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Natural Gas Flaring in the Eagle Ford –
An Air Quality Perspective
November 13, 2014
James Smith
Air Quality Director
Overview

Fracking Boom

Reasons for NG Flaring

Pollution Being Emitted

Air Quality Regulations That Address Flaring

What Companies Are Doing to Reduce Flaring
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July 17, 2015
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Eagle Ford Shale
From ~zero to >1,000,000 BOE/day by end of 2013
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Negative Press On NG Flaring in Eagle Ford

4-Part Investigative Report – “Up in Flames” (published Aug 22, 2014)
 From 2009 – 2012, 400% increase in flared/vented NG
 In 2012, 33 BCF flared/vented  2/3 (21 BCF) from Eagle Ford
 Eagle Ford flaring 10X combined rate of all other TX oil fields
 2012  Eagle Ford flares emitted > 15,000 tons VOC/other pollutants
More emissions than 6 refineries in Corpus Christi combined

Main Point – Companies Not Doing Enough to Capture NG
http://www.expressnews.com/business/eagleford/item/Up
-in-Flames-Day-1-Flares-in-Eagle-Ford-Shale-32626.php
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Perspective on NG Flaring (TX RRC)
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Reasons for Flaring Natural Gas

Coveting Crude Oil Over Natural Gas Production



Price of crude oil ~ $78/bbl (has been > $100/bbl)
Price of raw natural gas < $4/MCF
Lack of NG Pipeline Infrastructure from Field to Processing Plant

No gas pipelines in remote, rural areas
 Existing gas pipelines cannot handle surge in NG production
 Long delays in obtaining air permits for constructing compressor stations and
processing plants

Temporary Flare Used During Well Production Testing

For Safety and During Emergencies and Maintenance
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If Downstream Customer Cannot Take Sales Gas, Must
Re-route Gas to Flare or Shut In Well
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Air Pollution From Flaring

Pollutants from combustion:
 Nitrogen Oxides (NOx)
 Particulate Matter (PM)
 Carbon Monoxide (CO)
 Sulfur Dioxide (SO2)  minute amounts for “sweet” fields
 Carbon Dioxide (CO2)  greenhouse gas

Un-combusted pollutants (assumed 98% control):
 2% Volatile Organic Compounds (VOC)
 Can contain benzene  hazardous air pollutant
 2% Methane (CH4)  greenhouse gas
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Federal Air Regs That Address Flaring

New Source Performance Standards (NSPS), 40 CFR 60, Subpart
OOOO – Crude Oil and Natural Gas Production, Transmission, and
Distribution
 Requires gas capture starting 1/1/2015 from NG production wells
drilled after 8/23/2011 (“green completions”)

National Emission Standards for Hazardous Air Pollutants (NESHAP) for
Source Categories, 40 CFR 63, Subpart HH – Oil and Natural Gas
Production Facilities
 Flaring related to TEG Glycol Dehydrators

NESHAP for Source Categories, 40 CFR 63 Subpart HHH – Natural
Gas Transmission and Storage Facilities
 Flaring related to
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Texas Air Regs That Address Flaring
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Texas RRC Statewide Rule 32
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30 TAC 106.352 – Permit by Rule (PBR) for Oil
and Gas Handling and Production Facilities
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30 TAC 106.492 – PBR for Flares (tied to 106.352)

30 TAC 116.620 – Standard Permit for Installation and/or
Modification of Oil and Gas Facilities
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“Non-Rule” Standard Permit for Oil and Gas Handling and
Production Facilities  most Eagle Ford sites obtain this air
permit
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Potential Penalties

Curtailing Oil Production
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Potential Enforcement

EPA’s Six National Enforcement Initiatives for 2014 – 2016
o
Keeping raw sewage and contaminated stormwater out of our nation’s waters
Preventing animal waste from contaminating surface and ground waters
o
Cutting toxic air pollution that affects communities’ health
o
Reducing widespread air pollution from the largest sources, especially the
coal-fired utility, cement, glass, and acid sectors
Reducing pollution from mineral processing operations
o
o
o
Assuring energy extraction sector compliance with
environmental laws

For HAPs, EPA focused on three areas of reduction (based
on historical non-compliance)
1.
Leak Detection and Repair (LDAR)
Reducing volume of waste gas to flare and flare control efficiency
Excess emissions, including those from Startup, Shutdown, and Malfunction
2.
3.
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Flare Reduction Measures

“Green Completion”
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Reduce Site NG Production Rate
 Avoid More Stringent Air Permit (Title V)

Install a Vapor Recovery Unit on Oil Tanks
(reduces flash gas to flare)
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Green Completion
 Required
by NSPS Subpart OOOO
 Per
EPA, can reduce VOC by up to 95% for over
11,000 fracked gas wells each year
 Rule
requires all new and re-fracked NG wells to
implement green completions by Jan 2015
Not required for “oil” wells – EPA defines a NG well as a
well “drilled principally for production of natural gas”

July 17, 2015
Rule will not affect most Eagle Ford wells
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Green Completion (cont’d)
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Green Completion (cont’d)
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Vapor Recovery Unit

Recover > 95% hydrocarbons from storage tank
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7,000 – 9,000 VRUs currently installed in O&G
industry (average 4 tanks connected to 1 VRU)

Benefits of VRU:
 Recover
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Vapor Recovery Unit (cont’d)
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Vapor Recovery Unit (cont’d)
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Questions?
James Smith
Golder Associates Inc.
500 Century Plaza Drive, Ste. 190
Houston, TX 77073
(281) 821-6868
[email protected]
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Backup Slides
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Positive Message – TCEQ Video on Air
Quality Control For O&G Sector

Texas is the leading O&G producing state in the country

Texas energy sector contributes $200 billion to Texas economy

TCEQ committed to keep air quality safe amid increased O&G
production via:


State-of-the-art monitoring equipment, data analysis
Increased no. air monitors throughout shale areas
http://www.youtube.com/watch?
v=7w3elLj6mlo
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