Oil and Gas Air Permitting Guidance and Updates

Oil and Gas Air Permitting : Guidance and Updates Samuel Short, Manager Air Permits Division Texas Commission on Environmental Quality

Topics for Discussion �Permit Options �Application Process �Federal Updates �Frequently Asked Questions

Non-Barnett Shale Oil and Gas Options 30 TAC § 106. 352(l) - Oil and Gas Handling and Production Facilities 30 TAC § 106. 512 Stationary Engines and Turbines 30 TAC § 106. 492 - Flares 30 TAC § 116. 620 Installation and/or Modification of Oil and Gas Facilities Standard Permit Voluntarily use Barnett Shale mechanisms

Barnett Shale Counties Oil and Gas Options New – Projects constructed or modified on or after April 1, 2011 30 TAC § 106. 352 (a)-(k) Non-Rule Standard Permit for Oil and Gas Handling and Production Facilities Existing – 30 TAC § 106. 352 (l) 116. 620 Installation and/or Modification of Oil and Gas Facilities Standard Permit New equipment and upstream downstream affects must be done under new rules.

30 TAC § 106. 352(l) Sweet: No registration required Meet condition of the rule and 106. 4 limits Keep records. Vent heights no less than 20 feet Sour (> 24 ppm H 2 S): Registration required ¼ mile distance limit 4. 0 lb/hr limit of sulfur compounds (not including sulfur oxides) Vent height requirements change based on sulfur compound limit

Other Related PBRs 30 TAC § 106. 353 Temporary Oil and Gas Facilities • 90 days to test the content of a subsurface stratum to establish the proper design of a permanent facility • 4. 0 lb/hr limit of sulfur compounds (not including sulfur oxides) • Vent height requirements 30 TAC § 106. 351 Salt Water Disposal (Petroleum) • Requires registration • ¼ mile distance requirements for sour sites 30 TAC § 106. 512 Stationary Engines and Turbines • Requires registration, if >240 -hp • Requires NAAQS compliance demonstration 30 TAC § 106. 492 Flares • Specific design requirements • ¼ distance limit for sour sites

30 TAC § 106. 352(a)-(k) Notification and registration are required to be submitted using the e. Permits system Notification - Prior to construction or implementation of changes Registration Level 1 - Within 180 days from start of operation Level 2 - Within 90 days from start of operation

Impacts Review (Hourly and Annual) Effects Screening level (ESL): Benzene at the nearest receptor within specified distance • ¼ mile – Level 1 • ½ mile – Level 2 • State and Federal ambient air standards compliance demonstration • NO 2 • SO 2 • H 2 S 30 TAC § 106. 352 (a) – (k)

30 TAC § 116. 620 Standard Permit Why use: • Sour sites that can’t meet ¼ mile limit in § 106. 352(l) • VOCs are >25 tpy VOCs must be speciated using E=L/K Calculation techniques, emissions summary tables, etc. – same as a PBR application

Non-Rule Standard Permit Notification & registration online – STEERS (e. Permits) system Notify - Prior to construction or implementation of changes Register • Within 90 days from the start of operation Impacts – Same as § 106. 352 (a)-(k)

Planned Maintenance, Startup, and Shutdown (MSS) Planned MSS emissions may be authorized under: 106. 359 - Non-Barnett Shale • Used in conjunction with 106. 352(l) or 116. 620 Standard Permit 106. 352 (a)-(k), or the Non. Rule Standard Permit. Barnett Shale Planned MSS emissions do not include unplanned MSS, upsets, or emissions events.

Administrative Documents Preferred Order Cover Letter Core Data Form PI-7, PI-7 Cert, APD-CERT Copy of Check / epay Voucher

When do I need to Certify? Emission limitations for Title V applicability. Federal applicability Control/destruction efficiency claims Operating hours

Technical Documents Preferred Order Introduction Table of Contents Process and Flow Diagram Summary of Emissions Emission Calculations Rule Compliance Demonstration Applicability (NESHAP, NSPS, MACT) Lab Analysis Maps Supporting Documentation

Technical Documents Preferred Order Introduction Table of Contents Process and Flow Diagram Summary of Emissions Emission Calculations Rule Compliance Demonstration Applicability (NESHAP, NSPS, MACT) Lab Analysis Maps Supporting Documentation

Introduction On behalf of XYZ Inc. , I am submitting the enclosed permit by rule registration to authorize a sweet production facility in Anderson County. Equipment at the site consists of production separators, crude oil storage tanks; a produced water tank, a flare, loading, two heater treaters, and process fugitives. As documented in the enclosed registration package, these facilities are authorized under 30 TAC § 106. 352 and § 106. 492. If you have any questions, please call me at (512) 2345678.

Technical Documents Preferred Order Introduction Table of Contents Process and Flow Diagram Summary of Emissions Emission Calculations Rule Compliance Demonstration Applicability (NESHAP, NSPS, MACT) Lab Analysis Maps Supporting Documentation

Table of Contents TABLE OF CONTENTS PROCESS DESCRIPTION AND FLOW DIAGRAM. . . . 1 TABLE 1 A AND SUMMARY TABLE. . . 2 EMISSIONS CALCULATIONS. . . . 4 APPLICABILITY………………. . . . 34 LAB ANALYSIS……………. 36 MAP. ………………. . …. …. …. 37 MANUFACTURER DOCUMENTATION………. . 38

Technical Documents Preferred Order Introduction Table of Contents Process and Flow Diagram Summary of Emissions Emission Calculations Rule Compliance Demonstration Applicability (NESHAP, NSPS, MACT) Lab Analysis Maps Supporting Documentation

Process Description Produced fluids enter the site and flow through production separators and a heater treater to separate the oil, water, and gas. The crude oil is sent to six 500 -bbl crude oil storage tanks and then trucked off site. Water is stored in two 500 -bbl water tanks and then trucked off site. Emissions from the tank battery are controlled by a flare. The gas is sent to the sales pipeline. Fugitive emissions from valves, connectors, etc. are represented by EPN FUG.

Flow Diagram VRU Case Study Compressor Gas Sales VRU Separator Crude Tank 1 Tank 2 ct u d in ro P g I om c n Crude Pipeline

Technical Documents Preferred Order Introduction Table of Contents Process and Flow Diagram Summary of Emissions Emission Calculations Rule Compliance Demonstration Applicability (NESHAP, NSPS, MACT) Lab Analysis Maps Supporting Documentation

Summary of Emissions

Technical Documents Preferred Order Introduction Table of Contents Process and Flow Diagram Summary of Emissions Emission Calculations Rule Compliance Demonstration Applicability (NESHAP, NSPS, MACT) Lab Analysis Maps Supporting Documentation

Emissions Calculations

Technical Documents Preferred Order Introduction Table of Contents Process and Flow Diagram Summary of Emissions Emission Calculations Rule Compliance Demonstration Applicability (NESHAP, NSPS, MACT) Lab Analysis Maps Supporting Documentation

Rule Compliance Demonstration

Applicability NAAQS § 115, § 117, § 112 NSPS, MACT, NESHAP

Technical Documents Preferred Order Introduction Table of Contents Process and Flow Diagram Summary of Emissions Emission Calculations Rule Compliance Demonstration Applicability (NESHAP, NSPS, MACT) Lab Analysis Maps Supporting Documentation

Lab Analysis

Technical Documents Preferred Order Introduction Table of Contents Process and Flow Diagram Summary of Emissions Emission Calculations Rule Compliance Demonstration Applicability (NESHAP, NSPS, MACT) Lab Analysis Maps Supporting Documentation

Maps 1532 ft

Technical Documents Preferred Order Introduction Table of Contents Process and Flow Diagram Summary of Emissions Emission Calculations Rule Compliance Demonstration Applicability (NESHAP, NSPS, MACT) Lab Analysis Maps Supporting Documentation

Miscellaneous Supporting Documents Engine • Manufacture data sheet Flare Other • Control device manufacture data • Modeling data • Software reports

Hardcopy Submittal Mail Room • Check In • Delivery to Air Admin Staff • First Look • Deficiency Notification • Process File • Transfers to Reviewing Section Received by RR • First Look • Deficiency Notification • Review of Application • Letter of Authorization or ….

STEERS e. Permitting System What can I register with it? • All PBRs • Oil and Gas Standard Permits Am I required to use it?

STEERS – Oil and Gas Projects Same-day response (if specific parameters); Company will receive authorization letter; and Staff will periodically review these submittals manually.

NSPS OOOOa Overview What is NSPS OOOOa? • Applicable to Oil and Natural Gas facilities What does it address? • BSER for additional equipment and activities for VOCs and GHGs Compliance • If site is in compliance with NSPS OOOOa, it is assumed to be in compliance with NSPS OOOO

Modifications to to. NSPS Proposed Rule OOOOa from proposed rule • Fixed schedule • Method 21 • Six months to meet green completion requirements

NSPS OOOOa �What sources are affected? �Any source that has been constructed, modified, or reconstructed after September 18, 2015: � Centrifugal compressors � Reciprocating compressors � Pneumatic controllers � Pneumatic pumps � Well completions of hydraulically fractured wells � Fugitive emissions from well sites, gathering and boosting stations, and compressor stations � Equipment leaks at natural gas processing plant

NSPS OOOOa �What entities and affected facilities are potentially subject to the rule? Category Industry Type NAICS Codea 211111 Examples of Regulated Entities 211112 Natural Gas Liquid Extraction 221210 Natural Gas Distribution 486110 Pipeline Distribution of Crude Oil 486210 Pipeline Transportation of Natural Gas Crude Petroleum and Natural Gas Extraction a. North American Industry Classification System

NSPS OOOOa Single well is affected facility if: • It conducts a well completion Single well is affected facility if: operation after hydraulically • It a conducts athat well completion fracturing of well operation after hydraulically How do I of a well thatafter commencedfracturing construction commenced construction after determine if my September 18, 2015, 18, or September 2015, or well is an conducts a well completion • It conducts • a. Itoperation well after completion hydraulically affected facility? operation after refracturing for which hydraulically commenced after refracturing for which September 18, 2015 refracturing commenced after September 18, 2015

NSPS OOOOa Well site exceptions: � EPA defines a well site as one or more surface sites that are constructed for the drilling and subsequent operation of any oil well, natural gas well, or injection well. � This includes a separate tank battery surface site collecting crude oil, condensate, intermediate hydrocarbon liquids, or produced water from wells not located at the well site (e. g. , centralized tank batteries). �When is a site not subject to NSPS OOOOa?

LDAR & NSPS OOOOa �TCEQ will continue to evaluate LDAR programs: �Must use TCEQ recognized LDAR for reductions �Non-Rule Standard Permit and § 116. 620 LDAR

Updates �On March 2, 2017 EPA withdrew the 2016 information collection request for the oil and gas industry. �On April 4, 2017 EPA announced it is reviewing the 2016 Oil and Gas NSPS OOOOa and, if appropriate, will initiate reconsideration proceedings to suspend, revise, or rescind the rule.

Frequently Asked Questions (FAQs) �I am using a representative analysis for my oil and gas site; the site is sour. Do I need a site specific analysis for the H 2 S? �Do sites authorized under a PBR get 25 tpy VOC for planned MSS activities and 25 tpy for normal operations? �My floating roof tank is applicable to NSPS Kb. Do I have to comply with NSPS OOOO �Certification to limit tank emissions below the 6 tpy of VOC threshold

More FAQs �What does TCEQ consider a sour site? �Pro. Max, HYSYS, Win. Sim �Can I submit a § 106. 352 (a)-(k) project (Barnett Shale) as a hard copy? �My site is currently authorized under § 116. 620. Can I use § 106. 352 to add a piece of equipment?

E-Permit Contact Information STEERS Helpline • (512) 239 -6925 Sabrina Coty-Butler • (512)239 -1225 • sabrina. coty-butler@tceq. texas. gov Amber Huddle • (512) 239 -1595 • amber. huddle@tceq. texas. gov Britany Gilman • (512) 239 -944 • britany. gilman@tceq. texas. gov

Contact Information Samuel Short • (512) 239 -5363 • samuel. short@tceq. texas. gov Air Permits Main Line: • (512) 239 -1250