Statewide Update 2012

Statewide Update 2012

Keith Sheedy, P.E.Technical Advisor

Office of Air

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Approximately 397,827 Oil and Gas Wells as of July 2012 and Growing

What are the environmental regulations that apply to the oil and gas sector?

Who Regulates Oil and Gas Activities in Texas?(RRC or TCEQ)

• The Railroad Commission of Texas (RRC) has primary regulatory jurisdiction over the oil and gas (O&G) industry.

• The Texas Commission on Environmental Quality (TCEQ) is the environmental agency for the state (especially air emissions).

• There is a Memorandum of Understanding (MOU) between the RRC and TCEQ detailing jurisdictions of O&G activities.– http:/info.sos.state.tx.us/pls/pub/readtac$ext.viewtac)

• Common Environmental Requirements for Regulated O&G Operations - Publication RG – 482 http://www.tceq.texas.gov/publications/rg/rg-482.html

http://www.tceq.texas.gov/publications/rg/rg-482.html

Who Regulates Oil and Gas Activities in Texas?Water Issues (RRC or TCEQ)

• Process wastewater discharge and storm water run-off from O&G sites – EPA

• Drinking water– Private wells – suspected contamination by O&G should

be reported to the RRC– Public water supply – concerns should be reported to the

TCEQ• Reclaimed water from municipal or industrial sources used

for hydraulic fracturing – TCEQ

Surface Water Rights

• Before initiating any diversion, impoundment, taking, or use of surface water, or construction for those activities, a permit must be acquired from the TCEQ.

• There are areas of the state where it may be difficult to find water available on a permanent, temporary basis due to existing permits and specific conditions in the stream.

Who Regulates Spills at Oil and Gas Sites?(RRC or TCEQ)

Classification of the spill determines which agency has jurisdiction

• Spills associated with exploration, development, and production of O&G – RRC (air emissions - TCEQ)

• Hazardous substances - TCEQ• Refined petroleum products – TCEQ• Abandoned containers of unknown substances that are

not leaking – TCEQ• Texas Oil Spill Prevention and Response Program –

Texas General Land Office

Who Regulates Waste at Oil and Gas Sites?(RRC or TCEQ)

In general wastes from O&G related activities are regulated by RRC. The exceptions are:

• Waste associated with transportation of crude oil and natural gas by railcar, truck, barge, or oil tanker

• Refined petroleum products by pipeline• Wastes generated at oil field service facilities that

provide equipment, materials, or services to the O&G industry

• Wastes that are processed, treated, or disposed of at a solid waste management facility authorized by the TCEQ

What about the dust, noise, and traffic associated with O&G sites?

• Dust from public roads should be addressed by the local government.

• Noise complaints should be reported to the local law enforcement agency.

• Traffic complaints should also reported to the local law enforcement agency.

State Air Regulations - Authorizations

Since September 1, 1972, owners and operators of an O&G site must obtain an authorization for air emissions.

The agency uses a tiered approach to provide more options for permitting oil and gas facilities: de minimis exclusion; historical standard exemptions, permits by rule (PBR); standard permits; and case-by-case permits.

TCEQ Air Regulations

A company had an “upset” at an O&G site that lead to unauthorized air emissions.

• Are they required to record the information concerning the event? Yes

• Are they required to report the event to the TCEQ? Depends on what and how much was emitted

• 30 TAC §101.201 and §101.222 have all of the answers

TCEQ Air Regulations

Someone has complained to the TCEQ about an odor or dust issue at a well pad that is being completed, what TCEQ rules could apply?

• 30 TAC §101.4 – Nuisance and

• 30 TAC §111.111 – Visible emissions

TCEQ Air Regulations (cont.) • Chapter 101 – State delegation of some Federal

Regulations• Chapter 112 – Control of sulfur dioxide and hydrogen

sulfide • Chapter 113 – State adopted 40 CFR Part 63 (MACT

rules)• Chapter 114 – Control of air pollution from motor vehicles

- Gasoline and diesel• Chapter 115 – Control of air pollution from volatile organic

compounds• Chapter 117 – Control of air pollution from nitrogen

compounds

Federal Air Regulations

40 CFR Part 60 New Source Performance Standards (NSPS)– Subpart KKK – Equipment leaks of VOC from onshore natural

gas processing plants– Subpart LLL – Standards of performance for Onshore Natural

Gas Processing: SO2 emissions– Subpart JJJJ – Standards of performance for stationary spark

ignition internal combustion engines 40 CFR Part 63 National Emission Standards for hazardous Air

Pollutants (NESHAP) – Subpart HH – Natural gas production facilities– Subpart HHH – Natural gas transmission and storage facilities– Subpart ZZZZ – Reciprocating internal combustion engines

Federal Air Regulations (cont.)

• Federal NSPS and MACT changes – EPA has just finalized a major revisions to oil and gas

rules, includes a new Part 60 Subpart OOOO – Standards of Performance for Crude Oil and Natural Gas Production, Transmission, and Distribution

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Federal Clean Air Act

• EPA set health-based standards for clean air called National Ambient Air Quality Standards (NAAQS) for criteria air pollutants:

– Ground-Level Ozone (O3)– Particulate Matter (PM2.5 and PM10)– Nitrogen Dioxide (NO2)– Sulfur Dioxide (SO2)– Carbon Monoxide (CO)– Lead (Pb)

Requires states with counties failing to meet air quality standards to produce a State Implementation Plan (SIP).

EPA’s NAAQS Review Schedule

20

2008 2009 2010 2011 2012 2013

2008 2009 2010 2011 2012 2013

Ozone

Nitrogen Dioxide (NO2)

SO2

Lead

NOX/Sulfur Oxides (SOX)

Secondary Level

CO

PM

Final Rule: May 27, 2008 Proposed Rule: October 2013

Proposed Rule – July 15, 2009 Final Rule – February 9, 2010

Proposed Rule – December 8, 2009 Final Rule – June 2, 2010

Proposed Rule – May 20, 2008 Final Rule - November 12, 2008

Proposed Rule – August 1, 2011 Final Rule – March 20, 2012

Proposed Rule – February 11, 2011 Final Rule – August 31, 2011

Proposed Rule – June 2012 Final Rule – June 2013

0

5

10

15

20

25

30

48

66

84

102

120

1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011

Millionsppb

Eight-Hour Ozone Design Values and Population in Texas

Population BPACC DFWHGB ARRELP SANNET VICBB LRGLAR 1997 Eight-Hour Ozone NAAQS: 84 ppb2008 Eight-Hour Ozone NAAQS: 75 ppb

*Design Values are from EPA's AQS.*MSA populations from US Census Bureau.

Noncertified 2012 Ozone Design Values as of September 1, 2012

87

8876

74 80

72 71

64

69

72

79

75

70

61

=Based on federal requirements, areas where new ozone monitors could be required

0.0

1.3

2.7

4.0

5.3

6.7

8.0

60

90

120

150

180

210

240

1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011

MillionsppbOzone Design Values and Population in the DFW Area

Population

Eight-Hour Ozone Design Values

One-Hour Ozone Design Values

1997 Eight-Hour Ozone NAAQS: 84 ppb

2008 Eight-Hour Ozone NAAQS: 75 ppb

*Design Values are from EPA's AQS. **Population from US Census Bureau.

Main questions: How many sources are there and what is

in the air?

We quickly figured out that while we knew how many wells there were in the Barnett Shale formation, we didn’t know how many sources (storage tanks, compressors, etc…) were associated with each of those wells and what their actual emissions were.

2009 Oil and Gas Equipment and Emission Inventory

• Phase I – the first phase of the inventory request asked for basic information from producers and pipeline companies in the 24-county area.

• Phase II required that the companies provide detailed information for each piece of equipment reported in Phase I, including:– Equipment and production information– Air emissions authorizations– Location of the sources located within one-quarter

mile of the nearest receptor, and– Annual 2009 emissions for nitrogen oxides, volatile

organic compounds, and hazardous air pollutants.

Barnett Shale 2009 Special Inventory

Emission Source Number of Sources

Separators Vented to Atmosphere 16

Total Storage Tanks 20,775

Uncontrolled Glycol Dehydrators 112

Controlled Glycol Dehydrators 184

Total Stationary Engines 3,553

Turbines 37

Flares 78

Frac tanks 27

Piping Component Fugitive Areas 15,824

Blowdown Vents 7,490

Process Vents 1,191

Heaters/boilers 893

Other Stationary Equipment 1,858

Total Emission Sources 52,038

Oil and Gas Emissions Inventory Improvement Activities

• Flash emissions model evaluation• Drilling rig emissions project• DFW compressor engine project• Emissions inventory guidance improvements• Engine fleet DFW nonattainment area survey, • Oil and Gas model evaluation

• Texas-specific calculator for state-wide area inventory development

Copies of these studies and more are available on the Agency’s emissions inventory website: http://www.tceq.texas.gov/airquality/airmod/project/pj_report_ei.html

• The reduction is primarily associated with the use of low bleed, ultra low bleed, or no bleed pneumatic valves.

2012 Estimated Emissions in DFW Area

The latest DFW Attainment Demonstration SIP Revision for ozone estimated 2012 emissions of VOC and NOX in the nine-county area as:

Category 2012 NOX tpd 2012 VOC tpd

On-road mobile 181 80NOX = 282 tpdVOC = 129 tpd

Non-road (excl O/G)

64 43

Off-road 37 6

Point Source 51 39

Area (excl O/G) 18 240

O/G Production 10 113 NOX = 19 tpdVOC = 114 tpdO/G Drilling 9 1

DFW Total 370 522

Barnett Shale Pneumatic Valve Survey

• The TCEQ conducted a Barnett Shale specific pneumatic valve survey in late 2011.

• The survey requested addition data from the top 17 producers in the Barnett Shale, which accounted for 90 percent of the active gas wells.

• Results indicated a reduction of 49.6 tpd in estimated emissions associated with those devices.

• Based on results of the survey, the estimated 2012 VOC emissions would decrease to 63 tpd, which is half of the mobile source VOC emissions.

What Does This Mean in Terms of Ozone Formation in the DFW Area?

Several variables in addition to the tons of ozone precursors emitted determine the potential impact of the emissions on ozone formation.• Most of the O/G emissions are located north, west, and southwest of

the DFW urban core, which is generally not upwind during conditions when the highest ozone concentrations are measured.

• The DFW area is NOX limited, so controlling NOx emissions is more efficient control strategy to minimize DFW area ozone.

• O/G NOX emissions are estimated to have been reduced from 68 tpd to19 tpd, because of TCEQ rules requiring the use of lower NOX emitting engines.

• Mobile source NOX emissions are approximately 15 times higher than O/G NOX emissions.

Statewide Pneumatic Devices Survey

• As part of ongoing efforts to improve the area source oil and gas emissions inventory, the TCEQ requested data associated with pneumatic devices operating at active gas well sites outside of the Barnett Shale area for calendar year 2011.

• Total component count of pneumatic devices categorized according to type and bleed rate.

• This data will be used to evaluate volatile organic compounds emissions estimates from pneumatic devices on the county-level.

Air Monitoring in Texas

• Mobile monitoring (short-term monitoring)

• Ambient air monitoring networks (long-term monitoring)

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Short-term monitoring

• We conducted several (9) multiple day mobile monitoring trips in the Barnett Shale area

• Evaluating the ambient air along the ‘fence-line’ of the facilities (short-term 30 minute sampling)

Short-term monitoring

• Provides short-term data – a snapshot of air quality for a specific time and place

• Short-term data allows the TCEQ to make assumptions about the potential for health effects after a short-term exposure to the monitored concentrations

• Short-term data also helps the TCEQ determine where to focus resources

What is in the Ambient Air? Short-term Monitoring

• Since August 1, 2009, the TCEQ has surveyed 2,428 sites in the DFW area using the GasFind IR camera and at 2,384 of these sites, a hand-held volatile organic compound sampler was also used.

• 1,198 canister samples have been collected in the DFW area. • Since 2005, the TCEQ has purchased 11 GasFind IR

cameras (4 are located in DFW region) and numerous other handheld, state-of-the-art, air monitoring instruments

• Barnett Shale Air Sampling Map Viewer: http://www.tceq.texas.gov/airquality/barnettshale/bshale-viewer

http://www.tceq.texas.gov/airquality/barnettshale/bshale-viewer

Investigative Presence and Complaint Response

• Implemented a 12-hour response time for all complaints received concerning oil and gas facilities in the 24-county Barnett Shale area

• Added additional investigators to the DFW Region Office and created a Barnett Shale team

• Conduct periodic reconnaissance investigations in selected areas, along with scheduled compliance investigations at natural gas sites

• Conduct monitoring at the request of the public and other interested parties.

Ambient Air Monitoring Network• One of the

largest monitoring networks in the nation

• Monitor for:• CO/NOx/O3

• SO2/H2S/• VOCs and

Semi-volatiles• Chromium VI• Particulate

Matter• Lead

TCEQ Monitoring Sites in DFW Area

2012

General locations of the next five Auto GCs

2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 20120

0.05

0.1

0.15

0.2

0.25

0.3

0.35

Auto GC Benzene Annual Averagespart per billion - by volume (ppbv)

Dallas Hinton

FW Meacham

DISH

Eagle Mountain

Flower Mound

Decatur

Everman

Kennedale

Year

ppbv

NOTES:DISH and Eagle Mountain Lake AutoGC monitors established in April 2010.Decatur AutoGC monitor established October 2010.Flower Mound AutoGC monitor established in November 2010.The Everman Johnson Park monitor was established in July 2011. Kennedale monitor was established in July 2012.

Benzene Health Effect LevelsBenzene Concentration in Air

(parts per billion, ppb)Short-Term Exposure Long-Term Exposure

(less than 14 days) (years)100,000,000

10,000,000

1,000,000

100,000

10,000

1,000

100

10

1

0.1

DrowzinessDizzinessHeadache

Leukemia

Eye Irritation

EPA Acceptable Cancer Risk

TCEQ Long-Term AM CV (1.4 ppb)

TCEQ short-term AMCV (180 ppb)

OSHA 15-minute Standard

OSHA 8-hour Standard

OSHA Action Level

BenzeneHealth Effects

andRegulatory

Levels Death

Blood changes in animals

Auto GC monitors avg. reading: <0.2 ppb

Eagle Ford Shale Zero to 150,000 bbl/day in five years

San Antonio 8-Hour Ozone Design Value (ppb)

Meteorological Features in San Antonio’s Conceptual Model

• High ozone days exhibit light winds and either– northeast and easterly flow at C23– northwesterly to easterly flow reversal at C58

• Low ozone days exhibit mostly southerly to south-southeasterly flow

Eagle Ford Counties with 2010 Population

Data

Low ozone days

High Ozone days

What might a newer episode show?

• Other episodes, for example 2009, will show more high ozone days from southerly flow.

• Lowering the ozone standard will increase the importance of selecting spring episodes which are generally more southerly flow regimes.

• Furthermore, the TCEQ has started to review the need for addition monitors in the area.

Eagle Ford Counties with 2010 Population

Data

TCEQ’s Oil and Gas Web Site: “Oil and Gas Facilities: Compliance Resources”

Compliance tools for oil and gas facilities in Texas“texasoilandgashelp.org”

• Compliance information on air, water, waste, and spill issues.

• Guidance documents for local governments having to deal with oil and gas facilities and associated ancillary businesses.

• RV Parks: Am I Regulated

Summary: What We Are Finding• Nearly all of the issues documented arose from human

or mechanical failures.• These items were quickly remedied and could have been

avoided through increased diligence on the part of the operator.

• Corrective actions amounted to little more than replacing worn gaskets, closing open hatches, and repairing stuck valves.

Moving Forward

The TCEQ must continue to: Ensure transparency of our efforts through abundant and

timely communication with all interested parties; Evaluate the existing ambient air quality monitoring network and

expand, as needed, through the use of established agency protocol for determining the placement of long-term, stationary monitors;

Apply the use of state-of-the-art handheld air monitoring equipment to assess short-term, near-source air quality;

Maintain a frequent, routine investigative presence while also providing timely complaint response;

Base our rules and permits on sound science and common sense; and

Apply our enforcement tools in a fair and consistent manner.

Keith Sheedy, P.E.Technical Advisor

Office of AirTexas Commission on Environmental Quality

[email protected]

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Questions?

mailto:[email protected]

Statewide Update 2012

Documents

Transcript of Statewide Update 2012