WEBVTT
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Brought to
you by adminmonitor.com.
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Good afternoon and thank you
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for attending this webinar.
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You may submit questions
throughout the presentation
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by clicking the Q&A button
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in the center of the
bottom of your window.
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You will see both the
questions and responses
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after they have been answered.
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Some questions may be held for answer
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until the end of the presentation.
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Presentations and webinar
recordings are all available
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by navigating to RRC regulatory webinars
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from the oil and gas
workshops and seminars page
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on the Railroad
Commission of Texas website.
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Our presenter this
afternoon is Weston Cassady
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of the engineering unit
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and the technical permitting department
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of the oil and gas division.
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All right, let's go
ahead and get started.
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Weston, whenever you're ready.
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All right, good
afternoon, everyone.
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I really appreciate
everyone taking the time
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to attend this presentation.
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My name is Weston Cassady,
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and I'm part of the engineering unit
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here at the Railroad Commission.
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The engineering unit, for
those of you that don't know
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is part of the technical
permitting division of oil and gas.
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I generally review completion,
statement rule 10 requests,
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field transfers and
new field discoveries.
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But today I'll be covering
Statewide Rule 32,
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which deals with venting and flaring.
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And for those of you that
attended last year's conference
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almost looked similar,
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but I have some
updated flaring statistics
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and I'll be covering
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some of the new
administrative procedures
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that we have been implementing.
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Tim Speer, the engineering unit manager,
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will be handling Q&A
during, after the presentation.
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So please feel free to type
any questions as we go along.
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You're welcome to hold
them to the end as well.
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I'll be sure to go
through all the questions,
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answered or not, at the
end of the presentation
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so that everyone gets
a chance to see them.
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I'll go ahead and get
started with a slide
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that I'm sure everyone
has memorized by now.
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So this is our mission here
at the Railroad Commission,
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is to serve Texas by our
stewardship of natural resources
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and the environment,
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our concern for personal
and community safety
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and our supported enhanced
development and economic vitality
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for the benefit of Texans.
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So before we get into the rule itself,
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I'd like to give a bit of background
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and sort of set the stage for the rule.
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And the actual title
of Statewide Rule 32
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is the Gas Well Gas and Casinghead Gas
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Shall Be Utilized for Legal Purposes.
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So if you read the table
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showing the number of flaring
permits issued per fiscal year
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and to put these numbers into context,
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as of August 31st, 2019,
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Texas had almost 265,000
producing oil and gas wells.
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So venting and flaring
really only involves
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a pretty small fraction
of the state's oil wells.
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As you can see, in 2010, 2011,
we had a substantial increase
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in the number of permits
issued up until about 2014,
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where it stabilized through 2018.
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And then in 2019, we did see
a large number of flare permits
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issued once again.
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This graph ties directly
into our previous table.
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The black line at the
top shows gas produced
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in billion cubic feet
and uses the left y axis.
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It goes from zero bcf to 900 bcf.
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That purple line down at the bottom
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shows the percent of total gas flared.
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And that's gonna use the right y axis.
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It goes from zero to 7%.
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And then that blue line
they see there in the middle,
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that's the percent of
casinghead gas flared,
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and that uses the right y axis as well.
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And for those of you that aren't aware,
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the casinghead gas
is gas that is produced
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from a producing oil well.
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So what this graph is
showing us is the rapid rise
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in percentage of
casinghead gas flared in 2010,
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all the way through 2013,
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sort of like our table was showing us
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as far as the increase in permits.
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So the total amount of gas produced
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did not dramatically
increase along with this.
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In part, what this can be
attributed to are the shell plays
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out in the Eagle Ford which produce oil,
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but also obviously a
significant amount of gas.
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And really, the reason
I'm saying all this
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and going through this background
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is because Rule 32 was created
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to handle the amount of permits
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we were seeing really before 2011,
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before that initial spike.
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So just sort of wanted to set the stage
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for exactly how and
why we apply the rule
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the way that we do.
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And as we go along,
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I'll do my best to explain
and highlight examples of this.
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And just another note in 2015
where you see that decrease,
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as many of you are aware,
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that's when the oil prices
tanked and productions slipped.
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So I just really wanted
to give a closer look
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at some of the data
just from this last year.
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So again, in black are the
total gas produced in bcf.
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We have total liquids in
green and million barrels of oil.
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And then we have total gas
flared in bcf shown in the gray,
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that really small line
down there at the bottom,
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along the x axis.
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And then last, we have gas flared
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as a percentage of total gas
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represented by the purple line,
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not utilized at zero to 2.5
percentage on the right y axis.
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So it's just giving you
a little bit closer look
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toward really the end of
our graph here in slide five.
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So just a little introduction here.
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Gas must be used for lease operations
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or sold if it can be readily
measured by devices, meters
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routinely used in the
operations of oil wells, gas wells,
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gas gathering systems or gas plants.
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So this is session description.
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We will see it four times.
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This is really just an outline
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of what we'll be discussing today.
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So like I said,
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we have four main points
that we wanna cover.
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So first, we're gonna go
over exemptions from the rule.
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This is when Statewide
Rule 32 does not apply.
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So a.k.a, when there's
no metering required.
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The second topic we'll go over today
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is authorized flaring and venting.
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So when flaring is
allowed without a permit
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under special conditions.
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So under this conditions,
all gasses are metered
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and reported on the production report.
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Third item we'll go over
are flaring exceptions.
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We'll discuss what is
required for an exception
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and what it actually
does for the operator.
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And then fourth, we'll go over
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some, a little bit of
additional helpful information.
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So I'll go ahead and hop
into exemptions from the rule.
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And just to note, the
handout for this presentation
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contains all the slides.
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I know it's not technically
a handout this time.
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But the notes on the
bottom of the slides
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will address where to find
the information within the rule.
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So for example, the
information on this slide
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is addressed in Statewide
Rule 32 D-1, A through D.
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So it should reference exactly
where this information is.
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If say you have a question about this,
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as you read through it at
another time or reference it,
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you can reference exactly
where I'm getting this information
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from the rule.
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So for the next slide,
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it would be Statewide
32 D-1, D through G.
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Okay.
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So the following are examples
of when Statewide Rule 32
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does not apply and
no metering is required.
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So the first would be tank vapors
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from crude oil storage tanks,
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gas well condensate storage tanks
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and salt water storage tanks.
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The second example
where no metering is required
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is fugitive emissions of gas.
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The third is amine treaters,
glycol dehydrator, excuse me,
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glycol dehydrator flash tanks
and, or reboiler emissions.
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And the fourth example is blowdown gas
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from gas handling
equipment for construction,
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maintenance and repair.
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Continuing on with exemptions.
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We have our fifth example here
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where no metering is required.
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That'd be gas purged
from compressor cylinders
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or other gas handling
equipment for startup.
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And then sixth, we have gas released
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either at a well site
during drilling operations
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prior to the completion
date of the well.
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This must be separated
from drilling fluids
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using a mud-gas
separator or mud degasser.
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Or gas released during
completion or re-completion.
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And just a note about this,
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the Commission may
also not require metering
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but determines that flaring
is required for safety reasons.
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And so you'll see that
come up a few times
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throughout this presentation.
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Okay.
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So onto our second item here.
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We're gonna look at
authorized flaring and venting.
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So the Commission may
require flaring of releases of gas
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not readily measured if
the Commission determines
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that flaring is required
for safety reasons.
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Like I just mentioned,
high concentrations of H2S
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or something like that.
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All gas releases greater
than 24 hours in duration
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shall be burned in a flare if
the gas can be burned safely.
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And then all gas releases
of 24 hours or less in duration
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may be vented to the air
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if not required to be
flared for safety reasons.
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And so if you're ever unsure,
the thing to do automatically
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is contact the district
office for verification,
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if you're unsure.
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So continuing on with gas
releases authorized by our rule.
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Authorized gas releases
during production operations
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must be measured, a.k.a
metered or be reported
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on monthly production reports.
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So flaring beyond the limits
set in the following scenarios
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requires an exception to be granted.
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So produced gas is not to
exceed 10 producing days
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after initial completion,
re-completion in other field
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or workover in the same field.
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So examples of workover
operations include perforating,
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stimulating, deepening,
clean up, oil maintenance,
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or some other repair operations.
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Also gas that must be
unloaded from a well
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may be vented up to 24
hours in one continuous event
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or two 72 cumulative hours in one month.
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So 24 and one of them,
72 cumulative in one month.
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Continuing on with gas
releases authorized by the rule.
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If gas from at lease production
facility may be released
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up to 24 hours in
the event of a pipeline
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or gas plant upset.
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So that would be our sort
of one continuous event.
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Also gas contained in waste
stream from molecular sieves
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or membrane gas treatment units,
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provided at least 85% of
the inlet gas is recovered
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and directed towards legal use.
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So molecular sieves or
membrane gas treatment units
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are used to remove carbon
oxide, hydrogen sulfide
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and other contaminants
from that gas stream.
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Also, we have low pressure
separator gas, up to 15 mcfd
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for gas wells and then 50 for oil leases
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or co-mingled points.
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And this has gas that must
pass through a separator,
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heater-treater, or other
low pressure equipment
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prior to its release.
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Sorry, I got a drink of water there.
00:13:10.500 --> 00:13:15.000
Okay, so again, we see may
be released for up to 24 hours
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in the event of a pipeline
or gas plant upset.
00:13:20.900 --> 00:13:23.490
And you wanna notify
your local district office
00:13:23.490 --> 00:13:26.730
as soon as reasonably
possible after the release begins.
00:13:26.730 --> 00:13:29.430
So again, you'll see
this as a common theme.
00:13:29.430 --> 00:13:32.550
If you're unsure, just
contact your district office
00:13:32.550 --> 00:13:34.350
and they will help you through that.
00:13:35.720 --> 00:13:37.830
If a gas plant operator
presents information
00:13:37.830 --> 00:13:40.670
that shows necessity
of release is justified
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beyond that 24 hours,
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the operator may continue to flare gas.
00:13:45.370 --> 00:13:49.090
Operator must file exception
request within one business day
00:13:49.090 --> 00:13:52.203
after the first 24 hours of release.
00:13:53.350 --> 00:13:57.800
So examples of situations
that may qualify for an exception
00:13:57.800 --> 00:14:00.400
are gas gathering system
or gas plant construction,
00:14:00.400 --> 00:14:04.550
repairs, maintenance,
gas plant turnaround,
00:14:04.550 --> 00:14:07.553
emergency situations like
fire or something like that.
00:14:09.660 --> 00:14:12.440
Okay, so we're onto our third topic,
00:14:12.440 --> 00:14:14.076
which is probably the one
00:14:14.076 --> 00:14:17.293
most of y'all are really interested in.
00:14:18.190 --> 00:14:20.290
This is flaring exceptions
00:14:22.287 --> 00:14:24.483
and the actual permitting process.
00:14:26.380 --> 00:14:28.490
So I just wanna start
by saying a flare permit
00:14:28.490 --> 00:14:30.690
is an exception to the Statewide rule.
00:14:30.690 --> 00:14:34.130
Application is made on the
Statewide Rule 32 Data Sheet,
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which can be downloaded from our website
00:14:36.440 --> 00:14:37.520
and I have it there.
00:14:37.520 --> 00:14:40.413
I'm sure all of you have
been there many times.
00:14:41.910 --> 00:14:46.240
Also there's a $375 fee
per gas well, oil lease
00:14:46.240 --> 00:14:48.393
or commingled vent/flare point.
00:14:49.400 --> 00:14:51.770
This is something that we've seen a lot
00:14:51.770 --> 00:14:56.770
where say that there is,
I don't know how many,
00:14:56.810 --> 00:15:01.170
however many wells
connected to a commingled point.
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You don't have to have a fee
for every single one of those.
00:15:04.970 --> 00:15:07.020
It can be per gas well, oil lease
00:15:07.020 --> 00:15:09.003
or commingled vent/flare point.
00:15:10.030 --> 00:15:12.140
And also there is a special situation
00:15:12.140 --> 00:15:14.210
that I won't really go
into too much detail
00:15:14.210 --> 00:15:16.600
but I do encourage you to read over it
00:15:16.600 --> 00:15:19.130
and I've referenced it in the notes,
00:15:19.130 --> 00:15:22.513
specific item in Statewide Rule 32.
00:15:23.837 --> 00:15:27.230
Also the exception
maybe sent by fax or email
00:15:27.230 --> 00:15:29.120
provided a signed original request,
00:15:29.120 --> 00:15:31.930
accompanied with fee, is
received by the Commission
00:15:31.930 --> 00:15:33.970
within three business days.
00:15:33.970 --> 00:15:36.050
Also copy the direct link
00:15:36.050 --> 00:15:39.503
to the Statewide Rule 32
Data Sheet in the notes.
00:15:40.700 --> 00:15:41.700
Another way to get there
00:15:41.700 --> 00:15:44.930
if for whatever reason
you can't type out
00:15:44.930 --> 00:15:47.760
this really long link, if
you go to our website,
00:15:47.760 --> 00:15:51.390
go to Oil and Gas and
then go to oil and gas forms.
00:15:51.390 --> 00:15:54.170
And if you go to the,
00:15:54.170 --> 00:15:57.380
it's a category arranged
by purpose of filing
00:15:57.380 --> 00:15:59.380
and you scroll all the way that bottom,
00:15:59.380 --> 00:16:02.370
I believe it's either the
last or second to last form
00:16:02.370 --> 00:16:03.543
at the very bottom.
00:16:08.200 --> 00:16:10.620
So we're continuing on with exceptions.
00:16:10.620 --> 00:16:13.257
Our current practice for
administrative exceptions
00:16:13.257 --> 00:16:18.257
are 45 to 60 day terms
for pipeline capacity issues
00:16:19.000 --> 00:16:20.770
and system upsets,
00:16:20.770 --> 00:16:23.743
or 90 day terms for lack of a pipeline.
00:16:25.070 --> 00:16:27.040
So these may be renewed administratively
00:16:27.040 --> 00:16:30.570
for up to a total of 180 days.
00:16:30.570 --> 00:16:32.850
Exceptions for anything over 180 days
00:16:32.850 --> 00:16:35.230
can only be granted through a hearing
00:16:35.230 --> 00:16:38.600
with a final order signed
by the Commission.
00:16:38.600 --> 00:16:42.580
And so like I prefaced
with the table and the graph,
00:16:42.580 --> 00:16:45.100
the rule was really not initially made
00:16:45.100 --> 00:16:47.660
to accommodate the
large amount of permits
00:16:47.660 --> 00:16:49.883
that we are currently receiving,
00:16:51.560 --> 00:16:53.420
the requests that we are receiving.
00:16:53.420 --> 00:16:56.570
So this is why in the rules,
you will not see anything
00:16:56.570 --> 00:17:01.570
regarding the 45 to
60 day or 90 day terms.
00:17:02.020 --> 00:17:05.730
These short terms are there to
ensure progress is being made
00:17:05.730 --> 00:17:08.640
towards connecting
to an actual pipeline.
00:17:08.640 --> 00:17:10.530
So understand it's not always possible,
00:17:10.530 --> 00:17:14.830
but the focus here is that we
see an intention to remediate
00:17:14.830 --> 00:17:17.963
between the first and second exceptions.
00:17:25.230 --> 00:17:26.063
Okay.
00:17:26.063 --> 00:17:27.420
Yeah, a little bit more
information down there
00:17:27.420 --> 00:17:29.853
at the bottom of what
information is required.
00:17:31.670 --> 00:17:33.470
Continuing on with exceptions.
00:17:33.470 --> 00:17:36.460
These may be indefinitely
approved administratively
00:17:36.460 --> 00:17:41.460
with adequate justification
if less than 50 mcf per day.
00:17:42.030 --> 00:17:44.090
So the rule states
requests for exceptions
00:17:44.090 --> 00:17:45.700
for more than 180 days
00:17:45.700 --> 00:17:50.070
and for volumes greater than
50 mcf of hydrocarbon gas
00:17:50.070 --> 00:17:53.180
per day shall be granted
all in the final order
00:17:53.180 --> 00:17:55.630
signed by the Commission,
like we just discussed.
00:17:56.640 --> 00:18:01.300
So for these administration approvals,
00:18:01.300 --> 00:18:04.000
these indefinite
administration approvals,
00:18:04.000 --> 00:18:08.130
there is more documentation
required, listed right here.
00:18:08.130 --> 00:18:10.930
Obviously the Statewide
Rule 32 Data Sheet.
00:18:10.930 --> 00:18:15.880
Other than that, is we'd
require a cost benefit analysis,
00:18:15.880 --> 00:18:20.137
a map showing the nearest
pipeline capable of accepting gas.
00:18:20.137 --> 00:18:25.030
And this goes back to us
wanting to see an intention
00:18:25.030 --> 00:18:29.513
to remediate the lack of
hooking up to a pipeline.
00:18:30.680 --> 00:18:33.713
And then also we need
an estimate of gas reserves.
00:18:36.920 --> 00:18:38.750
Four of the five here on exceptions.
00:18:38.750 --> 00:18:41.190
If additional time is requested,
00:18:41.190 --> 00:18:44.710
the operator must refile within 21 days
00:18:44.710 --> 00:18:48.480
before the expiration of the exist,
00:18:48.480 --> 00:18:50.940
excuse me, existing permit.
00:18:50.940 --> 00:18:54.450
So if refiled within 21 days,
00:18:54.450 --> 00:18:57.540
the operator is authorized
to continue flaring or venting
00:18:57.540 --> 00:19:00.160
until final approval or denial
00:19:00.160 --> 00:19:02.333
of the requested permit extension.
00:19:03.970 --> 00:19:06.030
So if the operator files for extension
00:19:06.030 --> 00:19:08.770
less than 21 days before expiration
00:19:08.770 --> 00:19:11.100
or after expiration of the permit,
00:19:11.100 --> 00:19:13.710
continues to flare during that time,
00:19:13.710 --> 00:19:17.400
during that request time and
request is ultimately denied,
00:19:17.400 --> 00:19:19.440
that is when the operator may be subject
00:19:19.440 --> 00:19:21.833
to some administrative penalties.
00:19:24.450 --> 00:19:25.760
We're on the last here on exceptions.
00:19:25.760 --> 00:19:27.690
Just a few more notes.
00:19:27.690 --> 00:19:32.100
Each filing or refile,
so not just the first one,
00:19:32.100 --> 00:19:35.070
must be accompanied by the
Statewide Rule 32 Data Sheet
00:19:35.070 --> 00:19:37.283
and that $375 fee.
00:19:38.650 --> 00:19:39.483
Another note.
00:19:39.483 --> 00:19:43.270
These are not transferable
upon a change in operatorship.
00:19:43.270 --> 00:19:46.870
And the operator has 90
days to refile the exception
00:19:46.870 --> 00:19:49.753
once the P-4 transfer has been approved.
00:19:50.720 --> 00:19:53.740
And then this last point
down here, this is updated.
00:19:53.740 --> 00:19:55.210
Not all of you may be aware of.
00:19:55.210 --> 00:19:57.310
So I wanna make
sure that I noted it here.
00:19:58.230 --> 00:20:01.930
The Railroad Commission is
no longer backdating exceptions.
00:20:01.930 --> 00:20:03.660
Operators are expected to comply
00:20:03.660 --> 00:20:05.320
with the filing time requirements
00:20:05.320 --> 00:20:08.223
set out in Statewide Rule 32.
00:20:10.647 --> 00:20:14.410
And so this is what hopefully
it would be very helpful
00:20:14.410 --> 00:20:16.800
to you all is filling
out that paperwork.
00:20:16.800 --> 00:20:20.320
And I know it's sort of
frustrating when you get it,
00:20:20.320 --> 00:20:24.130
you get an email from Terry Edwards.
00:20:24.130 --> 00:20:26.940
It comes back and says,
hey, I'm missing X, Y, and Z.
00:20:26.940 --> 00:20:28.380
Hopefully these next four slides
00:20:28.380 --> 00:20:30.367
will help you all avoid that
00:20:30.367 --> 00:20:34.170
and really see what we're looking for
00:20:34.170 --> 00:20:36.490
and what's important on our side
00:20:36.490 --> 00:20:39.120
when we're looking at the paperwork.
00:20:39.120 --> 00:20:41.010
So upon renewal, you wanna provide
00:20:41.010 --> 00:20:44.053
the existing Exception Number,
00:20:45.090 --> 00:20:47.240
include the Operator Number,
00:20:47.240 --> 00:20:51.400
provide the Railroad
Commission Lease ID if assigned.
00:20:51.400 --> 00:20:53.800
If not, then provide the
Drilling Permit Number.
00:20:55.670 --> 00:20:59.360
If applicable, provide the
Form H-9 Certificate Number
00:20:59.360 --> 00:21:03.960
and the hydrogen sulfide
concentration in ppm,
00:21:03.960 --> 00:21:04.860
parts per million.
00:21:05.750 --> 00:21:09.580
The requested flare rate
should be in mcf per day.
00:21:09.580 --> 00:21:12.970
So really try to avoid
mcf per month or per week
00:21:12.970 --> 00:21:14.190
or anything like that.
00:21:14.190 --> 00:21:16.910
It really should be in mcf per day.
00:21:16.910 --> 00:21:18.900
And also another big item here.
00:21:18.900 --> 00:21:20.890
And I hope I'll mention this again,
00:21:20.890 --> 00:21:25.700
but API numbers are not
helpful in processing at all.
00:21:25.700 --> 00:21:27.650
It's just not how our system is set up.
00:21:28.530 --> 00:21:31.960
Really what's more helpful
are the Drilling Permit Number,
00:21:31.960 --> 00:21:33.940
Commingle Number.
00:21:33.940 --> 00:21:35.910
And we'll get into
that a little bit more
00:21:35.910 --> 00:21:38.100
whenever I pull up the actual data sheet
00:21:38.100 --> 00:21:39.403
here in just a few slides.
00:21:41.440 --> 00:21:45.270
Just to, let's hear about
hearings and dockets.
00:21:45.270 --> 00:21:46.620
If the case goes to hearing,
00:21:46.620 --> 00:21:50.930
a Statewide Rule 32 Data
Sheet and fee are required.
00:21:50.930 --> 00:21:53.650
You also want to include
the flare exception number
00:21:53.650 --> 00:21:57.613
and the docket number of the
final order on the data sheet.
00:22:00.030 --> 00:22:00.930
So this is something
00:22:00.930 --> 00:22:03.930
that you'll definitely
wanna take note of.
00:22:03.930 --> 00:22:06.450
On the explanation
portion of the data sheet.
00:22:06.450 --> 00:22:10.050
This is something that
we're definitely giving,
00:22:10.050 --> 00:22:11.790
I don't know, I should
say more weight to.
00:22:11.790 --> 00:22:16.790
But we're really looking
at in much more detail,
00:22:17.960 --> 00:22:20.760
here's this explanation
portion of the data sheet.
00:22:20.760 --> 00:22:23.820
So generally, flaring is
considered to create waste.
00:22:23.820 --> 00:22:26.903
So if the operator claims
it's to prevent waste,
00:22:27.760 --> 00:22:29.210
they should really be prepared
00:22:29.210 --> 00:22:32.073
to give a detailed
explanation on the data sheet.
00:22:33.090 --> 00:22:35.490
So explanations need to
detail why the operations
00:22:35.490 --> 00:22:39.200
cannot be shut-in and how all legal uses
00:22:39.200 --> 00:22:43.620
for casinghead gas have been
investigated and exhausted.
00:22:43.620 --> 00:22:47.210
So some insufficient
explanation examples
00:22:47.210 --> 00:22:48.940
would be things like economics
00:22:48.940 --> 00:22:51.463
or the mineral owner might be damaged.
00:22:52.840 --> 00:22:54.340
So the Railroad Commission
00:22:54.340 --> 00:22:58.210
is not accepting simple
explanations such as these two
00:22:58.210 --> 00:23:02.140
I just listed above, since
there's really no loss of product
00:23:02.140 --> 00:23:05.820
through shut-in while
there is through flaring.
00:23:05.820 --> 00:23:08.350
So if the operator wants to
use economics as a reason,
00:23:08.350 --> 00:23:09.230
they need to provide
00:23:09.230 --> 00:23:12.623
a really detailed,
thoughtful explanation.
00:23:15.300 --> 00:23:20.300
Another item here that we
like to pay more attention to.
00:23:21.040 --> 00:23:23.990
We like the operator definitely
pay more attention to this.
00:23:23.990 --> 00:23:25.290
So it is important,
00:23:25.290 --> 00:23:29.550
is that the method of measurement
portion of the data sheet.
00:23:29.550 --> 00:23:32.810
So it must provide an actual
method of measurement.
00:23:32.810 --> 00:23:37.810
So Statewide Rule 32
does allow for estimations
00:23:37.860 --> 00:23:39.093
of the volumes.
00:23:40.040 --> 00:23:43.903
However, the method used
to estimate must be given.
00:23:45.880 --> 00:23:47.830
So can't really just say estimated.
00:23:47.830 --> 00:23:52.420
Really like the operator
go into further detail.
00:23:52.420 --> 00:23:56.063
And measured is not
an acceptable answer.
00:23:59.070 --> 00:24:02.160
So here's our data sheet.
00:24:02.160 --> 00:24:04.710
I just wanna make it
clear that all the data sheet
00:24:04.710 --> 00:24:08.540
needs to be filled out
to the best of your ability.
00:24:08.540 --> 00:24:09.910
One of the slide is to highlight
00:24:09.910 --> 00:24:14.640
some of the more important
items and commonly made mistakes
00:24:14.640 --> 00:24:17.900
that we see, some of the
reasons that we have to get back
00:24:17.900 --> 00:24:22.900
in touch with the operator
for further information.
00:24:23.220 --> 00:24:24.840
So when some of
these items are left blank,
00:24:24.840 --> 00:24:26.910
then we either need to find it ourselves
00:24:26.910 --> 00:24:28.800
or contact the operator.
00:24:28.800 --> 00:24:31.130
So really getting
these done the first time
00:24:31.130 --> 00:24:33.800
is extremely, extremely helpful for us
00:24:33.800 --> 00:24:36.080
and for the operator as well.
00:24:36.080 --> 00:24:39.410
So for example, if there's
an operator address,
00:24:39.410 --> 00:24:41.000
we may send it to the address
00:24:41.000 --> 00:24:43.760
that's associated with the P-5.
00:24:43.760 --> 00:24:47.060
So that P-5 address may or may not be
00:24:47.060 --> 00:24:49.683
where the operator
actually wants it sent.
00:24:50.840 --> 00:24:55.830
So the P-5 address is your
headquarters' in say Houston,
00:24:55.830 --> 00:24:58.450
but you really want us to go to,
00:24:58.450 --> 00:25:01.720
your field people are out in Midland.
00:25:01.720 --> 00:25:04.190
Well, it's gonna come to Houston
00:25:04.190 --> 00:25:06.180
because we didn't have
any other address to go by
00:25:06.180 --> 00:25:08.840
and then the operator
will have to then send it
00:25:08.840 --> 00:25:10.350
to their person in Midland
00:25:10.350 --> 00:25:12.933
or contact their person
in Midland somehow.
00:25:15.010 --> 00:25:18.280
As I stated previously, the
API number is not helpful
00:25:18.280 --> 00:25:20.810
in processing these exceptions.
00:25:20.810 --> 00:25:24.400
The Lease ID number,
the Drilling Permit Number,
00:25:24.400 --> 00:25:25.900
Commingle Permit Number,
00:25:25.900 --> 00:25:30.273
all of these are really
helpful types of ID,
00:25:31.130 --> 00:25:33.253
much more than the API number.
00:25:34.730 --> 00:25:37.700
Also be sure to include
the H-9 Certificate Number
00:25:37.700 --> 00:25:42.403
and the H2S concentration
in parts per million.
00:25:43.920 --> 00:25:46.730
The flare rate should
always be in mcf per day.
00:25:46.730 --> 00:25:50.690
I mentioned this before,
but it really is helpful for us,
00:25:50.690 --> 00:25:52.540
so we don't have to convert anything.
00:25:53.700 --> 00:25:56.550
And if everyone could just
do the same thing every time,
00:25:56.550 --> 00:25:58.063
it'd be really, really,
00:25:59.630 --> 00:26:02.093
the process would be
more uniform for everyone.
00:26:04.700 --> 00:26:07.533
So that per day is often missed there.
00:26:08.440 --> 00:26:10.260
And then, like I mentioned,
under explanation,
00:26:10.260 --> 00:26:13.410
try to be as specific as possible,
00:26:13.410 --> 00:26:15.600
such that if a plant shut down occurs,
00:26:15.600 --> 00:26:17.150
what is the name of that plant?
00:26:18.270 --> 00:26:22.170
But really wanna refer
back to that slide 24
00:26:22.170 --> 00:26:26.010
where we only covered
the explanation portion
00:26:26.010 --> 00:26:27.273
of this data sheet.
00:26:28.740 --> 00:26:31.170
Be sure to note also the return address
00:26:31.170 --> 00:26:32.803
at the bottom of the page.
00:26:36.470 --> 00:26:37.303
Okay.
00:26:37.303 --> 00:26:39.870
So we're back at our session description
00:26:39.870 --> 00:26:43.310
for the fourth and final time.
00:26:43.310 --> 00:26:46.330
So now we've covered
exemptions from the rule,
00:26:46.330 --> 00:26:49.770
authorized flaring and
venting and flaring exceptions.
00:26:49.770 --> 00:26:54.770
So now we will wrap up with
a bit of additional information.
00:26:56.340 --> 00:27:00.400
So there's an automated
system check for exceptions
00:27:00.400 --> 00:27:03.970
if flaring is indicated on
the production reports.
00:27:03.970 --> 00:27:06.090
So if flaring production
is not permitted,
00:27:06.090 --> 00:27:09.343
operator will automatically
be sent a Notice of Violation,
00:27:10.250 --> 00:27:12.560
a Notice of Intent to
Sever by certified mail
00:27:12.560 --> 00:27:15.520
30 days after that, and
then a severance letter,
00:27:15.520 --> 00:27:17.510
if compliance is not achieved.
00:27:17.510 --> 00:27:21.550
So let's just say process
that happens automatically.
00:27:21.550 --> 00:27:22.850
So you wanna make sure
you'd be showing everything
00:27:22.850 --> 00:27:24.400
on your production report that,
00:27:25.970 --> 00:27:28.283
you want to be permitted for.
00:27:30.960 --> 00:27:32.970
A permit extension maybe denied
00:27:32.970 --> 00:27:36.400
if no progress is made to
eliminate necessity for flaring.
00:27:36.400 --> 00:27:40.830
So this again, ties back
to our 45, 60, 90 day terms
00:27:40.830 --> 00:27:42.360
that we were discussing earlier.
00:27:42.360 --> 00:27:44.650
We wanna see that progress being made
00:27:44.650 --> 00:27:46.563
to hook up to a pipeline.
00:27:47.564 --> 00:27:51.980
If that's not happening, we
need detailed explanations
00:27:51.980 --> 00:27:54.123
as to why that's not possible.
00:27:56.360 --> 00:27:59.050
This is an important
notice to the industry
00:27:59.050 --> 00:28:01.370
in January of 2014.
00:28:01.370 --> 00:28:03.283
I won't sit there and read it to you.
00:28:04.244 --> 00:28:07.420
If an operator whose
application vent or flare gas
00:28:07.420 --> 00:28:09.750
is denied in whole or in part
00:28:09.750 --> 00:28:11.740
always has the right
to request a hearing
00:28:11.740 --> 00:28:13.210
before the Commission.
00:28:15.749 --> 00:28:17.670
These are some
frequently asked questions.
00:28:17.670 --> 00:28:21.680
I'm not gonna go through
all of these right now.
00:28:21.680 --> 00:28:24.140
But if you go to our homepage,
00:28:24.140 --> 00:28:26.410
in the search bar on
the top right hand corner,
00:28:26.410 --> 00:28:29.490
type in flaring frequently
asked questions,
00:28:29.490 --> 00:28:30.860
this list will populate.
00:28:30.860 --> 00:28:33.590
Simply click on any item
00:28:33.590 --> 00:28:36.893
and it will give you a
very detailed answer.
00:28:39.040 --> 00:28:44.040
This is simply for really your records,
00:28:44.500 --> 00:28:47.010
just to be helpful,
for your convenience.
00:28:47.010 --> 00:28:50.420
And same thing with this
is all of our district offices,
00:28:50.420 --> 00:28:52.310
phone numbers, addresses.
00:28:52.310 --> 00:28:54.360
So really here just
for your convenience.
00:28:56.450 --> 00:28:59.530
So my information
here is on the top right.
00:28:59.530 --> 00:29:01.363
Again, my name is Weston Cassady.
00:29:02.730 --> 00:29:07.550
And Terry Edwards, who
I'm sure many, if not all of you
00:29:07.550 --> 00:29:11.793
are very familiar with actually
retired a few weeks ago.
00:29:12.700 --> 00:29:14.680
So now you will want to refer
00:29:14.680 --> 00:29:17.810
to two of our newer
engineering unit members.
00:29:17.810 --> 00:29:19.130
Bill Heard.
00:29:19.130 --> 00:29:21.630
His information is down
there on the bottom right.
00:29:23.670 --> 00:29:26.360
He's more of a flaring technical expert.
00:29:26.360 --> 00:29:28.083
And then Lizana Villman.
00:29:29.950 --> 00:29:32.340
I will give you her phone
number here in just a moment.
00:29:32.340 --> 00:29:34.160
But she's gonna be processing
00:29:34.160 --> 00:29:37.503
a lot of the Statewide
Rule 32 Data Sheets.
00:29:39.580 --> 00:29:42.080
And her number, like I said,
her number isn't on here,
00:29:42.080 --> 00:29:44.190
but I'll give you just a
second to jot it down
00:29:44.190 --> 00:29:45.090
if you would like.
00:29:46.850 --> 00:29:51.850
And her number is 512-463-6899.
00:29:55.700 --> 00:30:00.700
Again, that's Lizana
Villman at 512-463-6899.
00:30:02.919 --> 00:30:05.500
We're really, really happy
to have both of these people
00:30:05.500 --> 00:30:08.810
helping us with flaring,
both great resources.
00:30:08.810 --> 00:30:10.010
And then the last of course,
00:30:10.010 --> 00:30:14.400
we have a Tim Speer who is
the engineering unit manager.
00:30:14.400 --> 00:30:17.170
And please feel free
to give any of us a call
00:30:20.298 --> 00:30:22.770
regarding Statewide
Rule 32 or anything else.
00:30:24.000 --> 00:30:28.890
So now I think Tim, we're
probably ready to get into Q&A.
00:30:30.390 --> 00:30:35.390
So I'm not sure if I can
be able to read through.
00:30:35.469 --> 00:30:36.740
Most of the questions
00:30:36.740 --> 00:30:39.140
have already been answered in the chat
00:30:39.140 --> 00:30:40.680
but we do have one raised hand.
00:30:40.680 --> 00:30:42.220
So I just want to acknowledge that
00:30:42.220 --> 00:30:44.920
and request that if you
have a question, go ahead
00:30:44.920 --> 00:30:46.750
and send it in in the chat.
00:30:46.750 --> 00:30:49.450
Or if you prefer to have
someone in the engineering unit
00:30:49.450 --> 00:30:52.630
give you a call, just
let us know that as well.
00:30:52.630 --> 00:30:54.920
And so we'll give you another minute
00:30:54.920 --> 00:30:56.383
to get your questions in.
00:31:00.160 --> 00:31:00.993
Yeah.
00:31:00.993 --> 00:31:03.080
I'm happy to back up to specific slides
00:31:03.080 --> 00:31:03.913
or anything else
00:31:03.913 --> 00:31:07.220
that I may have gone
too quickly through as well.
00:31:28.630 --> 00:31:31.433
Looks like we have a
few more questions coming in.
00:31:33.253 --> 00:31:35.660
So Tim, just let us know
00:31:35.660 --> 00:31:39.973
which ones you would like
to have Wes to answer live.
00:31:49.750 --> 00:31:50.683
So one question.
00:31:51.560 --> 00:31:55.693
Where can examples of the
completed approved forms be found?
00:31:57.500 --> 00:31:59.650
Completed,
approved, excuse me, forms.
00:31:59.650 --> 00:32:01.313
Completed approved forms.
00:32:03.070 --> 00:32:04.480
That is a good question.
00:32:04.480 --> 00:32:07.320
Just because I'm
not, like I said before,
00:32:07.320 --> 00:32:09.560
I'm not the one that processes these
00:32:09.560 --> 00:32:11.510
and does the actual data entry on them.
00:32:12.770 --> 00:32:16.960
Probably need to get with,
I would assume Tim Speer
00:32:16.960 --> 00:32:21.960
or maybe Bill Heard on
that to see what information
00:32:22.040 --> 00:32:25.363
we could actually release to someone.
00:32:26.520 --> 00:32:29.430
So we may have to do some
blacking out, that sort of thing
00:32:30.400 --> 00:32:32.100
on some of the data sheets.
00:32:32.100 --> 00:32:33.580
But I'm sure we could show you
00:32:33.580 --> 00:32:35.000
what a completed form looks like.
00:32:35.000 --> 00:32:39.330
I would just email the likes
of Tim Speer, Bill or myself
00:32:39.330 --> 00:32:42.713
and any of us would get
you some examples of those.
00:32:52.500 --> 00:32:54.370
Has RRC ever denied
00:32:54.370 --> 00:32:57.080
a Statewide Rule 32
application for exception?
00:32:57.080 --> 00:32:59.073
And if so, what was the reason?
00:33:01.580 --> 00:33:06.390
So again, I'm not
the one that processes these.
00:33:06.390 --> 00:33:09.190
Really with us, what I saw whenever,
00:33:09.190 --> 00:33:11.230
talking with Terry and whatnot
00:33:11.230 --> 00:33:16.090
was really just maybe
not a straight out denial,
00:33:16.090 --> 00:33:19.330
but were a lot of lacking information.
00:33:19.330 --> 00:33:22.240
Us having to either hunt
down too much information,
00:33:22.240 --> 00:33:23.970
or it's really not even possible
00:33:23.970 --> 00:33:26.100
for us to find all this information.
00:33:26.100 --> 00:33:30.560
But really just whenever
these permits would get rejected
00:33:30.560 --> 00:33:31.393
or sent back,
00:33:31.393 --> 00:33:36.053
it was due to a lack of
completeness in that data sheet,
00:33:37.950 --> 00:33:42.250
or they were requests
past that 180 days.
00:33:42.250 --> 00:33:45.050
And when those obviously
have to go directly to hearing.
00:33:47.410 --> 00:33:50.883
We may be able to get
more specific on that.
00:33:52.330 --> 00:33:54.060
Off the top of my head though,
00:33:54.060 --> 00:33:57.170
I wasn't the one that has
ever denied any of these.
00:33:57.170 --> 00:33:58.120
But I'm sure we could come up
00:33:58.120 --> 00:33:59.810
with some more specific examples
00:33:59.810 --> 00:34:02.583
if you were to shoot us an email.
00:34:06.467 --> 00:34:08.370
(mumbles)
just real quick here
00:34:08.370 --> 00:34:12.655
and I sent that because they
requested it be answered live.
00:34:12.655 --> 00:34:14.790
I'm Tim Speer.
00:34:14.790 --> 00:34:19.253
There have been a
few applications denied.
00:34:20.510 --> 00:34:22.550
The number one reason I know of
00:34:22.550 --> 00:34:27.550
is when an operator was
wanting to vent high H2S gas
00:34:29.010 --> 00:34:31.223
that can't safely be vented.
00:34:32.150 --> 00:34:34.130
And so that was denied.
00:34:34.130 --> 00:34:38.690
If they were to in turn put
that to flare and reapply,
00:34:38.690 --> 00:34:40.763
that would probably be approved.
00:34:43.500 --> 00:34:44.423
Thank you, Tim.
00:35:09.260 --> 00:35:10.730
Tim, are there
any other questions
00:35:10.730 --> 00:35:13.523
that you would like for
Weston to answer live?
00:35:14.510 --> 00:35:15.830
All right, we've got one.
00:35:15.830 --> 00:35:18.380
All four bullets in the
middle of the session
00:35:19.830 --> 00:35:22.910
do need to filled in on a
separate sheet for every permit.
00:35:22.910 --> 00:35:23.943
Is that correct?
00:35:26.316 --> 00:35:27.149
I'm sorry.
00:35:27.149 --> 00:35:28.910
One more time, if you don't mind?
00:35:28.910 --> 00:35:31.920
Do all four bullets in
the middle of this section
00:35:31.920 --> 00:35:35.907
need to be filled in on a
separate sheet for every permit?
00:35:44.170 --> 00:35:45.003
Yes.
00:35:45.003 --> 00:35:49.060
So this goes back to
this explanation portion.
00:35:49.060 --> 00:35:53.050
So really in the past
we had been getting
00:35:53.050 --> 00:35:55.800
really just like down here this one
00:35:55.800 --> 00:36:00.800
or really incomplete answers
that are not explaining,
00:36:00.990 --> 00:36:02.710
getting into all those questions.
00:36:02.710 --> 00:36:05.543
So I would say yes that they do.
00:36:06.670 --> 00:36:09.780
Really, we're really
looking for as much detail
00:36:09.780 --> 00:36:12.100
in that explanation as possible.
00:36:12.100 --> 00:36:17.100
We really wanna understand
why this is necessary right now.
00:36:19.090 --> 00:36:22.190
So yeah, and maybe, Tim,
maybe you can hop in here.
00:36:22.190 --> 00:36:23.940
But maybe if there's a reason
00:36:23.940 --> 00:36:26.880
you can't answer one of those questions,
00:36:26.880 --> 00:36:30.220
so maybe to the extent
that you think you might want,
00:36:30.220 --> 00:36:32.200
or excuse me, that we might want,
00:36:32.200 --> 00:36:35.580
maybe go into detail about
how you cannot answer that.
00:36:35.580 --> 00:36:40.310
So we just want you, or
the operator to, like I said,
00:36:40.310 --> 00:36:43.150
be as detailed as possible.
00:36:43.150 --> 00:36:45.250
And those four are just
really guidance points.
00:36:45.250 --> 00:36:46.760
Of course, we'd like you
to answer all four of those.
00:36:46.760 --> 00:36:48.860
But if you could even
go into more detail,
00:36:49.860 --> 00:36:50.793
there's really, as far as we see this,
00:36:50.793 --> 00:36:52.703
there's really no reason not to.
00:36:53.830 --> 00:36:54.903
It's very helpful.
00:37:07.470 --> 00:37:09.260
I need a flaring
permit for a lease
00:37:09.260 --> 00:37:12.630
but I'll be going to hearing
for a permanent exception.
00:37:12.630 --> 00:37:15.160
Will you grant a 180
day exception for this
00:37:15.160 --> 00:37:16.973
without needing to reapply?
00:37:19.390 --> 00:37:21.580
Tim, can I
defer to you on that one?
00:37:21.580 --> 00:37:23.163
I'm not a 100% sure.
00:37:28.740 --> 00:37:29.573
Okay.
00:37:29.573 --> 00:37:32.840
Generally, no.
00:37:32.840 --> 00:37:37.840
Generally the exceptions,
depending on the circumstances
00:37:37.870 --> 00:37:42.737
would be granted either for
45 or 98 or 90 days, I'm sorry.
00:37:50.024 --> 00:37:51.598
Yeah, this
is one thing that I--
00:37:51.598 --> 00:37:53.120
(Tim and Weston talking over each other)
00:37:53.120 --> 00:37:54.130
Sorry, go ahead, Tim.
00:37:54.130 --> 00:37:59.113
Okay, once you
file for the hearing,
00:38:00.750 --> 00:38:05.750
you're basically granted a period,
00:38:05.780 --> 00:38:09.270
you're basically granted
an extension to that.
00:38:09.270 --> 00:38:14.270
So if you're given 45 days or 90 days
00:38:15.110 --> 00:38:19.030
and you file for a hearing,
00:38:19.030 --> 00:38:23.880
then that extension is
actually going to continue
00:38:23.880 --> 00:38:25.253
until your hearing.
00:38:28.346 --> 00:38:29.250
You're right.
00:38:29.250 --> 00:38:31.810
And I was just gonna
interject that yeah, we don't,
00:38:31.810 --> 00:38:35.780
if you're asking if you can
just upfront request 180 days,
00:38:35.780 --> 00:38:37.520
I don't see that happening.
00:38:37.520 --> 00:38:41.287
Like Tim said, 45, 60, 90,
you request for the hearing
00:38:41.287 --> 00:38:43.236
and then it can get extended out.
00:38:43.236 --> 00:38:44.753
That's my understanding.
00:39:18.273 --> 00:39:21.106
Do you have anything else, Tim or?
00:39:35.930 --> 00:39:38.000
I guess I'll
just, for time's sake,
00:39:38.000 --> 00:39:40.650
I'll try and answer some of these live
00:39:40.650 --> 00:39:45.390
that I can probably
answer it a little easier.
00:39:45.390 --> 00:39:47.033
So we have a question.
00:39:48.440 --> 00:39:52.440
Will flaring approvals ever
be put on the RRC website
00:39:52.440 --> 00:39:54.253
like drilling permits?
00:39:55.280 --> 00:39:59.690
We're currently working
on going to an online system
00:39:59.690 --> 00:40:03.030
for Rule 32 exceptions.
00:40:03.030 --> 00:40:07.200
Once that is in place,
I think it's possible
00:40:07.200 --> 00:40:11.483
that the approvals will be put online.
00:40:12.810 --> 00:40:15.200
We're also working on an overhaul
00:40:15.200 --> 00:40:17.680
to our overall computer system.
00:40:17.680 --> 00:40:21.590
So I think the move is going to be
00:40:21.590 --> 00:40:24.690
to having more
information available online.
00:40:24.690 --> 00:40:26.853
So I think it's quite possible.
00:40:31.920 --> 00:40:34.177
Let me see, more questions.
00:40:37.300 --> 00:40:40.880
What about a situation where
there's low oil production,
00:40:40.880 --> 00:40:45.170
making 50 to 70 barrels of oil per day
00:40:45.170 --> 00:40:48.267
in the facility gathering a few wells
00:40:48.267 --> 00:40:51.540
and there does not
appear to be any gas line
00:40:51.540 --> 00:40:54.180
ever coming to the area?
00:40:54.180 --> 00:40:57.580
With gas at 150 mcf per day
00:40:57.580 --> 00:41:02.580
and H2S at 10,000 parts
per million gas is being flared.
00:41:05.350 --> 00:41:09.740
So I'm guessing are you,
00:41:09.740 --> 00:41:14.633
they're asking if the permanent
exception can be granted.
00:41:15.600 --> 00:41:18.010
That would have to be
done through hearing.
00:41:18.010 --> 00:41:22.187
Administratively, we
can grant up to 180 days.
00:41:22.187 --> 00:41:25.563
And anything beyond
that has to go to hearing.
00:41:36.020 --> 00:41:39.200
Just a suggestion,
could we as operators,
00:41:39.200 --> 00:41:41.720
maybe have a Q&A section set up
00:41:41.720 --> 00:41:46.720
to help us get through some
common struggles we might share.
00:41:47.650 --> 00:41:49.633
I think that could be done.
00:41:53.880 --> 00:41:57.580
We were recently told
that that long of our flaring
00:41:57.580 --> 00:42:00.083
needs to be added to the exception.
00:42:01.340 --> 00:42:04.440
Should that be added to the data sheet?
00:42:04.440 --> 00:42:09.440
Yes, we are starting to
request that long data.
00:42:16.470 --> 00:42:19.730
It's really voluntary at this point,
00:42:19.730 --> 00:42:21.043
but it is helpful.
00:42:23.620 --> 00:42:28.550
We are revising the
Statewide Rule 32 Data Sheet.
00:42:28.550 --> 00:42:29.930
And the new data sheet
00:42:29.930 --> 00:42:32.670
will probably require that information.
00:42:32.670 --> 00:42:36.930
That's a work in progress
so I can't say for sure.
00:42:36.930 --> 00:42:40.810
But it is information we'd like to have.
00:42:40.810 --> 00:42:43.310
It would be very helpful
if you could go ahead
00:42:43.310 --> 00:42:46.903
and add it to the current data sheet.
00:42:49.280 --> 00:42:50.113
Question.
00:42:50.113 --> 00:42:52.770
How often do you check a flare
00:42:52.770 --> 00:42:56.033
if an operator has an expired date?
00:43:00.131 --> 00:43:02.620
I'm assuming they're
asking how often we check
00:43:02.620 --> 00:43:05.703
to see if they're still flaring.
00:43:06.870 --> 00:43:10.600
We are working to check more often
00:43:10.600 --> 00:43:15.600
with our production
records against flare permits
00:43:16.540 --> 00:43:19.503
and expired flare permits.
00:43:20.790 --> 00:43:23.613
There's not a set schedule for that.
00:43:24.520 --> 00:43:28.460
I can tell you we are
having inspectors in the field
00:43:28.460 --> 00:43:30.453
check flares more often.
00:43:33.430 --> 00:43:36.690
So I can't really say how often,
00:43:36.690 --> 00:43:40.813
but that's probably going to
be more often than in the past.
00:43:48.159 --> 00:43:48.992
All right.
00:43:48.992 --> 00:43:50.700
It doesn't look like we
have any other questions
00:43:50.700 --> 00:43:51.533
at this time.
00:43:51.533 --> 00:43:54.700
So we've reached the
conclusion of our webinar.
00:43:54.700 --> 00:43:56.700
There is an evaluation available
00:43:56.700 --> 00:43:59.870
on the RRC regulatory webinars page
00:43:59.870 --> 00:44:01.950
on the Railroad
Commission of Texas website.
00:44:01.950 --> 00:44:03.370
And we would greatly appreciate you
00:44:03.370 --> 00:44:05.499
taking the time to fill it out.
00:44:05.499 --> 00:44:07.600
With that, we'll wrap up.
00:44:07.600 --> 00:44:09.850
Thank you everyone
so much for participating.
00:44:11.240 --> 00:44:12.740
Thank you everyone.