SOCIETY OF PETROLEL!!ENGINEERS OF AI!

T2 PAPER
~.mER SPE 48! I
6200 North Central Expressway
Dallas, Texas 75.206

THIS IS A PREPRINT --- SUBJECT TO CORRECTION

Clean Air and the Petroleum Industry in West Texas

By

Charies Gregory Smort, ITexsxAtY C!ontml Board

@)Com’right 1974
American Institute of MiningIMe~aIlu-rgical, and Petroleum Engineers, Inc.

Th~S paper ~JeS p~epa~ed for the Permian Basin Oil Recovery Conference of the SocietY of
.-r,
Petroleum Engineers of AIME, to be held in Midland, Tex., March 11-12, 1Y(4. Permission to cGpY
is restricted to an abstract of not more than 300 words. Illustrationsmay not be copied. The
abstract should contain conspicuousacknowledgmentof where and by whom the paper is presented.
Publication elsewhere after publication in the JOURNAL OF PETROLEUM TECHNOLOGY or the SOCIETY OF
PETROLEUM ENGINEERS JOURNAL is usually granted upon request to the Editor of the appropriate
journal provided agreement to give proper credit is made.

Discussi~n of this paper is invited. Three c~pies of any discussion should be sent to the
Society of Petroleum Engineers office. Such discussion may be presented at the above meeting and,
the pq?er> may be considered for publication in one of the two SPE magazines.
‘witP.

ABSTRACT in the state and for setting standards, cri-

For a number of years +he oil zfiti
gas fields
of West Texas have supplied Texas and the
nation with large amounts of fossil fuel. In
recent years the Texas Air Control Boaxd has
adopted regulationswhich directly affect
the exploration,production, and processing
of these energy sources. The purpose of
this paper is to show how adopted air pollu-
tion control re.~lations affect the various
phases of development of these fuel sources
in this age where concern for both a clean en-
vironment and abundant energy supplies is
paramount.
INTRODUCTION
In 1967, the 60th Texas Ligislatme passed
the Texas Clean Air Act. The stated purpose
of the Act was to “...safeoqardthe air re-
sources of the state from pollution by con-
trolling or abating air pollution and,
emissions of air contaminants,consistentwith
the protection of health, general welfare,
and physical property of the people, including
the esthetic enjoyment of the air resources
by the people and the maintenance of adequate
visibility.”1 The Act establishesthe Texas
Air Control Board as the state air pollution
control agency, and names the Board as the
“principal authority in the state on matters
relating to the quality of the air resources
References and illustrationsat end of paper.
teria, levels, and emission limits for air
contaminantsand pollution control.”2 The
Act also provides for an Executive Director
to be administratorof air control activities
for the Board. His responsibilitiesinclude
any and all things necessary to achieve the
purposes and objectives of the Act and to
provide general supervisionover all personnel
employed by the Board. The Executive Director
has established 12 Air Quality Control Regions
in the state. Within each region the Executive
Director has established a regional office at
a convenientlocation. These regions and their
correspondingregional offices are designated
in Figure 1. The Regional Supervisor is rE-
sponsible for the operations of the regional
office as well as all air pollution control
activitieswithin his assigned region. In
January 19’72a regional office of the Texas
Air Control Board, Air Quality Control Region
,’ -.A-L?<oh A + (kkss3j Texas. From
0, was ebb&UL....eud
the time of establishmentof the Odessa regional
office it became apparent that the largest
number of air pollution problems in the region
were those directly related to the production
and/or processing of oil and gas from the
rich deposits in West Texas. This paper is
concernedwith the air pollution problems
encounteredby the oil and gas industry in
West Texas, and how that industry might operate
in compliancewith the Reomlations established
by the Board. Although this paper provides a
convenient outline for determininga facility’s
posture with respect to present air pollution

108 CLEAN AIR AND THE PETROLE1 INDUSTRY IN WEST TEXAS
I,Regfiationsin the State of Texas, there can
be no substitute for referring directly to
the Act and Regulations of the Board in
questions concerning compliancewith the law.
GENERAL RULES
The General Rules of the Air Control Board
provide guidelines and definitionsby which the
rest of the Reofiations of the Board may be
interpreted. Importantparts of the General
Rules presented for your considerationin this
paper are as follows:
Definitions.
Circumvention.
Nuisance.
NotificationRequirements for Maintenance.
NotificationRequirements for Major Upsets.
Sampling.
. Exemptions from Rules and ReOg@ations.
?finitionsfor terms commonly used by the Air
mtrol Board and its staff are given in Rule 1
f the General Rules of the Board. Definitions
sed in this paper and consideredrelevant to
ctivities in the oil and gas industry in West
exas are as follows:
. Act . The Texas Clean Air Act, codi-
% as Article 4477-5.
. Combustion Unit. Any boiler Plant>
furnace, incinerator,flare, engine,
or other device or system used to
oxidize solid, liquid, or gaseous
fuels, but excluding motors and ‘n-
~ines used in propelling land, watery
and air vehicles.
). Condensate. Liquids that result from
the cooling a,nd/orpressure changes of
produced natural gas. Once these liq-
uids are processed at gasoline plants,
refineries? or in any other manner,
they are no longer considered conden-
sates.
4. Downwind kVd. The concentrationof
air contaminantsfrom a source or
sources on a propetiy as measured at
or beyond the pruperty boundary.
5. Flue. Any duct, stack> chi~eY> ‘r
~uit used to conduct air contaminants
into the open air.
6. Major Upset. An unscheduled occurrence
SPE 4811
>r excursion 0S a process UL UPC*CV
;~on~~a~ .“.—
~aw;lts ———an emission of
in
-.--,.
Lir contaminantsthat contravenes
;he Texas Air Control Board Re.@a-
;ions and/or the intent of the ‘TeXas
:lean Air Act and is beyond immediate
?ontrol, or a release that is initiated
Lo protect life in the immediate or
adjacent areaS.
Net Ground-LevelConcentration. The
upwind level subtracted from the down-
wind level.
New SOUrCe. Any stationary source, the
‘n or modification of which
is commenced ai%er the date of adoption
of these regfiations”
The degree to which an emission
L?Ewzk
of air contaminmts obstructsthe trans-
mission of light expressed as the per-
centage to which the light is obstructed
as measured by an optical instrument
or trained observer.
Outdoor burning. Any fire or smoke
producing process which is not conducted
in a combustionunit.
Process or Processes. Any action,
oneration,
~. or treatment embracing
chemical> co~erci~y industrial~
or manufacturingfactors such as
combustionunits, kilns, stills,
dryers, roasters, and equipment used
in connectiontherewith, and all
other methods or forms of manufacturing
or processing that may emit smoke!
particulatematter, gaseous matter,
or visible emissions.
Property. All land under common con-
trol or ownership on which any source
or combinationof sources is located,
coupled with all improvementson such
land, and all fixed or movable objects
on such land, or any vessel on the
waters of this State which may consti-
tute a source.
r4-Al.-
DI[luAe
.
~,,LaAL~~~-~g~fi~m=.rticles
Cs,.w,ll =_-_—._.
‘ing from incomplete combustion
consistingpredominantlyof carbon
and other combustiblematerial and
present in sufficientquantity to be
visible.
CIn,,v
““u.!.
P.sc Afiynatrmal gas containing
“w” .
~ one and one-half (1-$)grains
of hydrogen sulfide per one hundred
{.nn) -...k: - .FaA- “- .
n-P -----~han thirty
mfwv
~~’gl~;l ~;;tal sulfur per one
lundred (100) cubic feet.
m 4811 CHARLES GREGORY SHORT
15. Sour Crude. A crude oil which will
emit a sour gas when in equilibrium
at atmosphericpressure.
16. Source. A point of origin of air
contaminants,whether privately or
publicly owned or operated. Upon
request of a source owner the Execu-
tive Director shall determine whether
multiple processes emitting air con-
taminants from a single point of emission
wiu be treated as a single source or
as a multiple sources.
17. Standard Conditions. A condition at
a temperature of 70% and a pressure
.l..Al,,+a
of 14.7 pounds per square iiichl
~LJou&~.-.
Pollutant concentrationsfrom an incin-
erator will be correctedto a condition
of 5C$ excess air if the incinerator
is operating at greater than 5~0 excess
air.
18. Sulfur Compounds. All inorganic or
organic chemicals having an atom Or
atoms of sulfur in their chemical
structure,
19. Sweet Crude Oil and Gas. Those crude
petroleum hydrocarbonsthat are not
r!
sour” as defirled.
20. Upwind Level. The representative
con”centratlon ---~-...~m
n+c
of aii’~ULltiuil&A.a
....
flowing onto or across a property as
measured at any point.
21. Visible Emissions. Particulate or
gaseous matter which can be detected
<y the human eye. The radiant energy
from an open flame shall not be con-
sidered a visible emission under this
definition.
Rule 4 of the General Rules is the Board’s
statement on any attempt to circumventthe
Re=wlations. C&cumve~tion may be thought
of as an attempt by an operator to misrepresent
emissions at any given point in time by
applying certain operating procedures that
might not be present under ordinary operating
conditions. Introducing excess air or re-
ducing feedstock to a given process in an
effort to demonstrate less emissions than
could be expected during normal operating
conditionsmay be construed as circumvention.
For example, tple~ta~f of t.b.e
B~ard
~QWS OIIIy5(3?0
excess air to be used in the
calculationof the allowable S02 emission
rate from the tail-gas incineratorof a
sulfur recovery Imit. The use of greeter
than 5@ air in the calculationof such an
allowable would be interpretedby the staff
as an effort to circumventthe Re=glations.
This is not to say that greater than 5W0
air could not be utilized in the tail-gas
incineratorfor cooling purposes. However,
for the purpose of calculatingthe allowable
emission rate for pollutants from the incinera-
tor, 5W0 excess air shall be the maximum
allowed. Any activity which might be illegal
and noticeable during daylight hours, done
during the hours of darkness to escape de-
tection,.also comprises a circumventive
activity. Examples of such activity would
-1
incltitie7.-:.o honvy
f~-....a..-. hydrocarbonswith smokej
burning tank bottoms, burning parafin, or
by-passing abatement equipment normally used
during daylight hours.
The Nuisance provision of the Generai Rules is
to provide an effective means for dealing
with situationswhere air pollution problems
may not be adequatelyhandled by specific
regulations. Rule 5 of the General Rules
states that no person shall cause a condition
of air pollution such as to adversely affect
human health or welfare, animal life> vegetation
or property, or as to interferewith the
normal use and enjoyment of animal life,
vegetation, Or property. If a facility pro-
cessing hydrocarbons is emitting into the air
certain compounds not covered by specific
re=tiations,and these compounds are inter-
fering with a person’s normal use &z6 enjoyw=nt
of his property in whatever way, this consti-
tutes a violation of the General Rules of
the Board by the operators of the processing
facility. The possibility exists that offen-
sive odors may be created at any hydro-
carbon processingfacility. Problems
associatedwith odors eminating from such a
facility may be effectively controlledby
the General Rule on Nuisance.
Rule 7 of the General Rules states that the
Executive Director and the appropriate local
air po31ution control agency shall be notified
as soon as possible of any major upset con-
dition which causes or may cause excessive
emissions as defined by the Act or ReQ@a-
tions of the Board. A major upset is defined
as an upset over which the operator has no
immediate control. However, it would not
be practical for the Board to concern itself
statewidewith all upsets which meet this
general definitionbut are of extremely short
duration. In general, any upset which can
be corrected in 10-15 minutes, and is correc%-
ed, can be.considereda minor upset. The
operator of such
.,a source should make record
ca+c ~.o
of the upset but noz rep~i% s’uek.
up....
L%
~f~eE~e~,JtiveDirector. Records of such
minor upsets will serve three purposes:
1. A member of the Boardfs staff may ob-
serve an excessive emission and question
.10 CW AIR AND THE PETR
the operator of the source as to why such
an emission took place. If records are
properly kept, the source operator will
be able to respond with the statement
that a minor upset had occurred during
that period.
2. If complaintsare received from the gen-
eral public concerningemissions during
a minor upset, the source operator will
be able to respond to the investigator
and the complainantby referring to prop-
erly kept records.
3. Frequent upsets may indicate to the source
owner that maintenance should be performed
on abatement equipment, etc.
Upsets of longer duration constitutemajor
upsets and must be handled accordingly. A
suitable reaction to a major upset condition
which produced excessive emissions would be
as follows:
1. The source operator should notify the
region~ office by phone relating the
details surroundingthe upset.
?
-. A Report Form for NotificationRequirements, of the Board, as stated in Rule 12.2 of the
similar to the one shown in Fiogure2%should General Rules. An exampie of plaiiiied wx?&nten-
be completed and sent to Austin.
In addition,thelocal air pollution control
agency, if any, should be notified. In Region
6, the only active local air pollution control
program is operated by and within the Ector
County Health Department. It should be men-
tioned that non-routine conditions,whether
minor or major, that occur regularly over an
extended period of time are not considered
upsets covered by this Rule. Such re=gular
‘.ipSe*S ZR cor2sidered an integral part of the tion Requirements. The reason for report-
daily uperation of the source for compliance
purposes. Poor facility maintenance,poor op-
erating techniques, or failure to maintain
air pollution control equipment at appropriate
efficienciesat all times, will not be accepted the flare system during this outage, excessive
as excuses for upset conditions.
An example of a situationwhich would require
notification of an upset to the Board would
be the failure of a sulfur recovery unit
processing the acid gas from a gas processing
plant to function properly. The inlet acid
gas from the gas processing plant to the sulfur
plant would have to be routed through a proper
flare or incinerator in order that examination
of condensers,reactor ‘Deals,etc., Wlight6E=
termine the cause of the malfunction of the
unit. This flaring or incinerationwould
probably result in excessive ground level
concentrationsof sulfur dioxide. The proper
response of the plant operator would be to
call the regional office giving the details
-,..
01”Xne uvset such as ..n.w,n+
of g~~ tQ ~~
w,,UU...
RTIMTNT)TJSTRY
---- TN WEST
--.—-—-- -- —-. —-— TEXAS
—— SPE 4811
flared, concentrationof hydrogen sulfide
in that gas, and probable duration of the
outage. He would also notify the local air
pollution control agency, if any, giving the
same information. The plant uperator would
then fill out a Report Form for Notification
Requirementsand send this form to the Execu-
tive Director in Austin. The Board is not
so naive as to expect immediatenotification
of upsets when action is required on other
fronts by a source operator in order to pre-
serve human or animal life or protect property.
Rowever, as soon as practicallypossible,
the source operator should report the upset
to the proper agents.
Rule 8 is similar to Rule 7 in that it allows
emissions in excess of the Re=@_ationsto
exist, but as a result of ylanned maintenmce.
The Rule requests that ten days advance
written notice be given to the Executive
Director in Austin concerningthe details of
a planned maintenance outage that might
cause excessive emissions from a facility.
A copy of the notice should be mailed to
the regional office. Emission levels to be
allowed during planned maintenanceprocedures
may be determinedby the Executive Director
ance requiring notificationof the Board
muld be the outage of a boiler used to pro-
duce steam for use in a smokeless flare.
Many of these boilers must be inspected
periodicallyby the state for safety
reasons. Since the boiler inspection must
be scheduled,this constitutesa planned
maintenance outage. The source operator
should notify the Executive Director of the
time and approximate duration of the outage
as required on the Report Form for Notifica-
ing such pl~ed ~intenance would, .be ~na~ ~ne
outage of the boiler would mean that no
steam would be available to the smokeless
flare system. If material must be flared in
visible emissions could result.
Rule 9 of the General Rules states that any
persons operating a source which emits air
pollutants into the air of the state shall,
upon request of the Board or the Executive
Director, conduct samplin~ to characterize
such emissions. It also states that the
results of such sampling should be forwarded
to the Executive Director. Although the
@fie ~ta~es the Executive Director can specify
the method by which sampling will be done,
the operator of a source may elect to pro-
pose to the Executive Director an alternate
method of sampling the emissions from his
facility. If that alternatemethod is accepted
by the Executive Director, the operator of
the source may use that alternate method to
m 48u CHARLES GIU?GORYSHORT
characterizethe emissions from his facility
and report the results of such sampling to
the Executive Director. It should be emphasized
that no monitoring is required of any source
unless specificallyrequired by the Executive
Director. Copies of all sampling data collec-
ted as a result of a requirement of Rule 9
shall be retained by a source operator for
at least 5 years.
Many requests have been received by the Execu-
tive Director to allow an alternate nethod of
monitoring by material balance to be used
in fulfillmentof Rule 9 requirements. The
general position of the Executive Director
has been to require sampling by in-stack methods
to determine the in~tial complianceposture
of a facility. If, during this stack sampling,
material balance tests are performed on the
facility and these tests support and agree
with the stack sample, the alternate method
of monitoringusing material balance cal-
culations may be allowed.
Rule 12 states that under certain conditions
the Executive Director may allow exemptions
from certain Rules and Regulations of the
Board. Careful inspection of this Rule by
a source operator will reveal whether an
operator’sparticular problem might fall in
an area where the Executive Director has
authority to limit the applicabilityof a
Rule or Re.@iation.
A particularly importantpart of the General
Rules pertains to the right of persons to
petition the Board to consider any air pollu-
tion control problem that he might have.
The Board and the staff are aware that in
many cases solutions to problems concerning
air pollution control are not found easily.
If the operator of a source has a problem
which he believes deserves special considera-
~iOn for---
UIl~- h~c +h~ ~nortunity
~e~~~?.,..=----...--==-.
h.
to petition the staff and/or the Board for an
%udience. In cases where a person has not
achieved compliancewith the Re@l.ations,he
may request a variance from certain Regula-
tions of the Board. The Board will review such
a request in view of past complianceefforts,
economic hardships, etc.
REGULATION I
The main portions of ReOgation I which
directly concern the oil and gas industry
are those referring to open burning and visible
emissions from flares or stacks. In the past,
Re=@ations of the Board have allowed linited
burning of parafin, tank bottoms, etc.>
at the location where produced, if the loca-
tion was sufficientlyisolated. This is not
allowed in present Regulations of the Board.
The only open burning of waste hydrocarbons
ermitted is done as a result of pipeline
111
breaks and oil spills, if disposal by,any
other means is not practical.
Visible emissions from a stationary flue
are not to exceed an opacity of thirty per
cent averaged over a five-minuteperiod.
If the stationary flue was constructedafter
January 31, 1972, the visible emissions must
not exceed twenty per cent opacity averaged
over a five-minuteperiod. These are opacitY
readings as taken by a qualified observer. The
Board recognizes a qualified observer as one
who has successfullycompletedthe state’s
course on evaluating visible emissions and
been recertifiedwithin the previous six
~TLorJ~pL.s
. ~+e ~&Qo~ On visible emissions
is offered in Odessa every six months. Defi-
nite dates, times, and locations may be ob-
tained from the Region 6 Office.
Regulation I also states that no visible
emissions may be permitted from a waste gas
flare for more than five minutes in any two-
hour period. The waste gas flare referred
to in this Reo@ation is one which is attempt-
ing to c~lete~ combust all,waste process
hydrocarbons from a processing facility. Rtie
103.2 of Reo@Lation I is not referring to
the sometimesvisible whi~emissions from
an acid gas flare at a gas processing plant.
REGULATION II
Rules governing the operation of Sulfur
Recovery Units processing acid gas from gas
processing plants are stated in Regulation
II. Specifically,Rule 201.03 gives the
allowable emission rate of sulfur dioxide
for a specified standard effective stack
height and stack effluent flow rate. This
allowable may be found from Table 1 and/or
Figure 3. However, if the effective stack
height is less than the standard effective
stack height, as found in Table 2 and/or
Figure ~, the allowable emission rate ~id~~
be reducedby multiplying it by the following:
(
Effective Stack Height 2
Standard Effective Stack Height)
lhe effective stack height of the stack at
a sulfur recovery facility may be calculated
using the following equation:
he = h + 0.083veDe
Where:
he . Effective stack height in feet (N)
h = Physical stack height above around
level in feet (ft)
Ve . Stack exit velocity in feet per second
De (fi/see)
= Stack exit inside diameter in feet (I%)
112 CLEAN AIR AND THE PETROLE :1NDUSTR% IN WEST TEXAS
Te = Stack exit temperature in degrees
Rankine (%)
No additional credit is given on allowable
emission rate if the effective stack height
is greater than the standard effective stack
height. It must be emphasized that this method
of calculationof allowable sulfur dioxide
emission rates is for sulfur recwery plants
only.
If a facility has a stack or flare emitting
sulfur dioxide not covered by Rules 201.01,
201.02, 201.0~, 201.0hj 201,05j 201.06: the
only restriction on allowable emission rate
is that which is required to meet a maximum
ground level concentrationof 0.40 ppm
measured at or beyond the property line of a
facility. Many equations and complex com-
puter programs are available to those who would
predict the ground level concentrationat a
sourcets property line based on various sul-
fur dioxide emissions within the property
boundaries. Equations and programs used
by Texas Air Control Board staff are avail-
able to interestedparties upon request.
Other than ground level concentration re-
strictions,the only restriction on a.liquid
fuel fired steam generator, furnace, or
heater is a 440 ppm, by volume, allowable
in-stack concentrationof sulfur dioxide.
Due to the shortage of comparativelylow-
sulf’urfuels for use in firing heaters and
boilers, many companiesmay find it necessary
to operate facilities on a temporary basis using
high-sulfur fue~~. ‘I% B~ard has specified
that any person expecting excessive sulfur
dioxide emissions as a result of such tem-
porary operation using high-sulflu fuels
should file a Temporary Fuel Shortage Control
Plan as outlined by Regulation II. The
acceptance of such a plan by the Board de-
pends on the operator’s ability to show the
non-availabilityof low-sulfur fuels as well
as the predicted consequencesof the usage of
high-sulfhr fuels for temporary shortages.
Any person who must operate under his Tem-
porary Fuel Shortage Plan should notify the
Executive Director of the Board and the local
air pollution control agency, if any, as soon
as possible of the fuel shortage causing the
utilization of his plan. Notification of
such a situation should include the estimated
duration of the shortage as well as any signif-
icant consequencesthat may be caused by utili-
zation of the Plan. Any person who operates
under a Temporary Fuel Shortage Control Plan
must submit to the Board semi-annuallya
record of the fiels used at his facility
during the preceding six months, as well as
any efforts he has made to avoid future use
of his Temporary Fuel Shortage Control Plan.
ML- ..--.--L“.
LlleLcaDull +-fiW
~~~o,firiP1g
~,2c~A
~ ShioV+,~.Ue
- --o-
Control Plan is to give operators of sources
SPE 481]
until December 31, 1976, to find or manufac-
ture appropriate supplies of low-sulfur fuel.
In this era of fuel conservationand short-
age, it seems appropriateto mention two
areas of air pollution control that may
possibly be operationallyaltered in order to
provide for fuel savings. At the present
time incineratorsof tail-gas on sulfur
recwery units are operating at temperatures
in the 1100o F to 1300°F range. However,
stack samples conductedby the State as well
as consulting firms, indicate that stack
temperatures lower than 11OOOF in some cases
may result in nearly complete combustion of
all available sulfur to sull%r dioxide. The
Board not only entertains,but encourages
requests for the operation of such stacks
at lower temperaturesproviding sufficient
justificationin the form of sampling data
is submitted. Another similar area where
a distinct possibility of fuel savings exists
is in the combustion of hydrogen sulfide to
sulfur dioxide at a flare tip. Most gas
processing plants which do not have sulfur
recovery plaii*sor FJigFL Rfi”ds *P
-. ~~~~gAQ
dioxide in the acid gas use such flares in
conjunctionwith their acid gas treating
units. It may be possible to reduce the
supplementalfuel gas to the flare without
causing a deteriorationin the combustion
characteristicsof the flare. These are
two areas in which the interest of fuel
conservationand adequate air pollution con-
trol may be satisfied by careful engineering
evaluation.
In addition to rules governing emissions of
sulfur dioxide, Regulation II of the Board
contains Rules for the control of hydrogen
sulfide emissions. A maximum ground level
concentrationof 0.08 ppn for a thirty-
minute sample is allowed if the downwind
concentrationof hydrogen sulfide affects
a property used for residential,business,
or commercialpurposes. A maximum ground
level concentrationof 0.12 ppm for a thirty-
minute sample is allowed if the downwind
concentrationof hydrogen sulfide affects
only property used for other than resi-
dential, recreational,business, or commercial
PWoses, such as industrialproperty and
vacant tracts and range lands not normally
occupied by people. An allowable emission
rate for a stack emitting hydrogen sulfide
can be calculatedusing methods shown in
Appendix A of Regulation II.
For property where the source of hydrogen
sulfide emissions is a bulk storage facility
for sour crude, the emission rate will have
to be determinedby ground level sampling at
the facility. For the purposes of such sam-
pling, the property line for a crude oil
storage facility shall be outside the area
!P?7Ml 1 CHARLES GREGORY SHORT
obviously set aside for oil and/or gas pro-
duction. The production area wL1l generally
be inside a fence or caliche pad or other-
wise cleared area provided for the installa-
tion and use of the storage facility. This
method of property line determination
obviously assumes the owner or operator of
.. . ~ .
mot,gwn or lease
an oIL am gas lease doe. ...
the surface rights associatedwith his
mineral lease. These procedures also
apply to facilitieswhere stored water
or other stored material might cause sig-
nificant amounts of hydrogen sulfide to be
released into the air.
REGULATION
Regulation V, Control of Air Pollution from
Volatile Carbon Compounds, is not applica-
ble in any counties within Air Quality
Control Region 6 at this time.
REGULATION VI
Until this point in the paper, the Control
of Air Pollution by Permits for New Con-
struction or Modification,Regulation VI,
has purposely been ignored. This is in
order that most of the importantpoints
pertaining to the Board’s permit system
may be discussed at one time. Rule 601
and 602 of Reg~ation VI state:
Rule 601. Section 3.27 (a) and Section
3.28 (a) of the Texas Clean
Air Act require any person
who plans to construct any
new facility or to engage in
the notificationof any exist-
ing facility which may emit
air contaminantsinto the air
of this State to obtain a
constructionpermit from the
Texas Air Control Board
befc-.
Au -..O
anv actual work is
begun on the facility, and
to obtain an operatingpermit
from the Texas Air Control
Board in order to continue
to operate the facility after
a sixty day start-up period.
Rule 602. The owner of the facility or
the operatwof the facility
authorized to act for the owner
is responsible for applying
for and obtaining a permit to
construct and operate.
The Texas Air Control Board considers
—. s
;i-~one
control of alr poliuticiiby per.m...
of the most effective means of controlling
air pollution with a minimum of time,
expense, and effort. A minimum of time,
because control of air pollution problems
113
generallybecomes more difficult after a source
is already built and in operation. A minimum
of expense, because the control of air pollu-
tion from a source already in operation is
generally more complex and requires considera-
bly more down time than would have been required
if controls were designed and implemented
before start-up of the facility. Msny times
the permits system wili require cmtrols
which may not seem to be justifiable. However,
experience has shown in many cases that the
controls have paid for themselves in recovery
of products or by-products. In addition,
there have often been design errors in process
informationsubmitted to our permit system
.. .—--- a .~a b~nmqht
which have ‘beenalscuv=~-eu=..ti.s-o.. to the
attention of the potential source operator
prior to the constructionof the facility. As
a result of the above reasons, and the re-
quirements of the Act, the following procedures
form general .midelines for use of the permit
system:
1. Engineering design of source is completed.
2. Particular attention is given to the loca-
tion of the source.
3. A general applicationto construct a
source is completed and submittedto
the Board.
4. A constructionpermit with appropriate
prwisions is received.
5. Constructionof the facility is started.
6. The Board is given thirty days notice
prior to start-up of facility.
7. The facility begins operation.
8. Emissions of the facility are character-
ized as required by constructionpermit.
9. Within sixty days aIfter start-up of tke
facility, an operating permit is requested,
and sampling data, if any, is submitted.
0. An operating permit is received.
At this point it should be noted that many
sources are small enough that, although they
emit air contaminantsinto the air of the State,
contaminantsare present in such small amounts
that the sources can be considered insignificant.
In order to allow the permit engineers to exam-
ine only the proposed sources which will be
significant,a list of exemptions from permit
procedures has been prepared, and is available
from the Executive Director upon request. If
a Potential source is included in the ii~t
of exemptions, it is automaticallyexempt from
any and all permit procedures. No written
request need be made to the Board unless a
.14 CLEAN AIR AND THl?PETROL M INDUSTRY IN WEST TEXAS
sCxl.Zz ce opera.t~rhas special questions concern-
ing l~hetheror not a source might qualify
for one of these exemptions. If an operator
believes his proposed source to be insignifi-
cant, he should petition the Board in writing.
In his letter to Austin, he should state the
basic parameters which describe the operation
of the source he desires to construct.Based
on this information,the permit section will.
either uphold or deny his request for an
exemption. If denied, he must submit a
complete permit package and obtain a construc-
tion permit before constructionis started.
Two exemptions relating to facilities on oil
or gas producing properties deserve special
mention. These exemptions, 76 and 77, are
as follows:
Temporary separators,tanks, meters,
and other fluid handling equipment
used, for a period not to exceed thirty
(30) days, to test the content of a
subsurface stratum believed productive
of oil or gas, provided that all
emissions to the atmosphere other
than stock tank vapors be flared.
Temporary separators,heaters, flow
treaters, meters, storage tanks,
and other fluid handling equipment
used, for a period not to exceed
ninety (90) days, to establish the
proper design of a permanent fluid
handling facility for an oil or gas
producing property, prwided that
all emissions to the atmosphere
other than stock tank vapors be
flared.
Before giving a detailed procedure as to how
these exemptions may best be utilized,
it will probably be profitable to give an
explanation as to why the exemptionswere
created. When the permit system was first
established,many oil companies contacted
the Board because of their concern with having
to procure a permit from the Board prior to
producing oil or gas from a recently completed
well. Most objections centered around the
problem of knowing the compositionor rate of
emissions into the atmospherewhich would
result from such production. Many objections
also pointed to the fact that it is advanta-
geous to be able to produce from a completed
oil or gas well as soon as possible. A two
or three week wait for a permit might prevent
much needed fuel from being produced and
transported to the user. Based on these
objections and others, exemptions 76 and 77
were created. It should be noted that the use
of the word temporary in exemptions 76 and
77 may be somewhat unconventional. Temporary
tanks, heaters, etc., are temporary only be-
cause they may change as a result of increased
SPE 4811
or decreased production from an oil or gas
-,
well or as a resul~ of origi~lal iM!OHeCt
sizing of differentparts of the facility.
Using exemptions 76 and 77 can be beneficial
to an operator in producing oil smd gas
immediatelyand complyingwith all Regulat-
ions of the Texas Air Control Board. A
typical procedure to be used incorrectly
applying exemptions 76 and 77 would be as
follows:
1. The well is completed.
2. Exemption 76 is invokeq and separators,
tanks, treaters, and other necessarY
~teria~ are b~~~~b.t%Q the well site
in order to produce the oil and/or gas.
Exemption 76 requires that all emissions
,.+ka-+h=n
to tineatmosphere UWG.
.Q+.ock-tSdC
. ... .. -.
vapors be flared. This exemption may
be used for a period of 30 days. During
these 30 days the exemption is specifi-
~z~L~ra.?lowed
---- - in order that a producer
might test and characterizethe content
of the zone producing the oil and/or
gas.
3. If additional time is needed to character-
ize the emissions of the producing
facility? exemption 77 may be used.
This exemption allows an additional 90
days to establish the proper design
for the equipment to be used in proper-
ly producing the oil and/or gas. This
exemption also requires that all
emissions to the atmosphere other than
stock tank vapors be flared.
4. During the period of time that one or
both exemptions have been invoke~ the
producer should take measurements of
the oil and/or gas of the composition
and rate in order to determine the
emissions from the facility. Applica-
tion should then be made for a construc-
L.
~iofiper,nit,Jsingthe data that has
been gathered during this period.
5. A constructionpermit is issued with
appropriateprovisions.
6. An operating permit application is for-
warded to the Board, along with any
additional informationrequired by
provisions of the constructionpermit,
-.:&L:..
Wlbul.11 Ln UO.J”
WV a-r. AA
~vnm
“L,. +.h=
“..- T~c~~pt of the
constructionpermit.
7. The operatingpermit is received.
It can be seen from the above rrroceduresthat
exemptions 76 and 77 greatly simplify the
responsibilitiesthat oil producers have in
obtainingproper permits from the Board and
allow plenty of time for the proper collection
SPE 4811 CHARLES GREGORY SHORT
of necessary operating data. Several other
exemptionsthat tmaybe usefhl to oil and gas
producers are the following:
1. Gas fired internal combustionengines
of less than 2000 hp and engine trains
of less than 5000 hp total.
2. Natural gas or LP gas fired combustion
units with rated fuel consumptionless
than 10,000 standard cubic feet per hour.
3. Equipment used exclusivelyto store
or hold dry natural gas.
4. Containers,reservoirs, or tanks used
exclusively for unheated storage of
organic materials with initial boiling
point of 300°F or greater.
5* Containers,reservoirs, or tanks used
exclusively for the storage of fuel
oil with a gravity of 25 degrees API
or lower; or for the storage of lubri-
cating oils.
6. Containers,reservoirs, or tanks used
exclusively for the storage of fuel
oil with a gravity of 40 degrees API
or lower; or for the storage of lubri-
cating oils.
7. Containers,reservoirs, or tanks with a
capacity of 6,OOO gallons or less used
exclusively for the storage of organic
liquids, except gasoline, normally used
as solvents, diluents, or thinners; inks;
colorants;paints; lacquers; enamels;
varnishes; liquid resins; or other
surface coatings.
8. Containers,reservoirs, or tanks used
exclusively for the storage of asphalt.
9. Storage tanks with a capacity of less
than 25,000 gallons, used exclusively
for the storage of asphalt.
10. Stationary crude oil and condensate
storage containers of 50,000 gallons
or less in which only sweet crude oil
is stored.
11. Gas dehydrationunits in fields process-
ing sweet crude oil.
12. Gas oil separators.
13. Natural gas or LP gas fired emulsion
treaters with rated fuel consumptionof
less than 10,000 standard cubic feet
per hour.
14. Free water knock-outs.
115
15. Identical replacement in whole or in
part of any article, machine or any
other contrivance.
16. Gas turbines of less than 20,000 hp
burning sweet natural gas.
17. A stationar.vtank, reservoir, or other
container u~ed for the storaie of
liquid petroleum gas (L.P.G.), if
such tank, reservoir, or other container
is a pressure vessel capable of main-
taining working pressures sufficient
at all times to prevent vapor or gas
loss to the atmosphere.
REGULATION VIII
Reg~a,tion VIII, Control of Air Pollution
Emergency Episodes, does not apply to
Region 6 because no priority I levels of any
of the appropriatepollutants have been
recorded in the Region.
SUMMARY
It is hoped that these observationswill aid
oil and gas industry personnel in complying
with Texas Air Control Board Rules and Regula-
tions while producing the oil and gas we
need so much. Careful engineeringassessment
of problems as well as frequent communication
between the industry and the Board will
bring about suitable solutionsto any problems
that may be presented. The staff of the
Board is willing to discuss the requirements
presented in this paper as well as any other
problems which may prohibit or enhance good
and effective Industry-Boaxdrelations.
ACKNOWLEDGETIENTS
The author wishes to express his appreciation
to the Texas Air Control Board for permission
to present this paper. He also wishes to
express his appreciationto the oil and gas
industry in West Texas for its part in making
his job of establishi%~and operating the
Regional Office for Air Quality Control Region
6 in Odessa, Texas, such an enjoyable and
worthwhile task.
REFERENCES
1. Vernon’s Texas Civil
—. Statutes, Article
J477-5.
9
L. Th+d
A-----
Rules and Regulations,Texas Air Control Board.
 TABLE 1

SULlwR RECOVERYPLANTS

ALLOWABLESULFUR DIOXIDE EMISSION BASED ON

SPECIFICFLOW RATES

EFFLUENTFLOW RATE RATE OF EMISSION

Scfn lb/hr

1,000 214
2,000 305
396
l;ro 487
5,000 579
6,000 6’70
7,000 759
8,000 845
9,000 929
10,000 1012
20,000 1766
30,000 2447
40,000 s084
50,000 3690

Interpolationand extrapolationof the data in this Table for stack effluent

flow rates less than or equal to 4,000 scfm shall be accomplishedby the use
of the equationE = 123.4 + 0.091 q’,whereE istheallowable emission rate
in lbjhrandq is thestackeffluent
flowratein scfm. Interpolarionand
extrapolation
of thedataforstackeffluentflowratesin excessof 4 000
scfmshallbe accomplished E = 0.614 q o.Bo~2.
by theuseof theequation

TABLE 2

SULFUR RECOVERYPLANTS

STANDARDEFFECTIVESTACK HEIGHT
BASED ON SPECIFICFLOW R4TES

EFFLUENTFLQW RATS STANDARDEFFEC1’IVE

STACK KEIGHT
scfm ft

100 85
500 96
1,000 109
2,000 129
3,000 148
4,000 164
5,000 178
6,000 192
7,000 204
8,000 215
9,000 226
10,000 236

20,000 311
30,000 366
40,000 411
50,000 450
60,000 484
80,000 544
100,000 595
Interpolationand extrapolateion of the data for stack effluentflow rates
less than or equal~ 4,000 scfm shall be accomplishedby the use of the
equationHe = 7.4 @.L + 0.091 ~ 0“5, where He is ~& ~~~~~~~~~f’f~gt ~~~
-J
stack height in feet and q is the stack effluent flow rate in scfm. Inter-
polation and extrapolationof the data for stack efl-~uentin excess of b,000
scfm shall be accomplishedby the use of the equationHe . 5.8q 0.402.
 I I I
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Air Quality Control Regions

1. Abilene-WichitaFalls
2. ‘o-Lubbock
3. Austin-Waco
4. Brownsville-Laredo(Harlingen)
5. Corpus Christi-Victoria
6. Midland-Odessa-SanAngelo
7 Un,,c+nn-cslveston
b; ‘F;;<.~;rth
9. San Antonio
“.,-l O_..AL--”“.Tm.7<.inns-~~lJtheBSt T
=Lu. i)uublleL1l Ll”uL.JAk----
(Beaumont)
*11 . El Pa-ruces-Alamogordo
*12. ‘rt-Texarkana.-Tyler

+Interstate Regions
Cities where Regional Office is located is underlined.
FORM NO. AG-6($969)

Fig. 1 - Texas Air Control Board regional offices.

 REPORT FORM FOR NOTIFICATIONREQUIREMENTS
FOR MAJOR UPSET (RULE 7), PLANNED MAINTENANCE (RULE 8), START-UP OR S~DO~

NLSSLAccount No. Region (This line for State only)

Company Name
Plant Location
Mailing Address City State Zip
Ownerj Operator or ResponsibleMan%”ement
Telephone No.

Nature of Unit or l%oeess Affected (and other processes affected, if any)

Inclusive Dates if for Shutdown and Start-up

Time antiExpected Duration of Excessive Emissions
Reason or Cause: Maintenance Major Upset
Explanation
•1 ❑

Level of Emissions (give basis for estimate): Physical and Chemical Composition,Rate,
Concentration,and Duration

Measures (to be) Taken to Minimize Quantity and Duration of Emissions:

...+a.+-~~;.~d
Measures (to be) Taken to Prevent Recurrence (if nub UG”G.>ILA..U
@j give date when
measures will be submitted)

Date, Time, and Means of Notification (letter,telephone, etc):

Executive Secretary
Regional Office
Local Program

Fig. 2
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