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

AIROG@tceq.texas.gov.pdf 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

airog@tceq.texas.gov

www.texasoilandgashelp.org

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