The Texas Railroad Commission (RRC) took another step toward flaring mitigation

The Texas Railroad Commission (RRC) took another step toward flaring mitigation efforts on Nov. 4, approving changes to a form concerning requests by operators to flare or vent gas.
Changes to the exception data sheet aim to improve the effectiveness of Statewide Rule 32, which states that all gas—whether from a well, gathering system, plant or other handling equipment—must be used. The rule, which aims to prevent waste, specifically prohibits flaring of associated gas from initial completion beyond 10 producing days. However, oil and gas companies may request an exception. Flaring may be necessary for safety reasons such as in cases of overpressured equipment.
As explained by the RRC, the data sheet changes—which take effect immediately—require companies seeking exception to the rule to more thoroughly document the need to flare gas and provide the RRC accurate information to assess compliance, encouraging transparency in grasping reasons and needs for flaring or venting during oil and gas production operations.
“I think this is a good step forward as we continue to look at flaring and what we ought to be doing better,” RRC Chairwoman Christi Craddick said during the meeting.
“I think this will be a good addition to the tools we have at the agency,” she added.
The action, which was unanimously approved Nov. 4 by commissioners, was taken amid heightened concerns about emissions and responsibly producing oil and gas to meet future energy needs. It also comes as parts of the world moves toward cleaner energy sources plus increased scrutiny by investors over ESG initiatives.
Higher oil production in the state, driven by the Permian Basin, led to rising levels of flared gas in the past. However, flaring has been decreasing this year due to a slowdown in activity as the coronavirus pandemic impacts demands.
Certain operators have also made it a priority to reduce flaring, putting gas to use, utilizing technology and making sure infrastructure is in place before bringing a well online.
During the Nov. 4 meeting, commissioners also approved several exception requests.
Unlike the current one-page exception data sheet, the revised four-page form has several documentation requirements. For example, operators must provide proof of the unavailability of a gas pipeline or marketing facility and show how avoiding curtailment of gas would result in less ultimate recovery of hydrocarbons.
“The new form greatly enhances collection of critical data points and in some cases significantly reduces flare duration,” said Paul Dubois, assistant director for technical permitting in the RRC’s oil and gas division.
Revisions to the form, now called Form R32, were presented to commissioners on Aug. 4 and more than two dozen individuals, operating companies, trade associations and non-governmental organizations shared thoughts on the proposed changes during a comment period that ended in early September.
An online filing system to support the Rule 32 program is also in the works. Dubois said plans are for the system to go live by the end of March. Until then, oil and gas operators may file the new form or use the current data sheet until April 1.
“Once the online system is implemented, the current Rule 32 data sheet will be phased out and discontinued,” Dubois said.