Hot Topics forOil & Gas Production
Authorizations
Anne M. Inman, P.E.Manager, Rules Registration Section
Erin Selvera, J.D.Special Assistant to Director
Air Permits DivisionTexas Commission on Environmental
QualityAdvanced Air Permitting Seminar 2014
Topics for Discussion
Workload
Authorization Processing
o Submittals – Complete applications:- Include site-specific or justification
o Pre-application meetingso e-Permitso Enhanced Application Review o AIROGo Electronic replies
ePermitting
o Currently available through e-Permitting (STEERS) for Barnett-Shale:
- Historical notification (deadline Jan 5, 2015)
- New/existing notifications for PBR or SP
- New/existing Level 1 and 2 registrations
- New/existing Non-rule SP registrations
e-Permitting(continued)
o Newly available in e-Permitting:- New/revision §106.352(l)
- New/existing SP §116.620
- PBR §106.359
- APD Certifications
- NSPS OOOO well completion/flowback notifications
- Change of Ownership
- All other PBRs and many SPs
Enhanced Application Review
o Purpose
o AIROG notification
o Expectations – necessary or critical items
o Reply
E.A.R
Electronic Documents & Replies
Electronic submittalse-Permits
[email protected] or .xls
Agency correspondenceFaster repliesEasily distributed
Authorization Types
o Notifications
o Certifications
o Voluntary registrations
o Registrations
o Registration & certifications (PBR and SP)
o Case-by-case permits (state & federal NSR)
Authorization Tools
o Authorization Processing:
- Spreadsheet updates
- Quality/Quick/Quantity processing
Small Crude Oil Sites
o Default emission estimates available
o Production of primarily crude oil
o Equipment = atmospheric separation, tanks, loading
only
o Must meet all of the following:
1. 10 bbl/day crude oil
2. 150 bbl/day water
3. Max 10,000 ppm H2S (1/4 mile limit)
4. Loading: submerged and dedicated normal
5. Minimum vent heights (> 20 feet)
Oil Field Waste Water Recycling and Recovery
o Need detailed process description:
- Wide variety of equipment configurations
o Identify air contaminant:
- Mixtures, concentrations
- Varies by source and type
o Possible authorizations under PBR include §§106.261,
106.262, 106.183, 106.472, 106.478, 106.352, 106.351
Flares & Combustion Devices
o Document type of control & efficiency
o Flares DRE 98% & 40 CFR §60.18
o “Sonic” flares
o “Combustors” - NSPS requires certification of
combustors by manufacturer or site-specific
sampling demonstration, DRE range 90%-99.9%
MSS Implementation
o Claim, register, or certify
o Default calculations for maintenance
o Guidance is now available:
- Inclusive of all emissions related to
root-cause
Pending Updates to NSPS OOOO
o Proposal published in Federal Register on July 17, 2014
o EPA refers to this as NSPS 1.5
o Final rule scheduled prior to January 1, 2015 REC compliance date
Pending Updates to NSPS OOOO
o Identify 3 distinct stages of well completions
o Clarify requirements for storage tanks
o Define low-pressure wells
o Clarify certain requirements for leak detection at natural gas
processing plants
o Update requirements for reciprocating compressors
o Update definition of “responsible official”
o Remove affirmative defense (from civil penalties) provisions
from startup, shutdown and malfunction
Pending Updates to NSPS OOOO
o 3 Distinct Stages of Well Completions:
1. Initial Flowback Stage
2. Separation Flowback Stage
3. Production Stage
Initial Flowback Stage
o Can use open top tank, frac tank, lined pit,
or other vessel
o No control requirement
o Gas can be vented
Separation Flowback Stage
o Route gas to flow line or collection system
o Re-inject gas, use as fuel, or for other useful
purpose
o No direct venting – flowback emissions must be
combusted using completion combustion device
o Liquids directed to completion vessel, storage
vessel, re-injected into the well or another well
(not required to route to “storage vessel”)
o May revert to initial flowback stage if flowback
becomes insufficient to maintain operation of
separator
Production Stage
o Separated crude oil, condensate, and
produced water must be routed to storage
vessels
o Begin 30-day process of estimating storage
vessel VOC PTE
o Must control no later than 60 days
o NO venting or flaring of gas
NSPS OOOO Strategy per EPA
o EPA is currently addressing the NSPS and NESHAP issues separately:
- NSPS-1, Storage vessel implementation revisions
- NSPS-1.5, Time-critical clarification of well
completion requirements
- NSPS-2, Remaining issues
- NESHAP
Greenhouse Gas Regulation
o Supreme Court decision effect on permitting
o EPA White Papers
Greenhouse Gas Permitting
o June 23, 2014 opinion:
- EPA may only require BACT for “anyway” sources if the
source emits more than a de minimis amount of GHGs
- 75,000 tpy may in fact be a reasonable de minimis level,
but EPA has to justify it on proper grounds
o July 24, 2014 EPA memo:
- “Anyway” sources – business as usual
- “Non-anyway” sources – permitting requirement no
longer enforced
EPA White Papers
o April 15, 2014: Released for external peer review
o June 16, 2014: Deadline submission of technical information from the public and for peer review to be completed
o Fall 2014: EPA will determine how best to pursue further methane reductions
o End of 2016: If EPA decides to develop additional regulations, complete those regulations
EPA White Papers
o Targets 4 key sources: Landfills Coal Mines Agriculture Oil and Gas:
• Compressors • Completions and on-going production of hydraulically
fractured oil wells • Leaks • Liquids unloading • Pneumatic devices
Expedited Permitting
o Implementation tools and guidance expected soon
o Oil and Gas PBRs and Non-rule Standard Permit do not require sites to wait for confirmation of authorization to operate
Where to Find More Information
Air Permits Main Line: (512) 239-1250
www.texasoilandgashelp.org
The Finish Line
