samuel short, manager air permits division texas commission on environmental quality advanced air...

Hot Topics in Oil and Gas Permitting

Samuel Short, ManagerAir Permits Division

Texas Commission on Environmental QualityAdvanced Air Permitting Seminar 2015

Topics for Discussion

Submitting Applications

ePermits

Updates to NSPS

Draft CTG for the Oil and Natural Gas Industry

Aggregation of Oil and Gas Sites

Mild to Moderately Hot Topics

Administrative Documents

The preferred order for your administrative documents is:1. Cover letter2. Core Data Form3. PI-7;PI-7CERT;APD-CERT4. Copy of your check or ePay voucher

Cover Letter

Core Data Form

PI-7; PI-7CERT; APD-CERT

Copy of check or ePay voucher

Technical Documents

The preferred order for technical documents is:1. Introduction2. Table of Contents3. Process and flow diagram4. Summary of emissions5. Emission calculations6. Impacts analysis/NAAQs7. Applicability8. Lab analysis9. Maps10.Tables and ePay voucher

IntroductionTable of Contents

Process & Flow DiagramEmissions Summary

Emission CalculationsImpacts Analysis/NAAQS

ApplicabilityLab Analysis

MapsTables

STEERS ePermitting System

What can I register with it?

All PBRs

Oil and Gas Standard Permits

Am I required to use it?

STEERS – How fast is it?

All 75 PBRs that don’t require registration will have a same-day response.

STEERS – Oil and Gas Projects

New!Same-day response (if specific parameters)

Company will receive authorization letter

Staff will periodically review these submittals manually

Rule SelectionWhat if I select the wrong rule?

Can I edit my application after I have received my authorization letter?

Example: Registered for §106.352(l) instead of §106.352(a)-(k)

STEERS Screenshot

STEERS What Not to Do

No Level 1

or Level2 option

Displays Rule ComplianceNo (a

)-(k)

Hotter Topics

Methane and VOC Standards

Proposal to amend NSPS OOOO and OOOOa by setting standards for methane and VOC

Proposal published in Federal Register on September 18, 2015

Sources AffectedCompressors (centrifugal and reciprocating)

Pneumatic controllers and pumps

Hydraulically fractured wells (well completions)

Well site and compressor station fugitives

Natural gas processing plant equipment leaks

Pneumatic PumpsNew, modified, and reconstructed natural gas-

driven and diaphragm pumps

Requires emission control by 95% in all source categories except natural gas processing plants

For natural gas processing plants, emissions of methane and VOC must be zero

Hydraulically Fractured Wells

Non-exploratory & non-delineation wells

Reduced emissions completions, aka green completion

Combustion device

Exploratory & delineation wells

Combustion device

Fugitive Emissions Monitoring

Defines fugitive emission components

Requires use of optical gas imaging

Sets leak monitoring schedule:

Includes incentives for minimizing leaks

Includes requirements for repairing leaks and resurveying

Electronic ReportingRequires electronic submittal of reports

(CEDRI)

May require reporting quantitative environmental results on corporate websites

Control Techniques Guidelines

Control Techniques GuidelinesDraft published in Federal Register on

September 18, 2015

Recommendations for evaluation of VOC RACT for existing sources in ozone nonattainment areas classified as moderate or above

Sources Affected by Control ChangesStorage vessels

Equipment leaks from natural gas processing plants

Compressors and pneumatics

Fugitive emissions

Source Determination

EPA ProposalOption 1 - within ¼

mile

Option 2 - within ¼ mile or greater than ¼ mile with functional interrelatedness

Texas StatuteWithin ¼ mile and

operationally dependent

Contact Information

Samuel Short Air Permits Division

(512) 239-5363samuel.short@tceq.texas.gov

Air Permits Main Line: (512) 239-1250airog@tceq.texas.gov