samuel short, manager air permits division texas commission on environmental quality advanced air...
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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) [email protected]
Air Permits Main Line: (512) [email protected]