Air Permitting in Louisiana Texas a guide to

Air Permitting in Louisiana & Texas a guide to compliance requirements presented by: Shonta’ Moore, MS Air Permitting Specialist - Environmental Division Client Focused. Technology Driven. C. H. Fenstermaker & Associates, L. L. C.

BACKGROUND • Clean Air Act Enacted in 1963 • Clean Air Act of 1970 (revised by Congress) • Amended in 1977 and again in 1990 • New Source Review and Federal Operating Permit programs • EPA sets limits on certain pollutants • State Regulations to uphold Federal Air Quality • State environmental agency administers the air permits program

STATE ENVIRONMENTAL AGENCIES Louisiana Department of Environmental Quality Texas Commission on Environmental Quality State agency responsible for upholding the federal air standards in Louisiana State agency responsible for upholding the federal air standards in Texas

FEDERAL REGULATIONS Clean Air Act (CAA) Clean Air Act of 1963 Amended 1970 Amended 1977 Amended 1990 These federal regulations established National Ambient Air Quality Standards (NAAQS) that each state must uphold.

NATIONAL AMBIENT AIR QUALITY STANDARDS (NAAQS) EPA has set national limits for these 6 “Criteria Pollutants”: Sulfur Oxides (SO 2) Particulate Matter (PM 10) Nitrogen Oxides (NO 2) Lead (Pb) Ozone (O 3) Carbon Monoxide (CO)

NONATTAINMENT AREAS EPA designated areas that do not meet the national air standards Significance: If your facility is located in a nonattainment area, stricter regulations apply.

LOUISIANA OZONE NONATTAINMENT PARISHES Ascension Iberville East Baton Rouge West Baton Rouge Livingston

TEXAS OZONE NONATTAINMENT COUNTIES Brazoria Chambers Collin Dallas Denton El Paso Ellis Fort Bend Galveston Harris Johnson Kaufman Liberty Montgomery Parker Tarrant Waller Wise

WHO NEEDS AN OIL & GAS PERMIT? Any oil & gas exploration, development, and production facility. A permit must be obtained PRIOR to constructing a facility NOTE: Construction means any person who plans to construct any NEW facility that will emit, or to modify any EXISTING facility that emits air contaminants.

COMPLIANCE When does a company need compliance assistance? • Drilling a Well • Laying a Pipeline • Constructing a Production Facility • Producing Hydrocarbon in a Field (Operating) • Acquiring or Selling Resources

COMPLIANCE Types of Compliance Assistance • Air Permits • Water Discharge Permits • LA- facilities located in coastal zones and wetlands • TX- facilities that require stormwater discharge (obtain permit from EPA) • Facility Documents • Greenhouse Gas Compliance • Environmental Assessments • Title III Compliance

CHANGE OF OWNERSHIP • Must report within 90 days (LDEQ); 30 days (TCEQ) • LDEQ/TCEQ may change permit, if necessary • If not reported w/in 30/90 days, permit is invalid. • If operating w/ invalid permit = potential penalties • Penalties = as high as $25, 000/day • Must use appropriate forms

PERMIT OPTIONS Applications • • • New facilities Existing facilities w/o permit Existing facilities w/ permit and facility changes: • equipment added • equipment deleted • production rates increase over permitted rates • equipment tests over permit limits Variances • • Well test flaring or venting Other temporary emission sources Administrative Amendments Change permit limits due to testing if changes are <5 TPY • Other administrative changes (typos, etc. ) •

SERVICES PROVIDED BY FENSTERMAKER • Permit Applications • Permit Modifications • Emission Inventory Questionnaire (EIQ) • Administrative Amendments • Variances • Changes of Ownership • Emission Inventory Submittal (EIS) reporting • Greenhouse Gas reporting • Toxic Emission Data Inventory (TEDI) reporting • Complete permit compliance assistance: coordinate required testing and record keeping • Interface with LDEQ/ TCEQ

WHAT TYPE OF EQUIPMENT REQUIRES PERMITTING? Point Source Emission Equipment - Any and all points of origin of air contaminants • Heater Treaters • Produced Water Storage Tanks • Line Heaters • Oil/Condensate Storage Tank • Glycol Dehydrator • Gas driven pumps • Compressors • Generators • Flares • Amine Units • Flash Gas Losses • Marine/Truck Loading • Waste Gas Disposal • Fugitive Emissions

FUEL COMBUSTION EQUIPMENT PM, SO 2, NOx, CO, and VOC Emissions Examples: Heater treater burners Line heater burners Glycol dehydrator reboiler burners Amine unit reboiler burners Flares limited to 0. 6 lbs/hr PM per MMBTU of heat input smoke from combustion must not exceed shade requirements

INTERNAL COMBUSTION ENGINES NOx, CO, and VOC Emissions Examples: Compressor Engines Generator Engines Saltwater Pump Engines >500 HP require testing: w/o converter = semi annually w/ converter = annual testing

STORAGE VESSELS VOC Emissions Examples: Produced Water Storage Tanks Oil/Condensate Storage Tanks > Standing and Working Losses > Flash Gas Losses

GLYCOL DEHYDRATORS VOC Emissions including BTEX & N-Hexane Exemptions: • If uncontrolled <9 TPY, then no control required • If operates <200 hrs/year, then no control required • If constructed prior to Oct 20, 1994, then 70% control efficiency required • If constructed after to Oct 20, 1994, then 85% control efficiency required

FLASH GAS LOSSES VOC Emissions Storage Tanks Heater Treaters Separators Results from depressurization of crude oil or condensate when it is transferred from a higher pressure to a lower pressure tank, reservoir, or other container. Can be a significant source of VOC emissions.

OTHER VOC SOURCES Loading Losses Waste Gas Disposal Fugitive Emissions

Questions & Answers Shonta’ N. Moore, MS Environmental Specialist C. H. FENSTERMAKER & ASSOCIATES, L. L. C. 5005 Riverway Dr. , Suite 300 Houston, TX 77056 713. 840. 9995 ext. 1435 shonta@fenstermaker. com Client Focused. Technology Driven.