Oil & Gas Investigations Jason Harris TCEQ Houston Region GCEAG – September 9, 2010

1. Oil & Gas Investigations Jason Harris TCEQ Houston Region GCEAG – September 9, 2010 SBEA Internal Training – Oil & Gas February 3, 2010

2. Oil & Gas Wells As of 2008 DFW Barnett Shale Oil & Gas Production in Texas GCEAG - September 9, 2010

3. Investigation Types • Complaints • Emissions Events • Stack Tests • Comprehensive Compliance Investigations • Focused Investigations GCEAG - September 9, 2010

4. Complaints GCEAG - September 9, 2010

5. Complaints • Noise • Truck Traffic / Road Conditions • Property Values • Well Location / Distance to Homes • Dust • Odors • No Permit / Authorization GCEAG - September 9, 2010

6. What is a Nuisance? • 30 Texas Administrative Code §101.4 “No person shall discharge from any source whatsoever one or more air contaminants or combinations thereof, in such concentration and of such duration as are or may tend to be injurious to or to adversely affect human health or welfare, animal life, vegetation, or property, or as to interfere with the normal use and enjoyment of animal life, vegetation, or property” • A nuisance violation may be issued regardless of compliance with other rules GCEAG - September 9, 2010

7. Complaint Response • Each complaint is prioritized • Oil & gas complaints are investigated within 12 hours or by the next business day GCEAG - September 9, 2010

8. Emissions Events GCEAG - September 9, 2010

9. Emissions Events • 30 TAC §101, Subchapter F – Emissions Events and Scheduled Maintenance, Startup and Shutdown Activities • Upset event – “An unplanned and unavoidable breakdown or excursion of a process or operation that results in unauthorized emissions” • Emission event – “Any upset event or unscheduled maintenance, startup, or shutdown activity, from a common cause that results in unauthorized emissions of air contaminants from one or more emissions points at a regulated entity” GCEAG - September 9, 2010

10. Emissions Events • 30 TAC §101.201 - Emissions Event Reporting and Recordkeeping Requirements • Reportable Quantities (within any 24 hr period) • Typically 5,000 lbs for natural gas • 100 lbs if H2S or mercaptans • If RQ exceeded, must be reported within 24 hours (reportable) • If not, final in-house record must be completed within 14 days (non-reportable) GCEAG - September 9, 2010

11. Stack Testing GCEAG - September 9, 2010

12. Stack Testing • Oil & gas production sites often include multiple combustion sources which may require stack testing • 30 TAC 117, Subchapter D Applies to minor, stationary sources of NOx located in ozone non-attainment areas • 40 CFR 60 Subpart JJJJ – Standards of Performance for Stationary Spark Ignition Internal Combustion Engines • 40 CFR 63 Subpart ZZZZ – National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines GCEAG - September 9, 2010

13. Stack Testing To determine whether an engine must be stack tested, the following information is needed: • Type of Compression • Horsepower Rating • Manufacture Date • Type of Burn (Rich v. Lean)  *these numbers differ for the EPA vs. TCEQ • Is the Engine in question Portable, Stationary, or Emergency? • Is the Engine located in an Attainment or non-Attainment County? • Is the Engine a Major or Minor Source? • Is the Engine used for Utility Electric Generation or is it used for Industrial/Commercial practices? GCEAG - September 9, 2010

14. Compliance Investigations GCEAG - September 9, 2010

15. Compliance Investigations • Investigations are triggered primarily through: • reconnaissance activities • complaints • ambient or mobile monitoring results • special projects or initiatives • An investigation may be limited in focus or may be more comprehensive GCEAG - September 9, 2010

16. GasFindIR® camera Toxic Vapor Analyzer Mini RAE Summa canister Investigation Tools GCEAG - September 9, 2010

17. GasFindIR Camera GCEAG - September 9, 2010

18. GasFindIR Camera • Sources of Observed Emissions • Condensate tank thief hatches • Water tanks • Unlit flares • Tank vents / Enardo valves • Glycol still vents • Gas-actuated valves • Wellheads GCEAG - September 9, 2010

19. GasFindIR Camera GCEAG - September 9, 2010

20. GasFindIR Camera • If emissions are observed with the GasFindIR • IR video is recorded • Video is shared with the owner/operator along with a questionnaire • The questionnaire is used to obtain specific information about site operations, the reason for the observed emissions, and steps taken to correct or minimize emissions GCEAG - September 9, 2010

21. Oil & Gas Questionnaire Company Name: Site Name: Site Location/Address: Contact Name: Contact Phone Number: Contact Email Address: 1. What are the TCEQ air authorizations for this site (i.e. Permit By Rule, Standard Permit, or New Source Review Permit, Title V (if applicable))? Please provide the authorization number, or registration number. 2. Is the site currently in compliance with the authorizations listed above? • What method (source testing, engineering calculations, etc…) did you use to determine compliance with your authorizations? • If you are not currently in compliance with your authorizations, what actions are you planning to take to achieve compliance? 3. What is the distance to the nearest receptor (i.e. residence, park, school, church)? 4. Please provide a list of equipment at the site. 5. Please provide a detailed process description. 6. Based upon the provided video, please provide the following information: • Identification of the unit or equipment with the observed plume. • The associated authorization for that piece of equipment. • Explanation for the observed plume. • Explanation as to how you plan to fix or have fixed the observed emissions. • If the observed emissions from the source are allowed by the site’s authorization, provide the method used to determine this compliance. • Please provide a timeline for addressing the observed emissions. GCEAG - September 9, 2010

22. Summa Canisters • Used to collect air samples • Analyzed with a gas chromatograph • Provide concentrations of benzene and other hazardous air pollutants GCEAG - September 9, 2010

23. Common Problems / Challenges Thief Hatch GCEAG - September 9, 2010

24. Common Problems / Challenges Authorization • Permit By Rule (PBR) - 30 TAC §106.352 • limits total VOC emissions to 25 tpy • special provisions for sour gas • no maintenance requirements and no distance requirements for sweet gas facilities • Standard Permit - 30 TAC §116.620 • not site-specific, but includes more requirements than a PBR • New Source Review (NSR) Permit • site-specific permit • may require modeling for air contaminants • Title V Permit • required for sources emitting VOC greater than major source threshold (depends on location) GCEAG - September 9, 2010

25. Common Problems / Challenges Emission Estimates • Several methods for estimating VOC emissions • Vasquez-Beggs Equation • Gas-Oil Ratio • Process Simulators • Direct Measurement • Each method has drawbacks • Many operators fail to estimate or measure emissions; simply assume PBR limits GCEAG - September 9, 2010

26. Rule Revisions GCEAG - September 9, 2010

27. Rule Revisions • Draft oil & gas standard permit and PBR currently open for public comment • Draft Standard Permit: http://www.tceq.state.tx.us/assets/public/permitting/air/Announcements/og_proposed_sp_fin.pdf • Draft PBR: http://www.tceq.state.tx.us/assets/public/permitting/air/Announcements/og_pro_010018106.pdf GCEAG – September 9,2010

28. Rule Revisions TCEQ seeks to accomplish the following through this rulemaking: • Update administrative and technical requirements • Include practically enforceable monitoring, sampling, and recordkeeping requirements • Address and authorize planned maintenance, startup, and shutdown (MSS) activities • Allow the commission to more effectively focus resources on facilities that significantly contribute air contaminants to the atmosphere • Make appropriate changes to registration and notification requirements • Ensure that air emissions from specific facilities are protective GCEAG – September 9,2010

29. Rule Revisions • The comment period for the proposed Oil and Gas PBR and Standard Permit has been extended to October 1, 2010. • New date for consideration of adoption by the Commission will be December 14, 2010 GCEAG – September 9,2010

30. Houston-Galveston-Brazoria Specific Requirements GCEAG - September 9, 2010

31. HGB Specific Requirements • After January 1, 2009, the following requirements apply to sites within the HGB ozone non-attainment area: • 30 TAC 115.112(d)(4): Storage tanks storing condensate must route flash gases to a control device if throughput exceeds 1,500 barrels per year • 30 TAC 115.112(d)(5): Storage tanks storing crude oil or condensate must route flash gases to a control device if VOC emissions exceed 25 tpy GCEAG – September 9,2010

32. HGB Specific Requirements • The Houston Regional Office recently concluded an outreach effort to advise tank battery operators of the HGB specific requirements • This outreach also included a survey of tank batteries with the potential to exceed 1,500 bbls of condensate per year • On-site investigations at a small number of tank batteries may begin as early as October GCEAG – September 9,2010

33. Additional Information • Multi-media compliance resource: http://www.tceq.state.tx.us/assistance/sblga/industry/oilgas.html • PBR and Standard Permit info: http://www.tceq.state.tx.us/permitting/air/announcements/nsr_announce_3_25_10.html GCEAG – September 9,2010

34. Questions? GCEAG - September 9, 2010