Oil & Gas
Investigations
Jason Harris
TCEQ
Houston Region
SBEA Internal Training – Oil & Gas
GCEAG – September 9, 2010
February 3, 2010
Oil & Gas Production in Texas
Oil & Gas Wells
As of 2008
GCEAG - September 9, 2010
DFW Barnett Shale
Investigation Types
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Complaints
Emissions Events
Stack Tests
Comprehensive Compliance
Investigations
Focused Investigations
GCEAG - September 9, 2010
Complaints
GCEAG - September 9, 2010
Complaints
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Noise
Truck Traffic / Road Conditions
Property Values
Well Location / Distance to Homes
Dust
Odors
No Permit / Authorization
GCEAG - September 9, 2010
What is a Nuisance?
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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”
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A nuisance violation may be issued
regardless of compliance with other rules
GCEAG - September 9, 2010
Complaint Response
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Each complaint is prioritized
Oil & gas complaints are investigated
within 12 hours or by the next business
day
GCEAG - September 9, 2010
Emissions Events
GCEAG - September 9, 2010
Emissions Events
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30 TAC §101, Subchapter F – Emissions Events and
Scheduled Maintenance, Startup and Shutdown
Activities
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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”
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GCEAG - September 9, 2010
Emissions Events
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30 TAC §101.201 - Emissions Event Reporting
and Recordkeeping Requirements
Reportable Quantities (within any 24 hr period)
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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)
GCEAG - September 9, 2010
Stack Testing
GCEAG - September 9, 2010
Stack Testing
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Oil & gas production sites often include multiple
combustion sources which may require stack testing
30 TAC 117, Subchapter D
Applies to minor, stationary sources of NOx located in ozone
non-attainment areas
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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
GCEAG - September 9, 2010
Stack Testing
To determine whether an engine must be stack
tested, the following information is needed:
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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?
GCEAG - September 9, 2010
Compliance Investigations
GCEAG - September 9, 2010
Compliance Investigations
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Investigations are triggered primarily
through:
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reconnaissance activities
complaints
ambient or mobile monitoring results
special projects or initiatives
An investigation may be limited in focus
or may be more comprehensive
GCEAG - September 9, 2010
Investigation Tools
GasFindIR® camera
Toxic Vapor Analyzer
Summa canister
GCEAG - September 9, 2010
Mini RAE
GasFindIR Camera
GCEAG - September 9, 2010
GasFindIR Camera
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Sources of Observed Emissions
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Condensate tank thief hatches
Water tanks
Unlit flares
Tank vents / Enardo valves
Glycol still vents
Gas-actuated valves
Wellheads
GCEAG - September 9, 2010
GasFindIR Camera
GCEAG - September 9, 2010
GasFindIR Camera
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If emissions are observed with the
GasFindIR
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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
GCEAG - September 9, 2010
Oil & Gas Questionnaire
Company Name:
Site Location/Address:
Contact Phone Number:
Site Name:
Contact Name:
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.
GCEAG - September 9, 2010
Summa Canisters
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Used to collect air
samples
Analyzed with a gas
chromatograph
Provide concentrations
of benzene and other
hazardous air
pollutants
GCEAG - September 9, 2010
Common Problems / Challenges
Thief Hatch
GCEAG - September 9, 2010
Common Problems / Challenges
Authorization
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Permit By Rule (PBR) - 30 TAC §106.352
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Standard Permit - 30 TAC §116.620
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not site-specific, but includes more requirements than a
PBR
New Source Review (NSR) Permit
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limits total VOC emissions to 25 tpy
special provisions for sour gas
no maintenance requirements and no distance
requirements for sweet gas facilities
site-specific permit
may require modeling for air contaminants
Title V Permit
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required for sources emitting VOC greater than major
source threshold (depends on location)
GCEAG - September 9, 2010
Common Problems / Challenges
Emission Estimates
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Several methods for estimating VOC
emissions
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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
GCEAG - September 9, 2010
Rule Revisions
GCEAG - September 9, 2010
Rule Revisions
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Draft oil & gas standard permit and PBR
currently open for public comment
Draft Standard Permit:
http://www.tceq.state.tx.us/assets/public/pe
rmitting/air/Announcements/og_proposed_s
p_fin.pdf
Draft PBR:
http://www.tceq.state.tx.us/assets/public/pe
rmitting/air/Announcements/og_pro_010018
106.pdf
GCEAG – September 9,2010
Rule Revisions
TCEQ seeks to accomplish the following through this rulemaking:
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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
GCEAG – September 9,2010
Rule Revisions
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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
GCEAG – September 9,2010
Houston-Galveston-Brazoria
Specific Requirements
GCEAG - September 9, 2010
HGB Specific Requirements
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After January 1, 2009, the following
requirements apply to sites within the HGB
ozone non-attainment area:
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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
GCEAG – September 9,2010
HGB Specific Requirements
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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
GCEAG – September 9,2010
Additional Information
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Multi-media compliance resource:
http://www.tceq.state.tx.us/assistance/sb
lga/industry/oilgas.html
PBR and Standard Permit info:
http://www.tceq.state.tx.us/permitting/air/
announcements/nsr_announce_3_25_10
.html
GCEAG – September 9,2010
Questions?
GCEAG - September 9, 2010