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Guideline for Management of GHG and Fugitive Emissions from Midstream and Downstream Petroleum Operations

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NIGERIAN MIDSTREAM AND 
jp DOWNSTREAM PETROLEUM 
F 
; 
rp “ REGULATORY AUTHORITY (NMDPRA) 
Applicable to all Midstream and Downstream 
Petroleum Operations 
GUIDELINES FOR MANAGEMENT OF GREEN HOUSE GASES (GHG) 
AND FUGITIVE EMISSIONS FROM MIDSTREAM AND DOWNSTREAM 
PETROLEUM OPERATIONS IN NIGERIA 
3.10.2 
b, 
A licensee 
or permit-holder of storage tanks 
for which 
the use 
of 
air 
pollution control equipment would not be technically feasible without 
supplemental fuel, may apply to the Authority for an exemption from the 
control requirements of Section 3.10.1(a}] above. The request shall include 
details of the non-feasibility of the 
air pollution control equipment. This 
exemption shall not assuage a 
licensee or permit-holder of compliance 
with the storage tank monitoring requirements. 
Venting of hydrocarbon emissions from hatches and other access points 
on tanks during normal operation is prohibited, except where: 
i. 
The 
hatch 
is 
opened 
for 
measurement 
purposes 
and 
closed 
immediately after the sample is taken. 
ii. 
An auto-gauging system or spigot to sample hydrocarbons in tank is 
used instead of opening the hatch. 
. Alicensee or permit-holder of facilities with controlled tanks shall evaluate 
their systems for controlling tank emissions and certify that each system as 
designed is large enough to capture all potential emissions from the tank. 
Monitoring 
A licensee or permit-holder shall: 
ad. Conduct monihly AVO inspections of floating roof, fixed roof storage tanks 
and control devices to ensure emissions of more than 
2 toy are being 
routed to control units and flares and are operating as designed. 
Monitor storage vessels, access points and Vapor Recovery Systems and 
combustors as part of instrumental LDAR. 
. 
Estimate annual methane emissions from the tanks and evaluate whether 
the exemption complies with conditions in Section 3.10.1(b) above. 
An 
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