sbea internal training – oil & gas february 3, 2010 oil & gas investigations jason harris...

SBEA Internal Training – Oil & Gas February 3, 2010

Oil & Gas Investigations

Jason HarrisTCEQ

Houston Region

GCEAG – September 9, 2010

GCEAG - September 9, 2010

Oil & Gas Production in Texas

Oil & Gas WellsAs of 2008

DFW Barnett Shale

Investigation Types

• Complaints• Emissions Events• Stack Tests• Comprehensive Compliance

Investigations• Focused Investigations



Complaints


Complaints

• Noise• Truck Traffic / Road Conditions• Property Values• Well Location / Distance to Homes• Dust• Odors• No Permit / Authorization


What is a Nuisance?

• 30 Texas Administrative Code §101.4“No person shall discharge from any source whatsoever one or more air contaminants or combinations thereof, in such concentration and of such duration as are or may tend to be injurious to or to adversely affect human health or welfare, animal life, vegetation, or property, or as to interfere with the normal use and enjoyment of animal life, vegetation, or property”

• A nuisance violation may be issued regardless of compliance with other rules


Complaint Response

• Each complaint is prioritized• Oil & gas complaints are investigated

within 12 hours or by the next business day


Emissions Events


Emissions Events

• 30 TAC §101, Subchapter F – Emissions Events and Scheduled Maintenance, Startup and Shutdown Activities

• Upset event – “An unplanned and unavoidable breakdown or excursion of a process or operation that results in unauthorized emissions”

• Emission event – “Any upset event or unscheduled maintenance, startup, or shutdown activity, from a common cause that results in unauthorized emissions of air contaminants from one or more emissions points at a regulated entity”


Emissions Events

• 30 TAC §101.201 - Emissions Event Reporting and Recordkeeping Requirements

• Reportable Quantities (within any 24 hr period)

• Typically 5,000 lbs for natural gas• 100 lbs if H2S or mercaptans

• If RQ exceeded, must be reported within 24 hours (reportable)

• If not, final in-house record must be completed within 14 days (non-reportable)


Stack Testing


Stack Testing

• Oil & gas production sites often include multiple combustion sources which may require stack testing

• 30 TAC 117, Subchapter DApplies to minor, stationary sources of NOx located in ozone non-attainment areas

• 40 CFR 60 Subpart JJJJ – Standards of Performance for Stationary Spark Ignition Internal Combustion Engines

• 40 CFR 63 Subpart ZZZZ – National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines


Stack Testing

To determine whether an engine must be stack tested, the following information is needed:

• Type of Compression• Horsepower Rating• Manufacture Date• Type of Burn (Rich v. Lean) *these numbers differ for the EPA

vs. TCEQ• Is the Engine in question Portable, Stationary, or Emergency?• Is the Engine located in an Attainment or non-Attainment

County?• Is the Engine a Major or Minor Source?• Is the Engine used for Utility Electric Generation or is it

used for Industrial/Commercial practices?


Compliance Investigations


Compliance Investigations

• Investigations are triggered primarily through:• reconnaissance activities• complaints• ambient or mobile monitoring results• special projects or initiatives

• An investigation may be limited in focus or may be more comprehensive


Investigation Tools

GasFindIR® camera

Toxic Vapor Analyzer

Mini RAESumma canister


GasFindIR Camera


GasFindIR Camera

• Sources of Observed Emissions • Condensate tank thief hatches• Water tanks• Unlit flares• Tank vents / Enardo valves• Glycol still vents• Gas-actuated valves• Wellheads


GasFindIR Camera


GasFindIR Camera

• If emissions are observed with the GasFindIR• IR video is recorded• Video is shared with the owner/operator

along with a questionnaire• The questionnaire is used to obtain specific

information about site operations, the reason for the observed emissions, and steps taken to correct or minimize emissions


Oil & Gas Questionnaire

Company Name: Site Name:Site Location/Address: Contact Name:Contact Phone Number: Contact Email Address:

1. What are the TCEQ air authorizations for this site (i.e. Permit By Rule, Standard Permit, or New Source Review Permit, Title V (if applicable))? Please provide the authorization number, or registration number.

2. Is the site currently in compliance with the authorizations listed above?• What method (source testing, engineering calculations, etc…) did you use to

determine compliance with your authorizations?• If you are not currently in compliance with your authorizations, what actions are you

planning to take to achieve compliance? 3. What is the distance to the nearest receptor (i.e. residence, park, school, church)?4. Please provide a list of equipment at the site.5. Please provide a detailed process description.6. Based upon the provided video, please provide the following information:

• Identification of the unit or equipment with the observed plume.• The associated authorization for that piece of equipment.• Explanation for the observed plume.• Explanation as to how you plan to fix or have fixed the observed emissions.• If the observed emissions from the source are allowed by the site’s authorization,

provide the method used to determine this compliance. • Please provide a timeline for addressing the observed emissions.


Summa Canisters

• Used to collect air samples

• Analyzed with a gas chromatograph

• Provide concentrations of benzene and other hazardous air pollutants


Common Problems / Challenges

Thief Hatch



Authorization• Permit By Rule (PBR) - 30 TAC §106.352

• limits total VOC emissions to 25 tpy• special provisions for sour gas• no maintenance requirements and no distance

requirements for sweet gas facilities• Standard Permit - 30 TAC §116.620

• not site-specific, but includes more requirements than a PBR

• New Source Review (NSR) Permit• site-specific permit• may require modeling for air contaminants

• Title V Permit• required for sources emitting VOC greater than major

source threshold (depends on location)



Emission Estimates• Several methods for estimating VOC

emissions• Vasquez-Beggs Equation• Gas-Oil Ratio• Process Simulators• Direct Measurement

• Each method has drawbacks• Many operators fail to estimate or measure

emissions; simply assume PBR limits


Rule Revisions

Rule Revisions

• Draft oil & gas standard permit and PBR currently open for public comment

• Draft Standard Permit: http://www.tceq.state.tx.us/assets/public/permitting/air/Announcements/og_proposed_sp_fin.pdf

• Draft PBR: http://www.tceq.state.tx.us/assets/public/permitting/air/Announcements/og_pro_010018106.pdf

GCEAG – September 9,2010

http://www.tceq.state.tx.us/assets/public/permitting/air/Announcements/og_proposed_sp_fin.pdf



http://www.tceq.state.tx.us/assets/public/permitting/air/Announcements/og_pro_010018106.pdf



Rule Revisions

TCEQ seeks to accomplish the following through this rulemaking:

• Update administrative and technical requirements • Include practically enforceable monitoring, sampling, and

recordkeeping requirements • Address and authorize planned maintenance, startup, and

shutdown (MSS) activities • Allow the commission to more effectively focus resources on

facilities that significantly contribute air contaminants to the atmosphere

• Make appropriate changes to registration and notification requirements

• Ensure that air emissions from specific facilities are protective


Rule Revisions

• The comment period for the proposed Oil and Gas PBR and Standard Permit has been extended to October 1, 2010.

• New date for consideration of adoption by the Commission will be December 14, 2010



Houston-Galveston-Brazoria Specific Requirements

HGB Specific Requirements

• After January 1, 2009, the following requirements apply to sites within the HGB ozone non-attainment area:• 30 TAC 115.112(d)(4): Storage tanks storing

condensate must route flash gases to a control device if throughput exceeds 1,500 barrels per year

• 30 TAC 115.112(d)(5): Storage tanks storing crude oil or condensate must route flash gases to a control device if VOC emissions exceed 25 tpy


HGB Specific Requirements

• The Houston Regional Office recently concluded an outreach effort to advise tank battery operators of the HGB specific requirements

• This outreach also included a survey of tank batteries with the potential to exceed 1,500 bbls of condensate per year

• On-site investigations at a small number of tank batteries may begin as early as October


Additional Information

• Multi-media compliance resource: http://www.tceq.state.tx.us/assistance/sblga/industry/oilgas.html

• PBR and Standard Permit info: http://www.tceq.state.tx.us/permitting/air/announcements/nsr_announce_3_25_10.html


http://www.tceq.state.tx.us/assistance/sblga/industry/oilgas.html

http://www.tceq.state.tx.us/assistance/sblga/industry/oilgas.html

http://www.tceq.state.tx.us/permitting/air/announcements/nsr_announce_3_25_10.html




Questions?

sbea internal training – oil & gas february 3, 2010 oil & gas investigations jason harris...

Documents

emissions points

emissions event reporting

subchapter f emissions

upset event

prioritized oil gas

oil gas production

natural gas

permit authorization