Texa s O il a n d G a s A ir P erm ittin g: $ 3 UD FWLWLRQ ...oilandgasconference.org/presentations/bryanOsborne.pdf · $ 3 UD FWLWLRQ HU·V * X LG H NOVEMBER 28 - 29, 2017 | HOUSTON,

BRYAN OSBORNE

SALLY BITTICK, P.E .

ZEPHYR ENVIRONMENTAL CORPORATION

Texas Oil and Gas Air Permitting: A Practitioner’s Guide

NOVEMBER 28 - 29, 2017 | HOUSTON, TEXAS

Purpose


Presentation Overview

Intent

Ba

ckgro

un

d

Specifics

Case Studies

Authorization Overview

Preconstruction Permits Operating Permits

Permits by Rule (PBR) Title V

Standard Permits

Case by Case Permits


Documentation Options

De Minimis Activities

Unregistered Permits

Under what conditions do sites not require registration with the TCEQ? ◦ Sites with engines < 240 horsepower

◦ Sweet sites (< 24 ppm H2S)


When does a site require registration with the TCEQ? ◦ Sites with engines > 240 horsepower

◦ Sour sites (> 24 ppm H2S)

◦ Sites requiring controls to meet permit limits

◦ Modifications to existing registrations

◦ Engine replacements

◦ Addition/Removal of equipment

◦ Change in operations

◦ Increase in production

Registered Permits

Simple oil and gas sites ◦ Low site-wide emission limits (<25 tpy VOC or SO2)

◦ No receptors within ¼ mile of a sour site [106.352(l) only]

◦ Minimal monitoring and recordkeeping requirements

◦ Can construct and operate immediately

◦ No permit expiration date, $450 Registration fee

• Common O&G PBR Authorizations

◦ Oil & Gas [30 TAC 106.352(a)-(k) or (l)]

◦ Flares [30 TAC 106.492], Engines/Turbines [30 TAC 106.512]

◦ MSS Activities [30 TAC 106.359]

Permits by Rule (PBR)

Permit by Rule: 352(l)

Category Permit Specifics

Timing Sweet Gas Sites – no waiting period

Sour Gas Sites – up to 30 days for TCEQ review

Control/Emission

Requirements

Follow 106.492 (flare design) & 512 (engine NOx

limits and NOx impacts eval.)

Minimum vent height of 20’ for H2S sources – higher

depending on lb/hr rate

MSS Activities

Can be authorized under either:

106.352(l) (general O&G PBR)

106.359 (MSS specific PBR)

Impact Assessments Sweet Gas Sites – NAAQS

Sour Gas Sites – no receptors within 1/4 mile

Tech. Requirements Very few specific requirements other than

referenced PBRs

Permit by Rule: 352(a)-(k) “Barnett Shale PBR”


Timing Immediate notification, up to 30 days for TCEQ review

Control/Emission

Requirements

Equip. distance to property line, engine

requirements, open top tanks, quarterly LDAR,

destruction efficiency, combined control

MSS Must be included in PBR 106.352 (a)-(k)

Impacts Required for NO2, SO2, H2S, and Benzene

unless trivial

Tech. Requirements Much more prescriptive than 106.352(l)

Two Types of Standard Permits for Oil & Gas Sites:

1. Section 116.620 (Installation and/or Modification of Oil and Gas Facilities)

2. Non-rule (Barnett Shale) Standard Permit for Oil and Gas ◦ Effective February 2011 and optional for sites located outside of Barnett Shale

Suitable for oil and gas sites with higher emission rates

◦ Increased monitoring and recordkeeping requirements (vs PBR)

◦ Increased control requirements (vs PBR)

◦ Impacts evaluation demonstrating compliance

◦ Can operate within 45 days (116.620) or immediately (w NRSP notification)

◦ Permit is good for 10 years, $900 registration fee

Standard Permits

Standard Permit: 116.620


Timing Up to a 45 day TCEQ review

Control/Emission

Requirements

Follow 106.492 & 106.512 requirements

Emission limits subject to 106.261/262

review (<6 lb/hr of each speciated VOC)

MSS Activities Std. Pmt. 116.620 or PBR 106.359

Impact Assessments VOC/H2S subject to 106.261/262 review

NO2 and SO2 (SCREEN3 is common)

Tech. Requirements May require LDAR

NonRule Standard Permit (NRSP)


Timing Immediate notification, up to 30 days for TCEQ review

Control/Emission

Requirements

Equip. distance to property line, engine

requirements, open top tanks, quarterly

LDAR, destruction efficiency, combined

control

MSS Activities Must include in NRSP (no PBR option)

Impact Assessments NO2, SO2, H2S, and Benzene

Tech. Requirements More prescriptive than 116.620 Std. Pmt.

NRSP: Emission Limits

Confused? NOVEMBER 28 - 29, 2017 | HOUSTON, TEXAS

What equipment (facilities) should be included in the permit?

SB1134 from the 82nd Legislature, effective 6/17/2011, applies to PBRs and Std. Permits

◦ Aggregation of facilities:

◦ Are under common control

◦ Belong to the same first two digits of the SIC code

◦ Operationally dependent

◦ Located not more than ¼ mile from each other

Aggregation Issues

Owned

Leased

Authorization Selection Criteria

Facility Size

Timing

Emission Limits

Technical Requirements

Operational Flexibility


PBR STD. PERMITS CASE BY

CASE

Scenario 106.352 116.620 NRSP NSR

Low prod., basic equip.,

sweet gas

X

Higher Prod., basic equip.,

sweet gas

X X X

High H2S (sour site) X X X

Compression X X X

Central Facilities (tanks,

loading, compression)

X X X

Gas Processing (Midstream) X X X

Multi-train Gas Processing X X

O&G Permit Sweet Spots


CASE



sweet gas

X


sweet gas

X X X


Compression X X X



X X X





CASE



sweet gas

X


sweet gas

X X X


Compression X X X



X X X





CASE



sweet gas

X


sweet gas

X X X


Compression X X X



X X X





CASE



sweet gas

X


sweet gas

X X X


Compression X X X



X X X





CASE



sweet gas

X


sweet gas

X X X


Compression X X X



X X X





CASE



sweet gas

X


sweet gas

X X X


Compression X X X



X X X





CASE



sweet gas

X


sweet gas

X X X


Compression X X X



X X X




What if I need something bigger?


More operational flexibility?

New Source Review (NSR) or Case-by-Case Permit

Oil & gas site that cannot meet Standard Permit Limits or those that need more flexibility.

◦ Permitting time is 10 – 14 months

◦ Public notice is required

◦ Best Available Control Technology (BACT) Requirements

◦ Detailed dispersion modeling required, including MSS emissions

◦ Expect detailed permit conditions including recordkeeping

◦ Registration fee is variable based on capital cost (up to $75,000)

◦ Permit is good for 10 years

Case by Case Permits

Even bigger?


Prevention of Significant Deterioration (PSD)

Major oil & gas site that exceeds 250 tpy of a criteria pollutant OR a named source (refineries, petroleum storage/transport >300k bbl, sulfur recovery) that exceeds 100 tpy of a criteria pollutant

◦ Permit time is 12 – 16 months

◦ Public notice is required

◦ Significant modeling effort

◦ Permit will have major source modification triggers

Case Studies


Case Studies


Case Study A An existing unauthorized production facility and associated saltwater disposal handling sour gas with VOC emissions <25 tpy are being permitted. The site is close to a structure that appears to have RV style trailers parked nearby.

Sour gas – must be registered, 352(l)?

Proximity to RV trailers may prohibit 352(l)– 352(a)-(k)?



TCEQ Definitions:

Homes, Schools, daycare, hospital, places of worship, parks, etc.

Exclusions:

Structures owned by mineral lease holders who have a financial stake in the O&G operation

Hunting Camps

Storage Sheds

What is considered a receptor? 106.352(l)

Case Study A (cont.) An existing unauthorized production facility and associated saltwater disposal handling sour gas with VOC emissions < 25 tpy are being permitted. The site is close to a structure that appears to have RV style trailers parked nearby.

Sour gas – must be registered, 352(l)?

Proximity to RV trailers – 352(a)-(k)?

Staff in area advised that the RV trailers were part of a hunting camp.

Recommendation: TCEQ opinion did not consider the hunting camp a receptor since it was used seasonally/sporadically. PBR 352(l).


Case Study B An existing tank battery handling sweet hydrocarbons (authorized under a non-registered 352(l) PBR) will soon have several sour wells tied in, but VOC emissions are expected to stay below 25 tpy. Operations tells the EHS group that more well additions may be happening in the future. The tank battery is near a home, but this wasn’t a problem when the site was handling sweet fluids.

Sour fluids, will require registration – 352(a)-(k)

Emission limits – 352(a)-(k)


352(a)-(k) v. NRSP


Case Study B (cont.) An existing tank battery handling sweet hydrocarbons (authorized under a non-registered 352(l) PBR) will soon have several sour wells tied in, but VOC emissions are expected to stay below 25 tpy. Operations tells the EHS group that more well additions may be happening in the future. The tank battery is near a home, but this wasn’t a problem when the site was handling sweet fluids.

Sour fluids, will require registration – 352(a)-(k)

Emission limits – 352(a)-(k) or NonRule Std. Permit

Recommendation: While the site could be permitted under PBR 352(a)-(k), the BMP’s, recordkeeping & monitoring requirements are so similar to those in the NonRule, that the NonRule is appealing for the higher emission limits (especially considering future expansion).


Case Study C An existing gas plant is permitted under a NonRule Std. Permit with VOC totals ~60 tpy. The owner has plans to build a nearly identical second processing train at the same site. Along with the second train, operations requested that annual turnarounds be permitted for both trains.

Proposed Sitewide VOC total ~120 tpy – NonRule, 116.620 or NSR

Timeline – NonRule, 116.620 or NSR


Case Study C (cont.) An existing gas plant is permitted under a NonRule Std. Permit with VOC totals ~60 tpy. The owner has plans to build a nearly identical second processing train at the same site. Along with the second train, operations requested that annual turnarounds be permitted for both trains.



What if construction needs to begin in six months?






MSS – hourly MSS limits in NonRule are likely too low


NRSP: Emission Limits





MSS – hourly MSS limits in NonRule are likely too low

Recommendation: Std. Pmt. 116.620 + PBR 106.359 for MSS (no PBR hourly emission limits). Some timing flexibility is lost without the ability to submit NonRule notifications.


Thanks!


Thank you!

Bryan Osborne

Sally Bittick, P.E.

Zephyr Environmental

Corporation

[email protected]

[email protected]

Visit us at www.ZephyrEnv.com

and www.HazMatAcademy.com

mailto:[email protected]



TCEQ Memo 1/18/2006 O&G Standard Air Permit Guidelines

◦ Natural gas speciated to C3 through C5, and BTEX

◦ Condensate speciation for components making up 1% or more of the liquid

◦ C10+ v. extended analysis

◦ Crude oil does not require speciation (§106.261, 6 lb/hr & 10 tpy)

◦ H2S “L-value” of 10 instead of published value of 1.1 in 106.262

Standard Permit 116.620: Speciation

Leak Detection and Repair (LDAR)

LDAR requirements for facilities < 500 ft from receptor

◦ None: Less than 10 tpy of uncontrolled fugitives

LDAR requirements for facilities ≥ 500 ft from receptor ◦ None: Less than 25 tpy of uncontrolled fugitives

H2S or SO2 emitting facilities < ¼ mile from receptor

◦ Daily auditory and visual checks

Standard Permit 116.620: LDAR

Calculating Emission Rates of same compound from different EPNs for 106.262

Weighted Average Method – Example

E = L / K

H2S L value of 10 mg/m3

K value based on distance to nearest offsite receptor

EPN 1 - 10% of project lb/hr at 1000 ft: K=34



E=(10% x 10/34)+(40% x 10/14)+(50% x 10/8) = 0.94lb/hr

Standard Permit 116.620: E=L/K

Step 1:

“Prior to construction or implementation of changes for any project which meets this standard permit a notification shall be submitted through the e-Permits system.”

*Emission limits are established immediately after notification even if an application has not yet been submitted.*

Step 2:

“Within 90 days after start of operation or implemented changes (whichever occurs first), the facilities must be registered with a PI-1S Standard Permit Application.”

NRSP: Notifications

Compression turbines must meet Table 6 emission limits (25ppm NOx, 50ppm CO).

Power turbines [operated < 876 hours/yr] can operate at Table 6 limits (25ppm NOx, 50ppm CO) if no reliable electric power is available.

Power turbines [operated > 876 hours/yr OR those installed in locations with

reliable electric service] may be authorized if they can meet emission limits set in the TCEQ EGU Standard Permit, which will likely require SCR catalyst.

NRSP: Turbines

Documents

Texa s O il a n d G a s A ir P erm ittin g: $ 3 UD FWLWLRQ ...oilandgasconference.org/presentations/bryanOsborne.pdf · $ 3 UD FWLWLRQ HU·V * X LG H NOVEMBER 28 - 29, 2017 | HOUSTON,