Texas Well Natural Gas Flaring and Venting Permitting
January 2, 2015

Flaring and venting of natural gas from oil and gas operations in Texas are regulated by the Railroad Commission of Texas (RRC) and the Texas Commission on Environmental Quality (TCEQ). The RRC regulations strive to maximize production and minimize waste. The TCEQ regulations focus on limiting air pollution. Regulations from these two agencies include permitting and emergency reporting requirements. 

For both agencies, the preferred method to reduce waste, maximize production and eliminate air pollution is to use a vapor recovery system (VRU) to recover the natural gas.

Flaring of natural gas at production well site. 

flaring natural gas for Quad O facility

Railroad Commission of Texas (RRC) Oil and Gas Division Rules

The Railroad Commission of Texas (RRC) Statewide Rule 32 (16 TAC 3.32) regulates gas well gas and casinghead gas venting and flaring. 

Under the RRC rules, an operator can vent to the atmosphere natural gas from regulated activities for up to 24 hours. After 24 hours, the natural gas must be flared if can be accomplished in a safe manner. Venting may not be allowed for safety reasons (e.g., H2S in gas) or if another regulation (e.g., EPA, TCEQ) requires recovery or flaring. 

RRC rules natural gas releases allowed include:  

  • Wells after initial completion, recompletion in another field, or workover operations for up to 10 days 
  • Well unloading and cleanup operations allowed for up to 24 continuous hours or up to 72 hours in one calendar month.
  • Depressure a pipeline, facility or equipment for up to 24 hours with notificaiton to the RRC. If natural gas release exceeds 24 hours then must submit an application to RRC to flare the gas. 
  • Waste gas from membrane unit or molecular sieve gas separation systems that meet certain criteria.
  • Low pressure separator gas that is less than or equal to 15 MSCFD of hydrocarbon gas per gas well or 50 MSCFD of hydrocarbon gas per oil lease or commingling point for commingled operations.
  • Exceptions to regulatory listed activities and limitations can be granted by RRC. 

The RRC can extend the above listed activities based on site speicific needs that can be justified.  

Extended venting or flaring of natural gas (e.g., casinghead gas) may be allowed for wells in new exploration areas where pipeline connections are not available.

Review the rules in 16 TAC 3.32 or contact the RRC to determine all the requirements and exceptions for specific activities.

The RRC reports that most flaring permit requests are for flaring cashinghead gas from oil wells. Flare permits for gas wells are not normally issued by the RRC because natural gas is the main product of a gas well.

A summary of the rule can be found at: RRC Venting and Flaring Summary Link.

RRC Flaring/Venting Exemptions

Flaring and venting releases from the following processes are exempt from the RRC rules in 16 TAC 3.32:

  • Vapors from crude oil storage tanks, gas well condensate storage tanks, or salt water storage tanks, including makeup gas for gas blanket maintenance
  • Fugitive emissions of gas
  • Amine treater, glycol dehydrator flash tank and/or reboiler emissions
  • Blowdown gas from flow lines, gathering lines, meter runs, pressurized vessels, compressors, or other gas handling equipment for construction, maintenance or repair
  • Gas purged from compressor cylinders or other gas handling equipment for startup
  • Gas released at a wellsite during drilling operations and prior to the completion date of the well, including gas produced during air or gas drilling operations or gas which must be separated from drilling fluids using a mud-gas separator or mud-degasser
  • Gas released at a wellsite during initial completion, recompletion in another field, or workover operations in the same field

NOTE: Some of the above mentioned emission sources are regulated by the TCEQ’s air permitting rules (e.g., PBR, Standard Permit) and EPA NSPS OOOO rules. See discussion below.

RRC Penalties

Any venting/flaring of casinghead gas or gas well gas not authorized by Statewide Rule 32 or by permit may be subject to administrative penalty action.

 

Texas Commission on Environmental Quality (TCEQ)

The TCEQ uses Permits by Rule (PBR), Standard Permits and individual air permits to permit routine air emissions from oil and gas handling and production facilities. These permits require air pollution controls and process designs to limit venting and flaring of gas from production facilities. The TCEQ enforces the EPA and its state air quality regulations. This includes NSPS OOOO (Quad O) venting regulations. 

Nonroutine upset and bypass of emission control devices that result in venting and flaring of natural gas can be handled by special air permit or may be required to be reported according to the TCEQ’s emergency and upset reporting rules.

TCEQ Emergency/Upset Reporting

Emergency and upset events from venting and flaring of natural gas may be reportable emissions events to the TCEQ.  This includes the bypass of pollution control equipment. Reportable emissions events are unauthorized emissions from any emissions point equal to or greater than a reportable quantity (RQ) in any 24-hour period. See Texas Administrative Code 30 §101.1(88) for definition of a RQ in Texas.

To report emergency releases, the TCEQ wants operators to use the State of Texas Environmental Electronic Reporting System (STEERS) online system. You must set up an account to use the system. Use TCEQ Reportable Event/Activity Notification/Reporting Form (TCEQ- 10360 - revised February 2014) and submit via STEERS. Upset reports to the TCEQ are due no later than 24 hours of discovery of the reportable event.

TCEQ Air Permits

An air permit is required for all oil and gas facility’s routine venting and flaring of natural gas. The facility must qualify for and/or obtain an air permit prior to beginning construction – based on requirements of the air permit type (i.e., PBR, Standard Permit, and Individual) used. The air permits may require emission controls for venting sources.  

Typical venting and flaring air emission sources included in TCEQ permits are listed below. The air permits have facility and emission source specific emission control requirements for VOCs.

  • Crude oil, condensate and produced water storage tanks
  • Crude/condensate loading and unloading – tank trucks, railroad cars, barges
  • Fugitive emissions (leaking valves, flanges, seals, pressure relief devices)
  • Flares, combustors, incinerators
  • Natural gas sweetening units (amine units)
  • Glycol dehydrators (still column vent, flash tank)
  • Pneumatic pumps using natural gas (e.g., Wilden/Aro/Texsteam)
  • Pneumatic controllers (e.g., pressure, level, temperature) using natural gas
  • Maintenance Startup and Shutdown (MSS) emission from venting and degassing of facilities to prepare for maintenance and emissions from maintenance activities. These can include facility blowdowns; pneumatic starts on reciprocating engines, turbines, compressors; pipeline pigging and sampling.

Venting from stuck separator dump valves may be treated as an upset that requires emergency reporting if emissions of VOC components or hazardous air pollutants (HAPs) exceeds a Reportable Quantity (RQ) as specified in Texas Administrative Code 30 §101.1(88).

To meet the emission limitations in TCEQ PBR and Standard Permits for oil and gas facilities, operators often use vapor recovery units (VRU) to recover gas and send it to sales. With the regulatory, public and press focus on flaring of natural gas in Texas and the US, VRUs are preferred and economically viable option over flaring storage tank gas. 

TCEQ Penalties

The TCEQ violations of air quality rules can be classified as administrative/civil violations and criminal. For administrative and civil issues, the TCEQ has published statutory penalties that it can assess for violations. The TCEQ uses its published Penalty Policy to calculate and assess administrative and civil penalties.

Statutory penalties include:

  • Administrative penalties, per violation per day range from $0 to $25,000
  • Civil penalties, per violation per day range from $0 to $25,000

The penalty assessed will be dependent on whether a facility was a major or minor source and based on an evaluation of the harm and severity of violations. 

 

NSPS OOOO and Well Completion Venting/Flaring 

In addition to RRC and TCEQ rules, operators must complly with EPA regulations in NSPS OOOO (Quad O). NSPS OOOO includes requirements for natural gas releases from hydraulically fractured gas wells during the flowback phase of well completion.

Beginning January 1, 2015, reduced emission completions (REC) are required for affected well completions.

The REC should capture the flowback gas after fracturing or refracturing so that the natural gas is not directly released to the atmosphere. The REC system should route the recovered gas into a gas flow line or collection system, re-inject the recovered gas into a well, use the recovered gas as an on-site fuel source, or use the recovered gas for another useful purpose that a purchased fuel or raw material would serve. 

RECs are not required for wildcat wells, delineation wells, low‐pressure wells and safety reasons. Operators are required to use combustion devices during for this flowback gas unless combustion is a safety hazard. 

NSPS OOOO also has requirements for storage tanks (included in TCEQ air permits), compressor seals and use of low bleed pneumatice devices. 

Conclusion

Conservation of natural resources, minimizing waste and reducing air pollution are goals of these agencies. Oil and gas operators want to maximize profits by sending as much natural gas to the sales line. And yet, even with air quality rules (e.g., air permits, NSPS OOOO) already impacting oil and gas operators, there is more public pressure to “do something” about flaring and venting of natural gas. In this regulatory driven atmosphere, operators wanting to enhance our industry will continue to focus on creative ways to reduce waste and implement systems to stay in compliance.

Let HY-BON help your company reduce your flaring and venting of natural gas.

VENT GAS MANAGEMENT – HANDLED!