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Our presenter this afternoon is Weston Cassady
of the engineering unit
and the technical permitting department
of the oil and gas division.
All right, let's go ahead and get started.
Weston, whenever you're ready.
Weston: All right, good afternoon, everyone.
I really appreciate everyone taking the time
to attend this presentation.
My name is Weston Cassady,
and I'm part of the engineering unit
here at the Railroad Commission.
The engineering unit, for those of you that don't know
is part of the technical permitting division of oil and gas.
I generally review completion, statement rule 10 requests,
field transfers and new field discoveries.
But today I'll be covering Statewide Rule 32,
which deals with venting and flaring.
And for those of you that attended last year's conference
almost looked similar,
but I have some updated flaring statistics
and I'll be covering
some of the new administrative procedures
that we have been implementing.
Tim Speer, the engineering unit manager,
will be handling Q&A during, after the presentation.
So please feel free to type any questions as we go along.
You're welcome to hold them to the end as well.
I'll be sure to go through all the questions,
answered or not, at the end of the presentation
so that everyone gets a chance to see them.
I'll go ahead and get started with a slide
that I'm sure everyone has memorized by now.
So this is our mission here at the Railroad Commission,
is to serve Texas by our stewardship of natural resources
and the environment,
our concern for personal and community safety
and our supported enhanced development and economic vitality
for the benefit of Texans.
So before we get into the rule itself,
I'd like to give a bit of background
and sort of set the stage for the rule.
And the actual title of Statewide Rule 32
is the Gas Well Gas and Casinghead Gas
Shall Be Utilized for Legal Purposes.
So if you read the table
showing the number of flaring permits issued per fiscal year
and to put these numbers into context,
as of August 31st, 2019,
Texas had almost 265,000 producing oil and gas wells.
So venting and flaring really only involves
a pretty small fraction of the state's oil wells.
As you can see, in 2010, 2011, we had a substantial increase
in the number of permits issued up until about 2014,
where it stabilized through 2018.
And then in 2019, we did see a large number of flare permits
issued once again.
This graph ties directly into our previous table.
The black line at the top shows gas produced
in billion cubic feet and uses the left y axis.
It goes from zero bcf to 900 bcf.
That purple line down at the bottom
shows the percent of total gas flared.
And that's gonna use the right y axis.
It goes from zero to 7%.
And then that blue line they see there in the middle,
that's the percent of casinghead gas flared,
and that uses the right y axis as well.
And for those of you that aren't aware,
the casinghead gas is gas that is produced
from a producing oil well.
So what this graph is showing us is the rapid rise
in percentage of casinghead gas flared in 2010,
all the way through 2013,
sort of like our table was showing us
as far as the increase in permits.
So the total amount of gas produced
did not dramatically increase along with this.
In part, what this can be attributed to are the shell plays
out in the Eagle Ford which produce oil,
but also obviously a significant amount of gas.
And really, the reason I'm saying all this
and going through this background
is because Rule 32 was created
to handle the amount of permits
we were seeing really before 2011,
before that initial spike.
So just sort of wanted to set the stage
for exactly how and why we apply the rule
the way that we do.
And as we go along,
I'll do my best to explain and highlight examples of this.
And just another note in 2015 where you see that decrease,
as many of you are aware,
that's when the oil prices tanked and productions slipped.
So I just really wanted to give a closer look
at some of the data just from this last year.
So again, in black are the total gas produced in bcf.
We have total liquids in green and million barrels of oil.
And then we have total gas flared in bcf shown in the gray,
that really small line down there at the bottom,
along the x axis.
And then last, we have gas flared
as a percentage of total gas
represented by the purple line,
not utilized at zero to 2.5 percentage on the right y axis.
So it's just giving you a little bit closer look
toward really the end of our graph here in slide five.
So just a little introduction here.
Gas must be used for lease operations
or sold if it can be readily measured by devices, meters
routinely used in the operations of oil wells, gas wells,
gas gathering systems or gas plants.
So this is session description.
We will see it four times.
This is really just an outline
of what we'll be discussing today.
So like I said,
we have four main points that we wanna cover.
So first, we're gonna go over exemptions from the rule.
This is when Statewide Rule 32 does not apply.
So a.k.a, when there's no metering required.
The second topic we'll go over today
is authorized flaring and venting.
So when flaring is allowed without a permit
under special conditions.
So under this conditions, all gasses are metered
and reported on the production report.
Third item we'll go over are flaring exceptions.
We'll discuss what is required for an exception
and what it actually does for the operator.
And then fourth, we'll go over
some, a little bit of additional helpful information.
So I'll go ahead and hop into exemptions from the rule.
And just to note, the handout for this presentation
contains all the slides.
I know it's not technically a handout this time.
But the notes on the bottom of the slides
will address where to find the information within the rule.
So for example, the information on this slide
is addressed in Statewide Rule 32 D-1, A through D.
So it should reference exactly where this information is.
If say you have a question about this,
as you read through it at another time or reference it,
you can reference exactly where I'm getting this information
from the rule.
So for the next slide,
it would be Statewide 32 D-1, D through G.
Okay.
So the following are examples of when Statewide Rule 32
does not apply and no metering is required.
So the first would be tank vapors
from crude oil storage tanks,
gas well condensate storage tanks
and salt water storage tanks.
The second example where no metering is required
is fugitive emissions of gas.
The third is amine treaters, glycol dehydrator, excuse me,
glycol dehydrator flash tanks and, or reboiler emissions.
And the fourth example is blowdown gas
from gas handling equipment for construction,
maintenance and repair.
Continuing on with exemptions.
We have our fifth example here
where no metering is required.
That'd be gas purged from compressor cylinders
or other gas handling equipment for startup.
And then sixth, we have gas released
either at a well site during drilling operations
prior to the completion date of the well.
This must be separated from drilling fluids
using a mud-gas separator or mud degasser.
Or gas released during completion or re-completion.
And just a note about this,
the Commission may also not require metering
but determines that flaring is required for safety reasons.
And so you'll see that come up a few times
throughout this presentation.
Okay.
So onto our second item here.
We're gonna look at authorized flaring and venting.
So the Commission may require flaring of releases of gas
not readily measured if the Commission determines
that flaring is required for safety reasons.
Like I just mentioned, high concentrations of H2S
or something like that.
All gas releases greater than 24 hours in duration
shall be burned in a flare if the gas can be burned safely.
And then all gas releases of 24 hours or less in duration
may be vented to the air
if not required to be flared for safety reasons.
And so if you're ever unsure, the thing to do automatically
is contact the district office for verification,
if you're unsure.
So continuing on with gas releases authorized by our rule.
Authorized gas releases during production operations
must be measured, a.k.a metered or be reported
on monthly production reports.
So flaring beyond the limits set in the following scenarios
requires an exception to be granted.
So produced gas is not to exceed 10 producing days
after initial completion, re-completion in other field
or workover in the same field.
So examples of workover operations include perforating,
stimulating, deepening, clean up, oil maintenance,
or some other repair operations.
Also gas that must be unloaded from a well
may be vented up to 24 hours in one continuous event
or two 72 cumulative hours in one month.
So 24 and one of them, 72 cumulative in one month.
Continuing on with gas releases authorized by the rule.
If gas from at lease production facility may be released
up to 24 hours in the event of a pipeline
or gas plant upset.
So that would be our sort of one continuous event.
Also gas contained in waste stream from molecular sieves
or membrane gas treatment units,
provided at least 85% of the inlet gas is recovered
and directed towards legal use.
So molecular sieves or membrane gas treatment units
are used to remove carbon oxide, hydrogen sulfide
and other contaminants from that gas stream.
Also, we have low pressure separator gas, up to 15 mcfd
for gas wells and then 50 for oil leases
or co-mingled points.
And this has gas that must pass through a separator,
heater-treater, or other low pressure equipment
prior to its release.
Sorry, I got a drink of water there.
Okay, so again, we see may be released for up to 24 hours
in the event of a pipeline or gas plant upset.
And you wanna notify your local district office
as soon as reasonably possible after the release begins.
So again, you'll see this as a common theme.
If you're unsure, just contact your district office
and they will help you through that.
If a gas plant operator presents information
that shows necessity of release is justified
beyond that 24 hours,
the operator may continue to flare gas.
Operator must file exception request within one business day
after the first 24 hours of release.
So examples of situations that may qualify for an exception
are gas gathering system or gas plant construction,
repairs, maintenance, gas plant turnaround,
emergency situations like fire or something like that.
Okay, so we're onto our third topic,
which is probably the one
most of y'all are really interested in.
This is flaring exceptions
and the actual permitting process.
So I just wanna start by saying a flare permit
is an exception to the Statewide rule.
Application is made on the Statewide Rule 32 Data Sheet,
which can be downloaded from our website
and I have it there.
I'm sure all of you have been there many times.
Also there's a $375 fee per gas well, oil lease
or commingled vent/flare point.
This is something that we've seen a lot
where say that there is, I don't know how many,
however many wells connected to a commingled point.
You don't have to have a fee for every single one of those.
It can be per gas well, oil lease
or commingled vent/flare point.
And also there is a special situation
that I won't really go into too much detail
but I do encourage you to read over it
and I've referenced it in the notes,
specific item in Statewide Rule 32.
Also the exception maybe sent by fax or email
provided a signed original request,
accompanied with fee, is received by the Commission
within three business days.
Also copy the direct link
to the Statewide Rule 32 Data Sheet in the notes.
Another way to get there
if for whatever reason you can't type out
this really long link, if you go to our website,
go to Oil and Gas and then go to oil and gas forms.
And if you go to the,
it's a category arranged by purpose of filing
and you scroll all the way that bottom,
I believe it's either the last or second to last form
at the very bottom.
So we're continuing on with exceptions.
Our current practice for administrative exceptions
are 45 to 60 day terms for pipeline capacity issues
and system upsets,
or 90 day terms for lack of a pipeline.
So these may be renewed administratively
for up to a total of 180 days.
Exceptions for anything over 180 days
can only be granted through a hearing
with a final order signed by the Commission.
And so like I prefaced with the table and the graph,
the rule was really not initially made
to accommodate the large amount of permits
that we are currently receiving,
the requests that we are receiving.
So this is why in the rules, you will not see anything
regarding the 45 to 60 day or 90 day terms.
These short terms are there to ensure progress is being made
towards connecting to an actual pipeline.
So understand it's not always possible,
but the focus here is that we see an intention to remediate
between the first and second exceptions.
Okay.
Yeah, a little bit more information down there
at the bottom of what information is required.
Continuing on with exceptions.
These may be indefinitely approved administratively
with adequate justification if less than 50 mcf per day.
So the rule states requests for exceptions
for more than 180 days
and for volumes greater than 50 mcf of hydrocarbon gas
per day shall be granted all in the final order
signed by the Commission, like we just discussed.
So for these administration approvals,
these indefinite administration approvals,
there is more documentation required, listed right here.
Obviously the Statewide Rule 32 Data Sheet.
Other than that, is we'd require a cost benefit analysis,
a map showing the nearest pipeline capable of accepting gas.
And this goes back to us wanting to see an intention
to remediate the lack of hooking up to a pipeline.
And then also we need an estimate of gas reserves.
Four of the five here on exceptions.
If additional time is requested,
the operator must refile within 21 days
before the expiration of the exist,
excuse me, existing permit.
So if refiled within 21 days,
the operator is authorized to continue flaring or venting
until final approval or denial
of the requested permit extension.
So if the operator files for extension
less than 21 days before expiration
or after expiration of the permit,
continues to flare during that time,
during that request time and request is ultimately denied,
that is when the operator may be subject
to some administrative penalties.
We're on the last here on exceptions.
Just a few more notes.
Each filing or refile, so not just the first one,
must be accompanied by the Statewide Rule 32 Data Sheet
and that $375 fee.
Another note.
These are not transferable upon a change in operatorship.
And the operator has 90 days to refile the exception
once the P-4 transfer has been approved.
And then this last point down here, this is updated.
Not all of you may be aware of.
So I wanna make sure that I noted it here.
The Railroad Commission is no longer backdating exceptions.
Operators are expected to comply
with the filing time requirements
set out in Statewide Rule 32.
And so this is what hopefully it would be very helpful
to you all is filling out that paperwork.
And I know it's sort of frustrating when you get it,
you get an email from Terry Edwards.
It comes back and says, hey, I'm missing X, Y, and Z.
Hopefully these next four slides
will help you all avoid that
and really see what we're looking for
and what's important on our side
when we're looking at the paperwork.
So upon renewal, you wanna provide
the existing Exception Number,
include the Operator Number,
provide the Railroad Commission Lease ID if assigned.
If not, then provide the Drilling Permit Number.
If applicable, provide the Form H-9 Certificate Number
and the hydrogen sulfide concentration in ppm,
parts per million.
The requested flare rate should be in mcf per day.
So really try to avoid mcf per month or per week
or anything like that.
It really should be in mcf per day.
And also another big item here.
And I hope I'll mention this again,
but API numbers are not helpful in processing at all.
It's just not how our system is set up.
Really what's more helpful are the Drilling Permit Number,
Commingle Number.
And we'll get into that a little bit more
whenever I pull up the actual data sheet
here in just a few slides.
Just to, let's hear about hearings and dockets.
If the case goes to hearing,
a Statewide Rule 32 Data Sheet and fee are required.
You also want to include the flare exception number
and the docket number of the final order on the data sheet.
So this is something
that you'll definitely wanna take note of.
On the explanation portion of the data sheet.
This is something that we're definitely giving,
I don't know, I should say more weight to.
But we're really looking at in much more detail,
here's this explanation portion of the data sheet.
So generally, flaring is considered to create waste.
So if the operator claims it's to prevent waste,
they should really be prepared
to give a detailed explanation on the data sheet.
So explanations need to detail why the operations
cannot be shut-in and how all legal uses
for casinghead gas have been investigated and exhausted.
So some insufficient explanation examples
would be things like economics
or the mineral owner might be damaged.
So the Railroad Commission
is not accepting simple explanations such as these two
I just listed above, since there's really no loss of product
through shut-in while there is through flaring.
So if the operator wants to use economics as a reason,
they need to provide
a really detailed, thoughtful explanation.
Another item here that we like to pay more attention to.
We like the operator definitely pay more attention to this.
So it is important,
is that the method of measurement portion of the data sheet.
So it must provide an actual method of measurement.
So Statewide Rule 32 does allow for estimations
of the volumes.
However, the method used to estimate must be given.
So can't really just say estimated.
Really like the operator go into further detail.
And measured is not an acceptable answer.
So here's our data sheet.
I just wanna make it clear that all the data sheet
needs to be filled out to the best of your ability.
One of the slide is to highlight
some of the more important items and commonly made mistakes
that we see, some of the reasons that we have to get back
in touch with the operator for further information.
So when some of these items are left blank,
then we either need to find it ourselves
or contact the operator.
So really getting these done the first time
is extremely, extremely helpful for us
and for the operator as well.
So for example, if there's an operator address,
we may send it to the address
that's associated with the P-5.
So that P-5 address may or may not be
where the operator actually wants it sent.
So the P-5 address is your headquarters' in say Houston,
but you really want us to go to,
your field people are out in Midland.
Well, it's gonna come to Houston
because we didn't have any other address to go by
and then the operator will have to then send it
to their person in Midland
or contact their person in Midland somehow.
As I stated previously, the API number is not helpful
in processing these exceptions.
The Lease ID number, the Drilling Permit Number,
Commingle Permit Number,
all of these are really helpful types of ID,
much more than the API number.
Also be sure to include the H-9 Certificate Number
and the H2S concentration in parts per million.
The flare rate should always be in mcf per day.
I mentioned this before, but it really is helpful for us,
so we don't have to convert anything.
And if everyone could just do the same thing every time,
it'd be really, really,
the process would be more uniform for everyone.
So that per day is often missed there.
And then, like I mentioned, under explanation,
try to be as specific as possible,
such that if a plant shut down occurs,
what is the name of that plant?
But really wanna refer back to that slide 24
where we only covered the explanation portion
of this data sheet.
Be sure to note also the return address
at the bottom of the page.
Okay.
So we're back at our session description
for the fourth and final time.
So now we've covered exemptions from the rule,
authorized flaring and venting and flaring exceptions.
So now we will wrap up with a bit of additional information.
So there's an automated system check for exceptions
if flaring is indicated on the production reports.
So if flaring production is not permitted,
operator will automatically be sent a Notice of Violation,
a Notice of Intent to Sever by certified mail
30 days after that, and then a severance letter,
if compliance is not achieved.
So let's just say process that happens automatically.
So you wanna make sure you'd be showing everything
on your production report that,
you want to be permitted for.
A permit extension maybe denied
if no progress is made to eliminate necessity for flaring.
So this again, ties back to our 45, 60, 90 day terms
that we were discussing earlier.
We wanna see that progress being made
to hook up to a pipeline.
If that's not happening, we need detailed explanations
as to why that's not possible.
This is an important notice to the industry
in January of 2014.
I won't sit there and read it to you.
If an operator whose application vent or flare gas
is denied in whole or in part
always has the right to request a hearing
before the Commission.
These are some frequently asked questions.
I'm not gonna go through all of these right now.
But if you go to our homepage,
in the search bar on the top right hand corner,
type in flaring frequently asked questions,
this list will populate.
Simply click on any item
and it will give you a very detailed answer.
This is simply for really your records,
just to be helpful, for your convenience.
And same thing with this is all of our district offices,
phone numbers, addresses.
So really here just for your convenience.
So my information here is on the top right.
Again, my name is Weston Cassady.
And Terry Edwards, who I'm sure many, if not all of you
are very familiar with actually retired a few weeks ago.
So now you will want to refer
to two of our newer engineering unit members.
Bill Heard.
His information is down there on the bottom right.
He's more of a flaring technical expert.
And then Lizana Villman.
I will give you her phone number here in just a moment.
But she's gonna be processing
a lot of the Statewide Rule 32 Data Sheets.
And her number, like I said, her number isn't on here,
but I'll give you just a second to jot it down
if you would like.
And her number is 512-463-6899.
Again, that's Lizana Villman at 512-463-6899.
We're really, really happy to have both of these people
helping us with flaring, both great resources.
And then the last of course,
we have a Tim Speer who is the engineering unit manager.
And please feel free to give any of us a call
regarding Statewide Rule 32 or anything else.
So now I think Tim, we're probably ready to get into Q&A.
So I'm not sure if I can be able to read through.
Host: Most of the questions
have already been answered in the chat
but we do have one raised hand.
So I just want to acknowledge that
and request that if you have a question, go ahead
and send it in in the chat.
Or if you prefer to have someone in the engineering unit
give you a call, just let us know that as well.
And so we'll give you another minute
to get your questions in.
Weston: Yeah.
I'm happy to back up to specific slides
or anything else
that I may have gone too quickly through as well.
Host: Looks like we have a few more questions coming in.
So Tim, just let us know
which ones you would like to have Wes to answer live.
So one question.
Where can examples of the completed approved forms be found?
Weston: Completed, approved, excuse me, forms.
Completed approved forms.
That is a good question.
Just because I'm not, like I said before,
I'm not the one that processes these
and does the actual data entry on them.
Probably need to get with, I would assume Tim Speer
or maybe Bill Heard on that to see what information
we could actually release to someone.
So we may have to do some blacking out, that sort of thing
on some of the data sheets.
But I'm sure we could show you
what a completed form looks like.
I would just email the likes of Tim Speer, Bill or myself
and any of us would get you some examples of those.
Host: Has RRC ever denied
a Statewide Rule 32 application for exception?
And if so, what was the reason?
Weston: So again, I'm not the one that processes these.
Really with us, what I saw whenever,
talking with Terry and whatnot
was really just maybe not a straight out denial,
but were a lot of lacking information.
Us having to either hunt down too much information,
or it's really not even possible
for us to find all this information.
But really just whenever these permits would get rejected
or sent back,
it was due to a lack of completeness in that data sheet,
or they were requests past that 180 days.
And when those obviously have to go directly to hearing.
We may be able to get more specific on that.
Off the top of my head though,
I wasn't the one that has ever denied any of these.
But I'm sure we could come up
with some more specific examples
if you were to shoot us an email.
Tim: (mumbles) just real quick here
and I sent that because they requested it be answered live.
I'm Tim Speer.
There have been a few applications denied.
The number one reason I know of
is when an operator was wanting to vent high H2S gas
that can't safely be vented.
And so that was denied.
If they were to in turn put that to flare and reapply,
that would probably be approved.
Weston: Thank you, Tim.
Host: Tim, are there any other questions
that you would like for Weston to answer live?
All right, we've got one.
All four bullets in the middle of the session
do need to filled in on a separate sheet for every permit.
Is that correct?
Weston: I'm sorry.
One more time, if you don't mind?
Host: Do all four bullets in the middle of this section
need to be filled in on a separate sheet for every permit?
Weston: Yes.
So this goes back to this explanation portion.
So really in the past we had been getting
really just like down here this one
or really incomplete answers that are not explaining,
getting into all those questions.
So I would say yes that they do.
Really, we're really looking for as much detail
in that explanation as possible.
We really wanna understand why this is necessary right now.
So yeah, and maybe, Tim, maybe you can hop in here.
But maybe if there's a reason
you can't answer one of those questions,
so maybe to the extent that you think you might want,
or excuse me, that we might want,
maybe go into detail about how you cannot answer that.
So we just want you, or the operator to, like I said,
be as detailed as possible.
And those four are just really guidance points.
Of course, we'd like you to answer all four of those.
But if you could even go into more detail,
there's really, as far as we see this,
there's really no reason not to.
It's very helpful.
Host: I need a flaring permit for a lease
but I'll be going to hearing for a permanent exception.
Will you grant a 180 day exception for this
without needing to reapply?
Weston: Tim, can I defer to you on that one?
I'm not a 100% sure.
Tim: Okay.
Generally, no.
Generally the exceptions, depending on the circumstances
would be granted either for 45 or 98 or 90 days, I'm sorry.
Weston: Yeah, this is one thing that I--
(Tim and Weston talking over each other)
Sorry, go ahead, Tim.
Tim: Okay, once you file for the hearing,
you're basically granted a period,
you're basically granted an extension to that.
So if you're given 45 days or 90 days
and you file for a hearing,
then that extension is actually going to continue
until your hearing.
Weston: You're right.
And I was just gonna interject that yeah, we don't,
if you're asking if you can just upfront request 180 days,
I don't see that happening.
Like Tim said, 45, 60, 90, you request for the hearing
and then it can get extended out.
That's my understanding.
Do you have anything else, Tim or?
Tim: I guess I'll just, for time's sake,
I'll try and answer some of these live
that I can probably answer it a little easier.
So we have a question.
Will flaring approvals ever be put on the RRC website
like drilling permits?
We're currently working on going to an online system
for Rule 32 exceptions.
Once that is in place, I think it's possible
that the approvals will be put online.
We're also working on an overhaul
to our overall computer system.
So I think the move is going to be
to having more information available online.
So I think it's quite possible.
Let me see, more questions.
What about a situation where there's low oil production,
making 50 to 70 barrels of oil per day
in the facility gathering a few wells
and there does not appear to be any gas line
ever coming to the area?
With gas at 150 mcf per day
and H2S at 10,000 parts per million gas is being flared.
So I'm guessing are you,
they're asking if the permanent exception can be granted.
That would have to be done through hearing.
Administratively, we can grant up to 180 days.
And anything beyond that has to go to hearing.
Just a suggestion, could we as operators,
maybe have a Q&A section set up
to help us get through some common struggles we might share.
I think that could be done.
We were recently told that that long of our flaring
needs to be added to the exception.
Should that be added to the data sheet?
Yes, we are starting to request that long data.
It's really voluntary at this point,
but it is helpful.
We are revising the Statewide Rule 32 Data Sheet.
And the new data sheet
will probably require that information.
That's a work in progress so I can't say for sure.
But it is information we'd like to have.
It would be very helpful if you could go ahead
and add it to the current data sheet.
Question.
How often do you check a flare
if an operator has an expired date?
I'm assuming they're asking how often we check
to see if they're still flaring.
We are working to check more often
with our production records against flare permits
and expired flare permits.
There's not a set schedule for that.
I can tell you we are having inspectors in the field
check flares more often.
So I can't really say how often,
but that's probably going to be more often than in the past.
Host: All right.
It doesn't look like we have any other questions
at this time.
So we've reached the conclusion of our webinar.
There is an evaluation available
on the RRC regulatory webinars page
on the Railroad Commission of Texas website.
And we would greatly appreciate you
taking the time to fill it out.
With that, we'll wrap up.
Thank you everyone so much for participating.
Weston: Thank you everyone.