Unveil the Mystique of Air Permit Speak
November 7, 2014

Many oil and gas operators use environmental consultants or in-house specialists to prepare air permit applications for oil and gas production facilities. This is needed since air quality rules can be complicated due to the alphabet soup of regulations affecting the industry.  The result is often that only a few people fully understand what is required for regulatory compliance.  Also, the permit that a company receives from the regulator may not clearly spell out what is required for compliance. Most often, a copy of the applicable air regulations and the permit application used to generate the air permit are also needed to determine what is required. 

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The environmental regulatory outlook is only getting more complex with ever more compliance tasks. This does not only include air permit compliance, since the EPA requires annual greenhouse gas (GHG) reporting for operations that emit over the specified GHG thresholds. 

An operations person may say: “Tell me what you need us to do, and we will get it done.” 

This can be easy to explain with some work. 

The compliance task can be easier if someone translates the air permit/regulations/application language to form that engineering and field operations can use.  The state regulatory agency may have resources for their specific permitting requirements.  A great resource you can use is the TCEQ’s guidance for the New Source Performance Standards and Hazardous Air Pollutant rules

Below are some ideas to help you unveil the mystique of air speak and help the field operations comply include:

The environmental regulatory outlook is only getting more complex with ever more compliance tasks. This does not only include permit compliance, since the EPA requires annual greenhouse gas (GHG) reporting for operations that emit over the specified GHG thresholds. 

An operations person may say: “Tell me what you we need us to do, and we will get it done.” 

This can be easy to explain with some work. 

The compliance task can be easier if someone translates the air permit/regulations/application language to form that engineering and field operations can use.  The state regulatory agency may have resources for their specific permitting requirements.  A great resource you can use is the TCEQ’s guidance for the New Source Performance Standards and Hazardous Air Pollutant rules

Below are some ideas to help you unveil the mystique of air speak and help the field operations comply include:

  1. Read the permit and the permit application used to generate that air permit. 
  2. Conduct a site visit after a new facility is constructed to ensure that the permit matches actual operations and emission sources operating.  Modify the air permit, as needed.
  3. Prepare a briefing spreadsheet sheet that contains the following:        
    1. Company name, facility name, location
    2. Contact personnel and responsibilities
    3. Type of permit (e.g., minor source, Title V)
    4. Permit start and expiration date
    5. Date facility began operation
    6. Air permit number, facility agency ID# and regulatory account number
    7. Table of facility and emission source hourly and annual emission limits by pollutant
    8. List of emission sources with permitted throughput, hours, capacity and facility total oil and natural gas production limits
    9. Listing of permit required air emission controls by emission source
    10. Listing of facility and emission source monitoring and testing requirements
    11. Listing of facility and emission source reporting requirements
    12. Listing of recordkeeping requirements
  4. Obtain from the engine supplier a copy of the “pedigree” document for each internal combustion engine that states the applicable EPA engine rules (e.g., 40 CFR 60 Subpart JJJJ; 40 CFR 60 Subpart IIII; 40 CFR 63 Subpart ZZZZ).  This should be in the permit application that should be kept on file with the air permit.
  5. Prepare a calendar of monitoring, testing, recordkeeping and reporting action items. 
  6. Prepare and use tracking forms to document the required monitoring, testing and recordkeeping. 
  7. Although not normally an air permit requirement at this time, include greenhouse gas emission (GHG) inventory activity data tracking. 

Incorporate this information into an environmental management system. 

Living with an air permit

The following may help with compliance with actions varying with each air permitting agency.  

  1. Train the field operations personnel on the air permit requirements.
  2. Conduct semiannual or annual site visits to facilities to determine permit compliance. Make these a “mock” inspection in preparation for an air inspection by the agency. 
  3. Comply with the air permit requirements as specified in your briefing sheet.
  4. Modify the air permit, as needed, for certain facility modifications.  Some air permits require the operator to get approval prior to beginning construction of new emission sources or activities that increase emissions. Check with an air specialist for requirements for permitting modifications.  A couple of examples that trigger a modification include:
    1. Throughput increases in oil, natural gas or produced water production over permitted limits
    2. Adding new air emission sources (e.g., engines, tanks, heaters, glycol dehydrator, flares, etc.)
    3. Increasing air emissions over permitted limits.
    4. Reducing air emissions with a control device may require a permit modification to ensure the reduction is enforceable and credited to the facility. 
  5. As required by the air permit and/or air quality rules, report to the appropriate agency any malfunctions, upsets and bypasses of emission control devices such as VRUs, flares, combustors.  Be ready to submit a written report to the agency on the cause, duration, corrective action and actions taken to prevent recurrence.  Consider redundant emission control systems to minimize upset reporting. 
  6. Retain records as required by the air permit and/or air quality rules. 
  7. Pay all required air permit application and “maintenance” fees. 
  8. Inform the permitting agency for changes in facility name, owners and operators or if the facility will be permanently removed from service.  

Want to learn more about air pollution and air permitting? Attend HY-BON’s free webinar on Air Permitting 101 and NSPS OOOO update scheduled for December 3, 2014, December 17, 2014, January 14, 2015.

Click the link below to find out more and sign up.