Oil and Gas Air Permitting in Texas
April 21, 2017

The Texas Commission on Environmental Quality (TCEQ) is the environmental agency that administers air quality regulations and permitting programs in Texas. Oil and gas (O&G) production facilities are required to obtain, from the TCEQ, an air permit prior to construction.

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The TCEQ is and will be in the future the primary enforcement agency for air quality regulations affecting Texas oil and gas facilities – regardless of changes in USEPA administration, regulations and oversight.

For Texas and all States, most operators limit facility emissions, where feasible, to qualify for minor source air permits. Minor source permits are granted via Texas minor source permitting program are desirable for following reasons:

  • Faster regulatory approval times mean the facility can begin construction and producing oil and gas for sales with minimal or almost no wait time.
  • Fewer recordkeeping and reporting requirements than Federal air operating permits.
  • Lower permit fees
  • Fewer expected onsite facility inspections by TCEQ
  • Keeps facility off list of facilities under Federal oversight
  • Public notices not required for certain minor source permitting actions (e.g., PBRs and Standard Permit for O&G facilities)

Below is an overview of some key aspects of the TCEQ’s air permitting program.

The air permitting programs managed by TCEQ include:

  • Federal Clean Air Act (CAA) requirements since TCEQ delegated authority by the USEPA.
  • Texas State only minor source air permits and standards

Federal (USEPA) Major Source Air Permits Administered by TCEQ:

  • Title V Federal Operating Permits – facility with potential to emit (PTE) of 100 tons per year (tpy) of criteria pollutants or 10/25 tpy of hazardous air pollutants (HAPs)
  • Prevention of Significant Deterioration (PSD) New Source Review Permits (facility with 250 tpy of criteria pollutants)
  • Nonattainment New Source Review (NNSR) Permits – major source facilities located in nonattainment areas (e.g., ozone (smog) nonattainment).

Texas State Minor Source Air Permit Types Available for O&G

General Air Permit Application Process

  1. Determine emission sources and operating parameters (throughputs, runtime, capacities, product characteristics, etc.).
  2. Calculate facility and equipment potential to emit (PTE) emissions to determine best air permit authorization available. Best permit strategy is to install emission controls (e.g., VRUs, Vapor Combustion Units, flares) to limit PTE to make the facility a minor source.
  3. Determine applicable regulatory requirements and emission standards.
  4. Prepare application using required TCEQ forms. 
  5. Submit completed application forms to TCEQ with any required permit application fees. Submittal of E-permits/Registrations using a STEERS (State of Texas Environmental Electronic Reporting System) Account may be an option.
  6. Begin construction and operation after approval or permit received from TCEQ. NOTE: Some PBRs do not require correspondence from TCEQ to begin construction/operation.
  7. Ensure that facility constructed and operated in compliance with all permit required emission control requirements and standards.

Enforcement

The TCEQ’s Office of Compliance and Enforcement enforces compliance with all environmental laws and regulations in Texas. Since the TCEQ has been delegated authority to administer the CAA requirements for Texas, it is the primary enforcement agency for federal air permits (Title 5, PSD, NNSR).

Best Practices for Oil and Gas Permitting

Below are a few best practices that can help permit an oil and gas production facility. 

  1. Design and operate facilities to meet available PBR or Standard Air Permit for O&G.  This reduces approval time for initial permitting and subsequent modifications.
  2. Limit potential to emit (PTE) emissions and obtain enforceable permit limits (production rates, runtime, etc.) where needed to qualify as a minor source. 
  3. Use emission controls to permit facilities as minor sources.  Federal air permits (Title V, PSD, NNSR) have more costs to comply with increased monitoring, recordkeeping and reporting requirements. 
  4. Minimize venting of natural gas.  Use vapor recovery units (VRU) as process equipment to control VOC emissions from storage tanks.  Use vapor recovery towers (VRT) as a part of the VRU system. 
  5. Use vapor combustion units (VCUs) or flares to control VOCs at facilities where VRUs are not feasible. 
  6. After the facility has been constructed and begins operation, verify that the approved air permit matches actual operations. 
  7. Prepare a briefing sheet and data forms that can be used to ensure the field operators comply all emission controls, permit monitoring, recordkeeping and reporting requirements. 
  8. Train field operations on the air permit requirements. 
  9. Conduct quarterly, semiannual or annual surveys of your facilities to ensure compliance. 

How does the right air permit save you money and lower exposure? 

If you can permit a facility as a minor source, then your permit fees, monitoring, reporting and recordkeeping would be less burdensome than for a major source.  The timeline to get an approval of a minor source general permit is usually much faster than for major source permits and individual permits.  If you shorten the time waiting for approval, the facility can begin production will no or minimal delays.  Also, use of minor source permit will reduce the exposure to federal oversight and requirements.

HY-BON/EDI uses its Identify, Quantify, Rectify (IQR) methodology to help your company reduce and manage air emissions. Our best in class Vapor Recovery Units, Vapor Recovery Towers, and Vapor Combustion Units can minimize emissions so production is optimized with minimal regulatory burdens.

Contact HY-BON/EDI now to find out how we can assist your operations. Company specific webinars tailored to your operations are available. Contact us at ]+A}xe_nL!Jv]#[l=N#/yqvY2^& or ]+A}xe_nL!Jv'o?c]#[Qh*cl|HhTb6e1S#Q for details.

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