WEBVTT 00:00:00.350 --> 00:00:02.800 Brought to you by adminmonitor.com. 00:01:05.510 --> 00:01:06.740 Good afternoon and thank you 00:01:06.740 --> 00:01:08.380 for attending this webinar. 00:01:08.380 --> 00:01:11.060 You may submit questions throughout the presentation 00:01:11.060 --> 00:01:12.770 by clicking the Q&A button 00:01:12.770 --> 00:01:15.390 in the center of the bottom of your window. 00:01:15.390 --> 00:01:17.650 You will see both the questions and responses 00:01:17.650 --> 00:01:19.210 after they have been answered. 00:01:19.210 --> 00:01:21.100 Some questions may be held for answer 00:01:21.100 --> 00:01:23.470 until the end of the presentation. 00:01:23.470 --> 00:01:26.670 Presentations and webinar recordings are all available 00:01:26.670 --> 00:01:29.950 by navigating to RRC regulatory webinars 00:01:29.950 --> 00:01:32.760 from the oil and gas workshops and seminars page 00:01:32.760 --> 00:01:35.690 on the Railroad Commission of Texas website. 00:01:35.690 --> 00:01:38.230 Our presenter this afternoon is Weston Cassady 00:01:38.230 --> 00:01:39.430 of the engineering unit 00:01:39.430 --> 00:01:41.040 and the technical permitting department 00:01:41.040 --> 00:01:42.850 of the oil and gas division. 00:01:42.850 --> 00:01:44.730 All right, let's go ahead and get started. 00:01:44.730 --> 00:01:46.230 Weston, whenever you're ready. 00:01:47.209 --> 00:01:48.703 All right, good afternoon, everyone. 00:01:48.703 --> 00:01:50.500 I really appreciate everyone taking the time 00:01:50.500 --> 00:01:52.850 to attend this presentation. 00:01:52.850 --> 00:01:54.290 My name is Weston Cassady, 00:01:54.290 --> 00:01:56.210 and I'm part of the engineering unit 00:01:56.210 --> 00:01:58.050 here at the Railroad Commission. 00:01:58.050 --> 00:02:00.090 The engineering unit, for those of you that don't know 00:02:00.090 --> 00:02:03.793 is part of the technical permitting division of oil and gas. 00:02:05.460 --> 00:02:08.250 I generally review completion, statement rule 10 requests, 00:02:08.250 --> 00:02:11.140 field transfers and new field discoveries. 00:02:11.140 --> 00:02:13.170 But today I'll be covering Statewide Rule 32, 00:02:13.170 --> 00:02:15.450 which deals with venting and flaring. 00:02:15.450 --> 00:02:18.400 And for those of you that attended last year's conference 00:02:18.400 --> 00:02:19.290 almost looked similar, 00:02:19.290 --> 00:02:21.720 but I have some updated flaring statistics 00:02:21.720 --> 00:02:22.570 and I'll be covering 00:02:22.570 --> 00:02:24.507 some of the new administrative procedures 00:02:24.507 --> 00:02:26.403 that we have been implementing. 00:02:28.460 --> 00:02:30.530 Tim Speer, the engineering unit manager, 00:02:30.530 --> 00:02:34.120 will be handling Q&A during, after the presentation. 00:02:34.120 --> 00:02:38.240 So please feel free to type any questions as we go along. 00:02:38.240 --> 00:02:40.440 You're welcome to hold them to the end as well. 00:02:40.440 --> 00:02:42.240 I'll be sure to go through all the questions, 00:02:42.240 --> 00:02:44.380 answered or not, at the end of the presentation 00:02:44.380 --> 00:02:47.003 so that everyone gets a chance to see them. 00:02:48.130 --> 00:02:50.700 I'll go ahead and get started with a slide 00:02:50.700 --> 00:02:53.433 that I'm sure everyone has memorized by now. 00:02:54.430 --> 00:02:57.440 So this is our mission here at the Railroad Commission, 00:02:57.440 --> 00:03:00.850 is to serve Texas by our stewardship of natural resources 00:03:00.850 --> 00:03:01.683 and the environment, 00:03:01.683 --> 00:03:04.340 our concern for personal and community safety 00:03:04.340 --> 00:03:07.920 and our supported enhanced development and economic vitality 00:03:07.920 --> 00:03:09.413 for the benefit of Texans. 00:03:11.570 --> 00:03:14.350 So before we get into the rule itself, 00:03:14.350 --> 00:03:16.510 I'd like to give a bit of background 00:03:16.510 --> 00:03:20.030 and sort of set the stage for the rule. 00:03:20.030 --> 00:03:22.550 And the actual title of Statewide Rule 32 00:03:22.550 --> 00:03:25.070 is the Gas Well Gas and Casinghead Gas 00:03:25.070 --> 00:03:27.463 Shall Be Utilized for Legal Purposes. 00:03:30.240 --> 00:03:31.210 So if you read the table 00:03:31.210 --> 00:03:35.050 showing the number of flaring permits issued per fiscal year 00:03:35.050 --> 00:03:36.900 and to put these numbers into context, 00:03:36.900 --> 00:03:40.450 as of August 31st, 2019, 00:03:40.450 --> 00:03:45.450 Texas had almost 265,000 producing oil and gas wells. 00:03:45.580 --> 00:03:47.810 So venting and flaring really only involves 00:03:47.810 --> 00:03:52.030 a pretty small fraction of the state's oil wells. 00:03:52.030 --> 00:03:57.030 As you can see, in 2010, 2011, we had a substantial increase 00:03:57.080 --> 00:04:00.680 in the number of permits issued up until about 2014, 00:04:00.680 --> 00:04:03.010 where it stabilized through 2018. 00:04:03.010 --> 00:04:08.010 And then in 2019, we did see a large number of flare permits 00:04:08.720 --> 00:04:09.853 issued once again. 00:04:13.020 --> 00:04:16.350 This graph ties directly into our previous table. 00:04:16.350 --> 00:04:19.170 The black line at the top shows gas produced 00:04:19.170 --> 00:04:23.310 in billion cubic feet and uses the left y axis. 00:04:23.310 --> 00:04:26.890 It goes from zero bcf to 900 bcf. 00:04:26.890 --> 00:04:29.330 That purple line down at the bottom 00:04:29.330 --> 00:04:31.940 shows the percent of total gas flared. 00:04:31.940 --> 00:04:34.940 And that's gonna use the right y axis. 00:04:34.940 --> 00:04:36.780 It goes from zero to 7%. 00:04:37.730 --> 00:04:40.510 And then that blue line they see there in the middle, 00:04:40.510 --> 00:04:43.277 that's the percent of casinghead gas flared, 00:04:43.277 --> 00:04:46.790 and that uses the right y axis as well. 00:04:46.790 --> 00:04:49.790 And for those of you that aren't aware, 00:04:49.790 --> 00:04:52.580 the casinghead gas is gas that is produced 00:04:52.580 --> 00:04:54.703 from a producing oil well. 00:04:55.850 --> 00:04:58.950 So what this graph is showing us is the rapid rise 00:04:58.950 --> 00:05:02.860 in percentage of casinghead gas flared in 2010, 00:05:02.860 --> 00:05:05.040 all the way through 2013, 00:05:05.040 --> 00:05:06.970 sort of like our table was showing us 00:05:07.840 --> 00:05:10.020 as far as the increase in permits. 00:05:10.020 --> 00:05:12.260 So the total amount of gas produced 00:05:12.260 --> 00:05:14.863 did not dramatically increase along with this. 00:05:15.750 --> 00:05:19.170 In part, what this can be attributed to are the shell plays 00:05:19.170 --> 00:05:21.940 out in the Eagle Ford which produce oil, 00:05:21.940 --> 00:05:24.573 but also obviously a significant amount of gas. 00:05:25.872 --> 00:05:27.290 And really, the reason I'm saying all this 00:05:27.290 --> 00:05:28.590 and going through this background 00:05:28.590 --> 00:05:30.190 is because Rule 32 was created 00:05:30.190 --> 00:05:32.220 to handle the amount of permits 00:05:32.220 --> 00:05:34.503 we were seeing really before 2011, 00:05:35.760 --> 00:05:38.060 before that initial spike. 00:05:38.060 --> 00:05:40.310 So just sort of wanted to set the stage 00:05:40.310 --> 00:05:42.650 for exactly how and why we apply the rule 00:05:42.650 --> 00:05:44.090 the way that we do. 00:05:44.090 --> 00:05:45.150 And as we go along, 00:05:45.150 --> 00:05:49.123 I'll do my best to explain and highlight examples of this. 00:05:50.088 --> 00:05:53.320 And just another note in 2015 where you see that decrease, 00:05:53.320 --> 00:05:54.240 as many of you are aware, 00:05:54.240 --> 00:05:58.213 that's when the oil prices tanked and productions slipped. 00:06:01.730 --> 00:06:05.100 So I just really wanted to give a closer look 00:06:05.100 --> 00:06:08.460 at some of the data just from this last year. 00:06:08.460 --> 00:06:11.930 So again, in black are the total gas produced in bcf. 00:06:11.930 --> 00:06:16.560 We have total liquids in green and million barrels of oil. 00:06:16.560 --> 00:06:21.000 And then we have total gas flared in bcf shown in the gray, 00:06:21.000 --> 00:06:23.520 that really small line down there at the bottom, 00:06:23.520 --> 00:06:25.400 along the x axis. 00:06:25.400 --> 00:06:27.560 And then last, we have gas flared 00:06:27.560 --> 00:06:30.090 as a percentage of total gas 00:06:30.090 --> 00:06:32.040 represented by the purple line, 00:06:32.040 --> 00:06:37.040 not utilized at zero to 2.5 percentage on the right y axis. 00:06:39.000 --> 00:06:42.110 So it's just giving you a little bit closer look 00:06:42.110 --> 00:06:47.110 toward really the end of our graph here in slide five. 00:06:50.463 --> 00:06:52.540 So just a little introduction here. 00:06:52.540 --> 00:06:54.920 Gas must be used for lease operations 00:06:54.920 --> 00:06:59.400 or sold if it can be readily measured by devices, meters 00:06:59.400 --> 00:07:03.400 routinely used in the operations of oil wells, gas wells, 00:07:03.400 --> 00:07:05.943 gas gathering systems or gas plants. 00:07:07.150 --> 00:07:08.330 So this is session description. 00:07:08.330 --> 00:07:11.240 We will see it four times. 00:07:11.240 --> 00:07:12.320 This is really just an outline 00:07:12.320 --> 00:07:14.180 of what we'll be discussing today. 00:07:14.180 --> 00:07:15.013 So like I said, 00:07:15.013 --> 00:07:17.950 we have four main points that we wanna cover. 00:07:17.950 --> 00:07:20.170 So first, we're gonna go over exemptions from the rule. 00:07:20.170 --> 00:07:23.640 This is when Statewide Rule 32 does not apply. 00:07:23.640 --> 00:07:26.593 So a.k.a, when there's no metering required. 00:07:27.570 --> 00:07:29.690 The second topic we'll go over today 00:07:29.690 --> 00:07:32.050 is authorized flaring and venting. 00:07:32.050 --> 00:07:34.540 So when flaring is allowed without a permit 00:07:34.540 --> 00:07:36.460 under special conditions. 00:07:36.460 --> 00:07:38.820 So under this conditions, all gasses are metered 00:07:38.820 --> 00:07:40.913 and reported on the production report. 00:07:42.270 --> 00:07:45.080 Third item we'll go over are flaring exceptions. 00:07:45.080 --> 00:07:47.270 We'll discuss what is required for an exception 00:07:47.270 --> 00:07:49.970 and what it actually does for the operator. 00:07:49.970 --> 00:07:51.070 And then fourth, we'll go over 00:07:51.070 --> 00:07:53.720 some, a little bit of additional helpful information. 00:07:54.850 --> 00:07:58.440 So I'll go ahead and hop into exemptions from the rule. 00:07:58.440 --> 00:08:02.950 And just to note, the handout for this presentation 00:08:02.950 --> 00:08:05.250 contains all the slides. 00:08:05.250 --> 00:08:08.520 I know it's not technically a handout this time. 00:08:08.520 --> 00:08:10.320 But the notes on the bottom of the slides 00:08:10.320 --> 00:08:14.600 will address where to find the information within the rule. 00:08:14.600 --> 00:08:17.350 So for example, the information on this slide 00:08:17.350 --> 00:08:22.350 is addressed in Statewide Rule 32 D-1, A through D. 00:08:23.150 --> 00:08:26.540 So it should reference exactly where this information is. 00:08:26.540 --> 00:08:28.440 If say you have a question about this, 00:08:29.490 --> 00:08:31.960 as you read through it at another time or reference it, 00:08:31.960 --> 00:08:34.300 you can reference exactly where I'm getting this information 00:08:34.300 --> 00:08:35.550 from the rule. 00:08:35.550 --> 00:08:36.550 So for the next slide, 00:08:36.550 --> 00:08:40.483 it would be Statewide 32 D-1, D through G. 00:08:41.840 --> 00:08:42.673 Okay. 00:08:42.673 --> 00:08:45.200 So the following are examples of when Statewide Rule 32 00:08:45.200 --> 00:08:48.390 does not apply and no metering is required. 00:08:48.390 --> 00:08:50.810 So the first would be tank vapors 00:08:50.810 --> 00:08:53.030 from crude oil storage tanks, 00:08:53.030 --> 00:08:55.430 gas well condensate storage tanks 00:08:55.430 --> 00:08:57.223 and salt water storage tanks. 00:08:58.333 --> 00:09:01.710 The second example where no metering is required 00:09:01.710 --> 00:09:03.940 is fugitive emissions of gas. 00:09:03.940 --> 00:09:07.950 The third is amine treaters, glycol dehydrator, excuse me, 00:09:07.950 --> 00:09:12.760 glycol dehydrator flash tanks and, or reboiler emissions. 00:09:12.760 --> 00:09:15.610 And the fourth example is blowdown gas 00:09:15.610 --> 00:09:17.700 from gas handling equipment for construction, 00:09:17.700 --> 00:09:19.033 maintenance and repair. 00:09:21.060 --> 00:09:23.320 Continuing on with exemptions. 00:09:23.320 --> 00:09:25.090 We have our fifth example here 00:09:25.090 --> 00:09:26.420 where no metering is required. 00:09:26.420 --> 00:09:29.250 That'd be gas purged from compressor cylinders 00:09:29.250 --> 00:09:32.080 or other gas handling equipment for startup. 00:09:32.080 --> 00:09:35.450 And then sixth, we have gas released 00:09:35.450 --> 00:09:38.750 either at a well site during drilling operations 00:09:38.750 --> 00:09:41.490 prior to the completion date of the well. 00:09:41.490 --> 00:09:44.090 This must be separated from drilling fluids 00:09:44.090 --> 00:09:47.630 using a mud-gas separator or mud degasser. 00:09:47.630 --> 00:09:51.483 Or gas released during completion or re-completion. 00:09:52.500 --> 00:09:54.000 And just a note about this, 00:09:54.000 --> 00:09:56.590 the Commission may also not require metering 00:09:56.590 --> 00:10:00.350 but determines that flaring is required for safety reasons. 00:10:00.350 --> 00:10:03.290 And so you'll see that come up a few times 00:10:03.290 --> 00:10:04.740 throughout this presentation. 00:10:06.650 --> 00:10:07.483 Okay. 00:10:07.483 --> 00:10:09.793 So onto our second item here. 00:10:10.880 --> 00:10:13.573 We're gonna look at authorized flaring and venting. 00:10:15.410 --> 00:10:18.850 So the Commission may require flaring of releases of gas 00:10:18.850 --> 00:10:22.100 not readily measured if the Commission determines 00:10:22.100 --> 00:10:24.343 that flaring is required for safety reasons. 00:10:24.343 --> 00:10:28.220 Like I just mentioned, high concentrations of H2S 00:10:28.220 --> 00:10:29.747 or something like that. 00:10:30.670 --> 00:10:33.540 All gas releases greater than 24 hours in duration 00:10:33.540 --> 00:10:37.890 shall be burned in a flare if the gas can be burned safely. 00:10:37.890 --> 00:10:42.150 And then all gas releases of 24 hours or less in duration 00:10:42.150 --> 00:10:43.570 may be vented to the air 00:10:43.570 --> 00:10:47.170 if not required to be flared for safety reasons. 00:10:47.170 --> 00:10:52.170 And so if you're ever unsure, the thing to do automatically 00:10:52.620 --> 00:10:56.020 is contact the district office for verification, 00:10:56.020 --> 00:10:57.053 if you're unsure. 00:10:59.820 --> 00:11:03.933 So continuing on with gas releases authorized by our rule. 00:11:05.310 --> 00:11:07.810 Authorized gas releases during production operations 00:11:07.810 --> 00:11:11.830 must be measured, a.k.a metered or be reported 00:11:11.830 --> 00:11:14.310 on monthly production reports. 00:11:14.310 --> 00:11:17.630 So flaring beyond the limits set in the following scenarios 00:11:17.630 --> 00:11:20.573 requires an exception to be granted. 00:11:22.590 --> 00:11:26.240 So produced gas is not to exceed 10 producing days 00:11:26.240 --> 00:11:29.600 after initial completion, re-completion in other field 00:11:29.600 --> 00:11:32.520 or workover in the same field. 00:11:32.520 --> 00:11:36.290 So examples of workover operations include perforating, 00:11:36.290 --> 00:11:39.600 stimulating, deepening, clean up, oil maintenance, 00:11:39.600 --> 00:11:41.903 or some other repair operations. 00:11:43.460 --> 00:11:46.060 Also gas that must be unloaded from a well 00:11:46.060 --> 00:11:50.520 may be vented up to 24 hours in one continuous event 00:11:50.520 --> 00:11:54.630 or two 72 cumulative hours in one month. 00:11:54.630 --> 00:11:59.193 So 24 and one of them, 72 cumulative in one month. 00:12:01.810 --> 00:12:05.460 Continuing on with gas releases authorized by the rule. 00:12:05.460 --> 00:12:08.690 If gas from at lease production facility may be released 00:12:08.690 --> 00:12:11.840 up to 24 hours in the event of a pipeline 00:12:11.840 --> 00:12:13.610 or gas plant upset. 00:12:13.610 --> 00:12:16.963 So that would be our sort of one continuous event. 00:12:17.800 --> 00:12:22.330 Also gas contained in waste stream from molecular sieves 00:12:22.330 --> 00:12:25.270 or membrane gas treatment units, 00:12:25.270 --> 00:12:28.900 provided at least 85% of the inlet gas is recovered 00:12:28.900 --> 00:12:31.070 and directed towards legal use. 00:12:31.070 --> 00:12:34.820 So molecular sieves or membrane gas treatment units 00:12:34.820 --> 00:12:37.557 are used to remove carbon oxide, hydrogen sulfide 00:12:37.557 --> 00:12:40.913 and other contaminants from that gas stream. 00:12:42.660 --> 00:12:47.660 Also, we have low pressure separator gas, up to 15 mcfd 00:12:48.240 --> 00:12:51.320 for gas wells and then 50 for oil leases 00:12:51.320 --> 00:12:53.230 or co-mingled points. 00:12:53.230 --> 00:12:56.580 And this has gas that must pass through a separator, 00:12:56.580 --> 00:12:59.900 heater-treater, or other low pressure equipment 00:12:59.900 --> 00:13:01.063 prior to its release. 00:13:08.220 --> 00:13:10.500 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 00:13:17.610 --> 00:13:20.900 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 00:13:40.670 --> 00:13:42.570 beyond that 24 hours, 00:13:42.570 --> 00:13:45.370 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, 00:14:34.130 --> 00:14:36.440 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. 00:15:01.170 --> 00:15:04.970 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.