oil and gas regulations and tceq lessons...
TRANSCRIPT
Oil and Gas Regulations and TCEQ Lessons Learned
City of Dallas Gas Drilling Task Force Meeting – July 26, 2011
Keith Sheedy, P.E.Technical Advisor
Chief Engineer’s OfficeTexas Commission on Environmental Quality
What information is going to be provided?
• Quick background information on Barnett Shale
• Who regulates oil and gas activities in Texas?
• TCEQ lessons learned
Page 2
Page 3
426,235 - Active Oil and Gas Wells
24 county Barnett Shale
area
24 county Barnett Shale
and ozone nonattainment
area
Active Oil and Gas Wells in the 24
county area
Barnett Shale wells in the 24 county
area
Page 6
Dallas city limits
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Barnett Shale Special InventoryPoint source emissions inventory equipment counts for the 23 county
Emission Source Equipment Counts
Separators Vented to Atmosphere *
Total Oil Storage Tanks *
Total Condensate Storage Tanks *
Total Produced Water Storage Tanks *
Total Slop Storage Tanks *
Total Storage Tanks 651
Uncontrolled Glycol Dehydrators 81
Controlled Glycol Dehydrators 64
Total Stationary Engines 900
Turbines 22
Flares 38
Frac tanks *
Piping Component Fugitive Areas 307
Process Vents *
Blowdown Vents 191
Heaters/boilers 277
Other Stationary Equipment 486
Total Emission Sources 3,017
*Equipment counts could not be determined for the indicated sources from point source inventory data.
Point Source Engines
Barnett Shale Special Inventory9,796 leases responded to the Phase One inventory.
The equipment totals by source type:
Emission Source Number of Sources
Separators Vented to Atmosphere 16
Total Oil Storage Tanks 852
Total Condensate Storage Tanks 4,143
Total Produced Water Storage Tanks 14, 997
Total Slop Storage Tanks 132
Uncontrolled Glycol Dehydrators 31
Controlled Glycol Dehydrators 120
Total Stationary Engines 2,653
Turbines 15
Flares 40
Frac tanks 27
Piping Component Fugitive Areas 15,517
Process Vents 1,191
Blowdown Vents 7,299
Heaters/boilers 616
Other Stationary Equipment 1,372
Total Emission Sources 49,021
Barnett Shale EI - Engines
All ReportedEngines
All Barnett Shale wells and Engines
Barnett Shale Special Inventory
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Barnett Shale equipment Totals for all inventory types.
Emission Source Number of Sources
Separators Vented to Atmosphere 16
Total Storage Tanks 20,775
Uncontrolled Glycol Dehydrators 112
Controlled Glycol Dehydrators 184
Total Stationary Engines 3,553
Turbines 37
Flares 78
Frac tanks 27
Piping Component Fugitive Areas 15,824
Blowdown Vents 7,490
Process Vents 1,191
Heaters/boilers 893
Other Stationary Equipment 1,858
Total Emission Sources 52,038
Who Regulates Oil and Gas Activities in Texas?(RRC, TCEQ, or ???)
• The Railroad Commission of Texas (RRC) has primary regulatory jurisdiction over the oil and gas (O&G) industry.
• The Texas Commission on Environmental Quality (TCEQ) is the environmental agency for the state.
• There is a Memorandum of Understanding (MOU) between the RRC and TCEQ detailing jurisdictions of O&G activities.– http:/info.sos.state.tx.us/pls/pub/readtac$ext.viewtac)
• Common Environmental Requirements for Regulated O&G Operations - Publication RG – 482 http://www.tceq.texas.gov/publications/rg/rg-482.html
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Who Regulates Oil and Gas Activities in Texas?Water Issues (RRC, TCEQ, or ???)
• Process wastewater discharge and storm water run-off from O&G sites - EPA
• Process wastewater discharge from non O&G sites – TCEQ• Drinking water
– Private wells – suspected contamination by O&G should be reported to the RRC
– Public water supply – concerns should be reported to the TCEQ
• Dam safety - TCEQ• Reclaimed water from municipal or industrial sources used
for hydraulic fracturing, after which the water must be disposed of by deep well injection – TCEQ and RRC
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Surface Water Rights
• Before initiating any diversion, impoundment, taking, or use of surface water, or construction for those activities, a permit must be acquired from the TCEQ.
• There are areas of the state where it may be difficult to find water available on a permanent, term, or temporary basis due to existing permits and specific conditions in the stream. Page 15
Surface Casing
• The Railroad Commission of Texas may require a groundwater-protection recommendation letter from the TCEQ, if someone is drilling: – an oil and/or gas well,– Class II disposal well,– cathodic protection well, or– seismic shot hole.
• They will be provided with the estimated depth to the base of usable-quality groundwater, so the appropriate level of surface casing can be installed.
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Who Regulates Spills at Oil and Gas Sites?(RRC, TCEQ, or ???)
Classification of the spill determines which agency has jurisdiction
• Spills associated with exploration, development, and production of O&G – RRC
• Hazardous substances - TCEQ• Refined petroleum products – TCEQ• Abandoned containers of unknown substances that are
not leaking – TCEQ• Texas Oil Spill Prevention and Response Program –
Texas General Land Office
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Who Regulates Waste at Oil and Gas Sites?(RRC, TCEQ, or ???)
In general wastes from O&G related activities are regulated by RRC. The exceptions are:
• Waste associated with transportation of crude oil and natural gas by railcar, truck, barge, or oil tanker
• Refined petroleum products by pipeline• Wastes generated at oil field service facilities that
provide equipment, materials, or services to the O&G industry
• Wastes that are processed, treated, or disposed of at a solid waste management facility authorized by the TCEQ
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What about the dust, noise, and traffic associated with O&G sites?
• Dust from public roads should be addressed by the local government.
• Noise complaints should be reported to the local law enforcement agency.
• Traffic complaints should also reported to the local law enforcement agency.
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Federal Air Regulations
40 CFR Part 60 New Source Performance Standards (NSPS)– Subpart KKK – Equipment leaks of VOC from
onshore natural gas processing plants
– Subpart LLL – Standards of performance for Onshore Natural Gas Processing: SO2 emissions
– Subpart JJJJ – Standards of performance for stationary spark ignition internal combustion engines
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Federal Air Regulations (cont.)
40 CFR Part 63 National Emission Standards for hazardous Air Pollutants (NESHAP) – Subpart HH – Natural gas production facilities
– Subpart HHH – Natural gas transmission and storage facilities
– Subpart ZZZZ – Reciprocating internal combustion engines
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Federal Air Regulations (cont.)
Federal regulations • NSPS (Part 60) and MACT (Part 63)
– revisions are to be proposed by July 28th, with final rules by Feb 2012
• Ozone National Ambient Air Quality Standard – 85 ppb, 75 ppb, 60 to 70 ppb what will it be ???
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Air Regulations - Authorizations
Owners and operators of an O&G site must obtain an authorization for air emissions.
REALLY, SINCE WHEN?
Since September 1, 1972, when the Texas Clean Air Act became effective.
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TCEQ Air Regulations Type of Authorizations Available
Permit by Rule (PBR) if:– Less than 250 tpy of CO or NOx,– Less than 25 tpy of VOC, SO2, PM10, and– Less than 25 tpy of any other air contaminant, except
carbon dioxide, water, nitrogen, methane, ethane, hydrogen, or oxygen
Common PBRs:• 106.351 – Saltwater Disposal• 106.352 – Oil & Gas Handling and Production Facilities• 106.353 – Temporary Oil & Gas Facilities• 106.492 - Flares• 106.512 – Stationary Engines & Turbines Page 24
TCEQ Air Regulations 106.352 O&G Handling and Production
Facilities
The new PBR, Section 106.352 for Oil & Gas Handling and Production Facilities became effective April 2011.
Please see the provided handout for a summary of the new requirements.
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TCEQ Air Regulations –Authorizations continued
Can’t qualify for a PBR, a company may be eligible for a Standard Permit.
Can’t qualify for a Standard Permit, then the company must get a new-source-review (NSR) permit.
Also “Major Sources” are subject to Title V of the Federal Clean Air Act and must meet operating permit requirements under that program. TCEQ has delegation of this federal program.
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TCEQ Air Regulations
A company had an “upset” at an O&G site that lead to unauthorized air emissions.
• Are they required to record the information concerning the event? Yes
• Are they required to report the event to the TCEQ? Depends on what and how much was emitted
• 30 TAC 101.201 and 101.222 have all of the answers
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TCEQ Air Regulations
Someone has complained to the TCEQ about an odor or dust issue at a well pad that is being completed, what TCEQ rules could apply?
• 30 TAC 101.4 –Nuisance and
• 30 TAC 111.111 –Visible emissions
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TCEQ Air Regulations Chapter 101.10. Emissions Inventory Requirements.
(a) Applicability. The owner or operator of an account … shall submit emissions inventories …:
(1) an account that meets the definition of a major facility/stationary source, … or any account in an ozone nonattainment area emitting a minimum of ten tons per year (tpy) volatile organic compounds (VOC), 25 tpy nitrogen oxides (NOx), or 100 tpy or more of any other contaminant subject to national ambient air quality standards (NAAQS);
(4) any minor industrial source, area source, non-road mobile source, or mobile source of emissions subject to special inventories under subsection (b)(3) of this section.
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TCEQ Air Regulations (cont.)
• Chapter 101 – State delegation of 40 CFR Part 60 (NSPS rules) and Part 61 (NESHAPS rules)
• Chapter 112 – Control of sulfur dioxide and hydrogen sulfide
• Chapter 113 – State adopted 40 CFR Part 63 (MACT rules)
• Chapter 114 – Control of air pollution from motor vehicles - Gasoline and diesel
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TCEQ Air Regulations (cont.)Chapter 115 – Storage of volatile organic compounds
• Additional requirements have been proposed. Potential adoption at the November 16th, TCEQ Commissioner’s Agenda
• A condensate tank or tank battery with more than 1,500 barrels per year liquid throughput requires a vapor recovery unit or control device.
• A crude oil or condensate tank or tank battery requires vapor recovery unit or control device if potential emissions are over 25 tons per year (tpy).
• At 25 tpy, vapor recovery devices are expected to be feasible and recovered product should help offset initial costs.
• The proposed rule would apply these more stringent regulations in the DFW area with 95% control of VOC flash emissions that would reduce VOC emissions by 14.37 tpd in 2012.
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TCEQ Air Regulations (cont.)
Chapter 117 – Control of air pollution from nitrogen compounds – In other words, the control of NOx from combustion sources.
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Barnett Shale – Lessons Learned
• Enhanced monitoring and use of emerging technology
• Emission related research• Rulemaking• Routine maintenance• Responsiveness• COMMUNICATION!!!
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Oil and Gas EI Improvement Activities
• 2005 Upstream Oil and Gas Tank Project– Measured emissions from oil and condensate tanks – Developed factor for area source emissions inventory– EPA approved Tank testing procedure needed– http://projects.tercairquality.org/AQR/H051C
• Dallas-Fort Worth (DFW) Compressor Engine Project– Ambient measurements downwind of gas compressor
engines– Develop typical compressor engine ambient signatures
• 2007 Engine Fleet DFW Nonattainment Area Survey• 2007 Southeast Texas Compressor and Dehydrator Survey
Oil and Gas EI Improvement Activities• Drilling Rig Emissions Project
– Activity data– Emissions characterization data– Used to develop the drilling rig emissions
inventory for 2008– www.tceq.state.tx.us/implementation/air/airmod/pr
oject/pj_report_ei.html• Oil and Gas Platform Inventory Improvement Project
– Oil and gas platforms in Texas water– Parallels federal platform inventories in Gulf of
Mexico– www.tceq.state.tx.us/implementation/air/airmod/pr
oject/pj_report_ei.html
Oil and Gas EI Improvement Activities
• Flash Emissions Model Evaluation– Evaluated different methods for calculating oil and
condensate tanks– Improved agency guidance– www.tceq.state.tx.us/implementation/air/airmod/proj
ect/pj_report_ei.html• Oil and Gas Model Evaluation
– Evaluate methods, models, and related data– Texas-specific calculator for area inventory
development– Posted on the agency’s emissions inventory web
page
Oil and Gas EI Improvement Activities
• Produced Water Storage Tank Project – This area may need additional research– Limited available data
• EI Guidance Improvement– Comprehensive guidance documents– www.tceq.state.tx.us/goto/ieas
• Barnett Shale Phase I and Phase II special inventory• Additional pneumatic valve control survey
– Type of valves being used: high, low, or no bleed
Current monitors in DFW area
8881
65
65
65
79
75
75
76
76
70
74
78
73
83
80
78
77
69
Current 2011 Ozone Design Values 68
Predominate wind direction on high ozone days
East
Page 39
0
0.05
0.1
0.15
0.2
0.25
0.3
0.35
2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011
ppbv
Year
Auto GC Benzene Annual Averagespart per billion - by volume (ppbv)
Dallas Hinton
FW Meacham
DISH
Eagle Mountain
Flower Mound
Decatur
NOTES: DISH and Eagle Mountain Auto GC monitors installed in April 2010.Flower Mound and Decatur Auto GC monitors installed in November 2010.
What We Are Finding
• Nearly all of the issues documented arose from human or mechanical failures.
• These items were quickly remedied and could have been avoided through increased diligence on the part of the operator.
• Corrective actions amounted to little more than replacing worn gaskets, closing open hatches, and repairing stuck valves.
Moving Forward
The TCEQ must continue to:• Ensure transparency of our efforts through
abundant and timely communication with all interested parties;
• Evaluate the existing ambient air quality monitoring network and expand, as needed, through the use of established agency protocol for determining the placement of long-term, stationary monitors;
Moving Forward
• Apply the use of state-of-the-art handheld air monitoring equipment to assess short-term, near-source air quality;
• Maintain a frequent, routine investigative presence while also providing timely complaint response;
• Base our rules and permits on sound science and common sense; and
• Apply our enforcement tools in a fair and consistent manner.
Additional Barnett Shale Information
• Barnett Shale website:– www.tceq.state.tx.us/implementation/barnetts
hale/bshale-main
Questions?
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Keith Sheedy, [email protected]
Tony WalkerDFW Regional [email protected]
Alyssa Taylor, R.E.M.DFW Air Section [email protected]