Guidelines for management of fugitive methane and greenhouse gases emissions in the upstream oil and gas operations in Nigeria

The Nigerian Upstream Petroleum Regulatory Commission (NUPRC) released these guidelines to establish actions and mechanisms for operators to prevent and control the emission of greenhouse gases from upstream oil and gas operations at new and existing facilities. The guidelines were designed to: reduce environmental and social impacts; prevent the waste of natural resources; and support the achievement of Nigeria's emissions mitigation and reduction targets, including the elimination of routine gas flaring by 2030, and a 60% reduction in fugitive methane emissions/leakages from oil and gas operations by 2031.

To this end, the guidelines establish the following requirements for upstream oil and gas facilities:

• GHG Management Plans: Operators shall develop and submit GHG management plans within 6 months of the effective date of the legislation that include an inventory of emission sources, accounting methodologies, and plans and timelines to reach net-zero emissions. 
• Emissions Monitoring and Inspection Requirements:
  • Leak Detection and Repair (LDAR): LDAR inspections shall be conducted using optical gas imaging, laser beam technology or other Commission-approved technology with the following frequency: one inspection within the first year of implementation of the Guidelines; two inspections in the second year; and four inspections in the third and subsequent years. Large leaks should be repaired within 5 working days of discovery; small leaks within 14 working days. Operators are required to record and submit the technical specifications of their LDAR equipment along with regular inspection reports. The Commission will monitor compliance and issue a certificate of confirmation to the operator upon completion. 
  • Flare Requirements: Flares found to be unlit venting gas must be repaired within 48 hours. Flare tips that are sputtering or smoking must be replaced within 2 years following the implementation of the Guidelines; after 2 years, sputtering or smoking flares should be addressed within 60 days of inspection.
• Operational and Equipment Standards
  • Cold Venting is prohibited unless an operator is granted a waiver due to operational exigencies. 
  • Flare Efficiency should meet a design destruction removal efficiency (DRE) of at least 98%. 
  • Pneumatic Controllers: natural gas driven controllers should be replaced with zero bleed controllers that are powered by electricity or instrument air or emissions shall be routed to a vapor recovery system. 
  • Pneumatic Pumps: natural gas venting pumps should be replaced with electric pumps or emissions should be routed to a vapor recovery system. 
  • Centrifugal Compressor Seals: Operators should route oil degassing unit emissions to a vapor recovery system or combustion device.
  • Reciprocating Compressor Rod-packing: Emissions should be routed from compressor vents and controlled by rod-packing replacement or the installation of an emissions collection system. 
  • Glycol dehydrators: vents from any flash separator or flash tank on a glycol natural gas dehydrator shall reduce uncontrolled actual emissions by at least 95% on a rolling 12-month basis using a condenser or air pollution control equipment. 
  • Liquid Storage Tanks (Flash gas, working & breathing losses): Operators shall route emissions to a vapor recovery system or combustion device.

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