

Flaring Authorization Types:

When Venting is Allowed

Venting is strictly limited to emergency situations where flaring is not possible or safe.

Acceptable Venting Scenarios:

• Emergency Safety: Immediate pressure relief to prevent equipment damage
• Flare System Failure: When flare equipment is inoperable
• Fire Prevention: When ignition sources create safety hazards
• Equipment Malfunction: Temporary venting during emergency repairs

Venting Reporting Requirements:

• Report venting incidents within 24 hours to RRC
• Document reason for venting vs. flaring
• Estimate volumes vented
• Describe corrective actions taken
• Include incident in next PR Form filing

PR Form Reporting Requirements

Proper documentation in PR Forms is essential for regulatory compliance and audit purposes.

Required Information for Flare Reporting:

• Disposition Code: Use code 03 for flared volumes
• Volume: Accurate measurement of flared gas
• Authorization Number: RRC permit or authorization number
• Remarks: Brief description of flaring reason
• Duration: Period during which flaring occurred

Required Information for Vent Reporting:

• Disposition Code: Use code 04 for vented volumes
• Volume: Estimated volume of vented gas
• Incident Number: RRC incident report number if applicable
• Remarks: Detailed explanation of emergency situation
• Corrective Action: Steps taken to prevent recurrence

Documentation Best Practices

Maintaining comprehensive documentation protects against regulatory scrutiny and supports compliance efforts.

Essential Documentation:

• Authorization Letters: Original RRC approval documents
• Application Forms: Copies of all submitted applications
• Volume Measurements: Daily flare/vent volume records
• Operational Logs: Detailed logs of flaring/venting activities
• Incident Reports: Documentation of emergency situations
• Corrective Actions: Records of improvements made

Record Keeping Requirements:

• Maintain records for minimum of 3 years
• Keep records readily accessible for RRC inspection
• Organize records by authorization period
• Include supporting calculations and measurements
• Document any deviations from authorized conditions

Common Compliance Issues

Avoid these frequent problems that lead to regulatory violations:

Authorization Problems:

• Expired Permits: Continuing to flare after authorization expires
• Exceeded Volumes: Flaring more than authorized amounts
• Wrong Authorization Type: Using inappropriate permit for situation
• Missing Applications: Flaring without any authorization

Reporting Errors:

• Wrong Disposition Codes: Using flare code for venting or vice versa
• Missing Authorization Numbers: Failing to include permit numbers
• Inadequate Remarks: Insufficient explanation of activities
• Volume Inaccuracies: Incorrect measurement or estimation

Documentation Deficiencies:

• Missing Records: Inadequate documentation of activities
• Incomplete Logs: Gaps in operational records
• Poor Organization: Records difficult to locate or review
• Calculation Errors: Mistakes in volume calculations

Enforcement and Penalties

The RRC takes flaring and venting violations seriously, with significant penalties for non-compliance.

Factors Affecting Penalty Severity:

• Volume of Unauthorized Flaring/Venting: Larger volumes = higher penalties
• Duration of Violation: Longer periods increase penalties
• Environmental Impact: Sensitive areas may have enhanced penalties
• Compliance History: Repeat violators face increased penalties
• Cooperation: Prompt reporting and correction may reduce penalties

Best Practices for Compliance

Follow these strategies to maintain compliance and avoid violations:

Proactive Management:

• Apply for authorizations well in advance of need
• Monitor authorization expiration dates
• Maintain flare equipment in good working condition
• Train personnel on proper procedures
• Implement volume measurement systems

Emergency Preparedness:

• Develop emergency response procedures
• Maintain contact information for RRC reporting
• Have backup flare systems where possible
• Train staff on emergency reporting requirements
• Keep emergency authorization forms readily available

Documentation Systems:

• Implement systematic record keeping
• Use standardized forms and procedures
• Regular review and audit of records
• Electronic backup of critical documents
• Clear assignment of documentation responsibilities