Obtaining and complying with air permits is critical part of the operation of oil and gas production facilities. Air permits are processed, approved and enforced by State environmental regulatory agencies unless located on Federal lands or waters. Regardless of the regulatory agency involved, there are several common things an operator can do to ensure easier permit approval and compliance.
State environmental agencies and Federal agencies such as the Bureau of Land Management (BLM) conduct routine inspections to ensure facilities have the proper air permits. In the future, these environmental regulatory agencies will continue to be the primary permitting and enforcement body for air permits for oil and gas operations.
Below are some helpful tips to assist in obtaining air permits quickly that can save an operator time and money.
- Where feasible, limit facility Potential to Emit (PTE) emissions to below Federal Title V/Part 70 Operating Permit limits and below Prevention of Significant Deterioration (PSD) emission levels. Facilities can then be eligible for an air permit under State minor source air permitting rules. Note that there are Federal and State emission standards that can require a facility’s PTE to be lower than major source levels.
- Obtain a State minor source under the State regulatory “Permit-by-Rule (PBR),” “General Permit” or “Standard Permit.” Facilities must comply with all requirements (PTE limits, emission standards and controls) of these types of permits. These permits have a faster approval time for the initial permit and for subsequent facility modifications.
- If the facility cannot qualify for a minor source PBR, General or Standard permit, then an individual minor source permit may be obtained. Individual minor source permit allow for more operational flexibility. These permits may require public notice and hearings based on comments received by the State agency.
- Ways to limit or lower PTE include:
- Limit throughput of crude oil, condensate, natural gas and produced water.
- Limit operating hours (e.g., engines, pneumatic pumps).
- Use emission control devices such as:
- Catalytic converters on engines
- Vapor recovery units (VRUs) to collect storage tank vent gas or heater treater flash gas
- VRUs or condensers for glycol still column vent
- Flares or enclosed combustors for vent gas
- Use compressed air for pneumatic pressure, level and temperature controllers. Also, use electronic devices instead of pneumatic (natural gas or air) controllers.
- Use electric or solar powered chemical injection and diaphragm pumps rather than pneumatic pumps.
- The permit application submitted becomes a representation that is the basis for the air permit. This means that application contents (e.g., process description, proposed action, calculations, throughputs, etc.) should be conditions that the facility can comply with.
- Keep a copy of the air permit application used to generate the current air permit with the current air permit document. This is needed since the air permit document received from the State may not have enough details to determine facility permit requirements.
- To obtain credit for reducing emissions using emission controls (VRUs, flares, enclosed combustors), always include the control devices in the permit application.
- Facilities should obtain an air permit that is an enforceable permit so that the PTE emissions meet State and Federal emission standards. Contact the appropriate State permitting agency for requirements.
- Where allowed, permit facility/equipment using annual throughputs of crude oil, condensate, natural gas and produced water. Permitting for annual throughput rather than daily throughputs gives operators greater flexibility if daily production rates vary.
- Use redundant or backup emission controls (VRUs, flares, enclosed vapor combustion devices) to minimize facility emergency upset and bypass reporting requirements. If a Reportable Quantity (RQ) of an air pollutant (e.g., benzene) is discharged into the atmosphere due to failure of a control device, then a report to the State emergency reporting agency may be required. Enclosed vapor combustion devices (VCU) can be backup controls for a VRU recovering vent gas from a crude oil storage tank.
- Use VRUs in lieu of flares and enclosed combustors to minimize air emissions.
- Standardize facility design so that each permit application is similar and results in lower permit application preparation costs and compliance costs.
- Create an air permit compliance manual and train field personnel to ensure permit compliance.
HY-BON/EDI’s Complete Solution
HY-BON/EDI’s engineered vapor recovery units (VRU), vapor recovery towers (VRT) and enclosed vapor combustion units (VCU) along with our IQR and Leak Detection and Repair (LDAR) services offer a complete package for operators to comply with your State and Federal air permitting and emission standards.