Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Railroad Commission of Texas
Statewide Rule 32 – Venting & Flaring
August 5, 2021
The meeting will begin shortly.
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Statewide Rule 32:
Venting & Flaring
Nathan Nattin
August 5, 2021
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
RRC Mission
Our mission is to serve Texas by our
stewardship of natural resources and
the environment, our concern for
personal and community safety, and
our support of enhanced
development and economic vitality
for the benefit of Texans.
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Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Statewide Rule 32
Texas Administrative Code (TAC)
Title 16, Part 1, Chapter 3
§3.32
Gas Well Gas and Casinghead Gas Shall
Be Utilized for Legal Purposes
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Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Flaring Exceptions
To put these
numbers in context,
as of August 31,
2020 Texas had
294,271 producing
oil and gas wells, so
venting and flaring
involves just a small
fraction of the
state’s oil wells.
FISCAL YEAR
FLARE PERMITS ISSUED
2020 4,521
2019 6,972
2018 5,488
2017 3,708
2016 4,870
2015 5,689
2014 5,313
2013 3,092
2012 1,963
2011 651
2010 306
2009 158
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Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
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Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
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Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Introduction
Gas must be used for lease
operations or sold if it can be
readily measured by devices
(meters) routinely used in
the operations of oil wells,
gas wells, gas gathering
systems or gas plants.
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Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Session Description
• Exemptions from the rule
– When does SWR 32 not apply? No metering
required!
• Authorized Flaring and Venting
– Flaring without an exception under special
conditions. Meter all gas and report on Production
Report.
• Flaring Exceptions
– What is required for an exception and what does
it do for an operator?
• Additional Information
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Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Exemptions
• Tank vapors from:
- crude oil storage tanks
- gas well condensate storage tanks
- salt water storage tanks
• Fugitive emissions of gas
• Amine treater, glycol dehydrator flash tank,
and/or reboiler emissions
• Blowdown gas from gas handling equipment
for construction, maintenance or repair
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Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Exemptions (cont.)
• Gas purged from compressor cylinders or
other gas handling equipment for startup
• Gas released:
• at a well site during drilling operations prior to
the completion date of the well must be
separated from drilling fluids using a mud-gas
separator, or mud-degasser
• During completion or re-completion (hydraulic
fracturing)
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Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Statewide Rule 32
• Exemptions from the rule
– When does SWR 32 not apply? No metering
required!
• Authorized Flaring and Venting
– Flaring without an exception under special
conditions. Meter all gas and report on Production
Report.
• Flaring Exceptions
– What is required for an exception and what does
it do for an operator?
• Additional Information
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Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Gas Releases to be Flared or Vented
• The Commission may require flaring of releases of
gas not readily measured if the Commission
determines that flaring is required for safety
reasons (e.g. high concentrations of H2S).
• All gas releases >24 hours duration shall be burned
in a flare, if the gas can burn safely
• All gas releases of ≤24 hours duration may be
vented to the air if not required to be flared for
safety reasons (contact District Office for
verification)
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Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Gas Releases Authorized by Rule
Authorized gas releases during production operations
must be measured (metered) and be reported on
monthly Production Reports. Flaring beyond the
limits set in the following scenarios requires an
exception to be granted.
• Produced gas not to exceed 10 producing days
after initial completion, recompletion in
another field, or workover in the same field.
• Gas that must be unloaded from a well may be
vented up to 24 hours in one continuous event
or up to 72 cumulative hours in one month.
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Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Gas Releases Authorized by Rule (cont.)
• Gas from a lease production facility may be
released for up to 24 hours in the event of a
pipeline or gas plant upset.
• Gas contained in waste stream from molecular
sieve or membrane gas treatment unit, provided at
least 85% of inlet gas is recovered and directed to
legal use.
• Low pressure separator gas, up to 15 mcfd for gas
wells, 50 mcfd for oil leases or commingled points
(gas must pass through separator, heater-treater,
free-water knockout, or other low-pressure
equipment prior to release).
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Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Gas Releases from Gas Gathering System or Gas Plant
• May be released for up to 24 hours in the
event of a pipeline or gas plant upset.
Notify the local District Office as soon as
reasonably possible after release begins.
• If gas plant operator presents information
that shows necessity of release is justified
beyond 24 hours, operator may continue
to flare gas. Operator must file exception
request within one business day after
first 24 hours of release.
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Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Statewide Rule 32
• Exemptions from the rule
– When does SWR 32 not apply? No metering
required!
• Authorized Flaring and Venting
– Flaring without an exception under special
conditions. Meter all gas and report on PR.
• Flaring Exceptions
– What is required for an exception and what does it
do for an operator?
• Additional Information
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Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Exceptions (1 of 5)
• Application is made using the Online System found at:
https://webapps.rrc.texas.gov/security/login.do
• Application can also be made on form R-32, which can be
downloaded from our website,
https://www.rrc.texas.gov/oil-and-gas/oil-and-gas-forms/
• Fee of $375.00 per gas well, oil lease, or commingled
vent/flare point [see SWR 32(h)(8) for a special situation].
• Exceptions not made via the Online System may be sent by
fax or email, provided a signed original request,
accompanied with fee, is received by Commission within 3
business days
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Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Exceptions (2 of 5)
• Current practice for administrative exceptions:
– 45 to 60-day term for pipeline capacity issues
and system upsets
– 90-day term for lack of pipeline
• May be renewed administratively for up to a total
of 180 days.
• Exceptions for more than 180 days may only be
granted through a hearing with a final order signed
by the Commission.
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Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Exceptions (3 of 5)
• When an operator files for a hearing to go beyond the 180
days, it is now required that form R-32 and filing fee be filed
with the hearing request letter.
– Information Required:
• Hearing Request Letter
• Service List (names & addresses of offset operators)
• Form R-32
• Filing Fee
• May be indefinitely approved administratively with
adequate justification if less than 50 mcf/day
• Documentation required for permanent exception
• Form R-32
• cost benefit analysis
• map showing nearest pipeline capable of accepting gas
• estimate of gas reserves
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Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Exceptions (4 of 5)
• If additional time is requested, the operator
must re-file within 21 days BEFORE the
expiration of existing exception.
• If re-filed within 21 days, the operator is
authorized to continue flaring/venting until final
approval or denial of the requested exception
extension.
• If the operator files for extension less than 21
days before expiration or after expiration of the
exception, and continues to flare during
processing of request and the request is denied,
the operator may be subject to administrative
penalties
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Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Exceptions (5 of 5)
• Each filing (re-file) must be accompanied by form R-32
and $375 fee.
• Not transferable upon a change of operatorship
• Operator has 90 days to re-file the exception once the
P-4 transfer has been approved
❖ Update:
o The RRC is no longer back-dating exceptions. Operators
are expected to comply with the filing time
requirements set out in SWR32.
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Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Exceptions – Paperwork Helpful Info (1 of 4)
• Renewal: provide existing Exception #
• Include the Operator Number
• Provide the RRC Lease ID if assigned; if not,
then provide the Drilling Permit No.
• If applicable, provide the Form H-9
Certificate No. and the hydrogen sulfide
concentration in ppm.
• Requested flare rate should be in mcf/day.
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Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Exceptions – Paperwork Helpful Info (2 of 4)
• If the case goes to hearing, form R-32 and
fee are required.
• Include the flare exception number and a
copy of the final order, with form R-32.
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Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Exceptions – Paperwork Helpful Info (3 of 4)
• “Explanation” portion of form R-32:
– Generally, flaring is considered to create waste,
so if the operator claims it is to prevent waste,
they should be prepared to give a detailed
explanation.
– Explanations need to detail why the operations
cannot be shut-in and;
– How all legal uses for casinghead gas have been
investigated and exhausted.
– Insufficient Explanation Examples:
• Economics
• Mineral Owner might be damaged
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Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Exceptions – Paperwork Helpful Info (4 of 4)
• “Method of Measurement” portion of form
R-32:
– Must provide an actual method of measurement
– SWR32 does allow for estimation of the
volumes; however, the method used to estimate
must be given.
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Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Statewide Rule 32 Exception Data Sheet
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Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Statewide Rule 32 Exception Data Sheet (1 of 3)
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Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Statewide Rule 32 Exception Data Sheet (2 of 3)
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Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Statewide Rule 32 Exception Data Sheet (3 of 3)
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Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Statewide Rule 32
• Exemptions from the rule
• When does SWR 32 not apply? No metering
required!
• Authorized Flaring and Venting
• Flaring without an exception under special
conditions. Meter all gas and report on PR.
• Flaring Exceptions
– What is required for an exception and what does
it do for an operator?
• Additional Information
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Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Additional information
• An automated system check is run for
exceptions if flaring is indicated on Production
Reports
• If flaring production is not permitted, operator will
automatically be sent a Notice of Violation (30
days), a Notice of Intent to Sever by certified mail
(30 days), and then a severance letter, if
compliance is not achieved.
• An exception extension may be denied if no
progress is made to eliminate necessity for
flaring.
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Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
January 2014 Notice to Industry
• …unauthorized venting or flaring of gas may
constitute waste. SWR 32 prohibits venting or flaring
of gas under certain conditions unless authorized by
the Commission. … Any venting/flaring of casinghead
gas or gas well gas not authorized by SWR 32 or by
exception may be subject to administrative penalty
action.
• An operator whose application to vent or flare gas is
denied in whole or in part has the right to request a
hearing before the Commission.
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Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Frequently Asked Questions
• Website – http://www.rrc.texas.gov
• Search “Flaring Frequently Asked Questions”
– Why does RRC grant flaring exceptions?
– Does RRC allow long-term flaring?
– Does RRC track how much has been flared?
– How many venting and flaring exceptions have
been issued in Texas?
– What percentage of total gas is reported flared?
– How does RRC regulate flaring?
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Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Oil and Gas District Offices
• San Antonio
• Houston
• Corpus Christi
• Kilgore
• Abilene
• San Angelo
• Midland
• Wichita Falls
• Pampa
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
District Offices
District City Address Phone
1 & 2 San Antonio
112 East Pecan St, Suite 705
San Antonio, TX 78205
(210) 227-1313
3 Houston
1919 N. Loop West, Suite 620
Houston, TX 77008
(713) 869-5001
4 Corpus Christi
10320 IH 37
Corpus Christi, TX 78410
(361) 242-3113
5 & 6 Kilgore
2005 North State Highway 42
Kilgore, TX 75662
(903) 984-3026
7B Abilene
3444 North First St, Suite 600
Abilene, TX 79603
(325) 677-3545
7C San Angelo
622 South Oakes St, Suite J
San Angelo, TX 76903
(325) 657-7450
8 & 8A Midland
10 Desta Dr, Suite 500 E
Midland, TX 79705
(432) 684-5581
9 Wichita Falls
5800
Kell Blvd, Suite 300
Wichita Falls, TX 76310
(940) 723-2153
10 Pampa
200 West Foster, Room 300
Pampa, TX 79065
(806) 665-1653
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Statewide Rule 32 Exception Contacts:
Nathan Nattin Bill Heard, PE
Engineering Specialist Engineer I
Phone: 512-463-6785 Phone: 512-463-7230
Tim Speer, PE- Austin Office
Engineering Unit Manager
Email: T[email protected]
Phone: 512-463-6452
Railroad Commission of Texas | June 27, 2016 (Change Date In First Master Slide)
Evaluation & Archive Video
Evaluation
• Please complete the evaluation available on
the RRC website at
https://survey.alchemer.com/s3/6403402/202
1-RRC-Regulatory-Webinars-Oil-Gas-and-
Pipeline-Safety-Evaluation
Archive Video
• A link to the archive video of the webcast will
be available on the same webpage as the
presentation.
