Air Permitting in Louisiana & Texasa guide to compliance requirements

presented by: Shonta’ Moore, MSAir Permitting Specialist - Environmental Division

Client Focused. Technology Driven.

• Clean Air Act Enacted in 1963

• Clean Air Act of 1970 (revised by Congress)

• Amended in 1977 and again in 1990

• New Source Review and Federal Operating Permit programs

• EPA sets limits on certain pollutants

• State Regulations to uphold Federal Air Quality

• State environmental agency administers the air permits program

BACKGROUND

STATE ENVIRONMENTAL AGENCIES

Louisiana Department of Environmental Quality

Texas Commissionon Environmental Quality

State agency responsible for upholding the federal air standards in Texas

State agency responsible for upholding the federal air standards in Louisiana

FEDERAL REGULATIONS

Clean Air Act (CAA)Clean Air Act of 1963Amended 1970Amended 1977Amended 1990

These federal regulations established National AmbientAir Quality Standards (NAAQS) that each state must uphold.

NATIONAL AMBIENT AIR QUALITY STANDARDS (NAAQS)

EPA has set national limits forthese 6 “Criteria Pollutants”:

(SO2)

(NO2)

(CO)

(PM10)

Lead

Ozone

Sulfur Oxides

Nitrogen Oxides

Carbon Monoxide

Particulate Matter

(Pb)

(O3)

NONATTAINMENT AREAS

EPA designated areas that do not meet the national air standards

Significance:If your facility is located in a nonattainment area,

stricter regulations apply.

LOUISIANA OZONE NONATTAINMENT PARISHES

AscensionIbervilleEast Baton RougeWest Baton RougeLivingston

TEXAS OZONE NONATTAINMENT COUNTIES

BrazoriaChambersCollinDallasDentonEl PasoEllisFort BendGalvestonHarrisJohnsonKaufmanLibertyMontgomeryParkerTarrantWallerWise

WHO NEEDS AN OIL & GAS PERMIT?

Any oil & gas exploration, development, and production facility.

A permit must be obtained PRIOR to constructing a facility

NOTE: Construction means any person who plans to construct any NEW facility that will emit, or to modify any EXISTING facility that emits air contaminants.

COMPLIANCE

When does a company need compliance assistance?

• Drilling a Well

• Laying a Pipeline

• Constructing a Production Facility

• Producing Hydrocarbon in a Field (Operating)

• Acquiring or Selling Resources

COMPLIANCE

Types of Compliance Assistance

• Air Permits

• Water Discharge Permits

• LA- facilities located in coastal zones and wetlands

• TX- facilities that require stormwater discharge (obtain permit from EPA)

• Facility Documents

• Greenhouse Gas Compliance

• Environmental Assessments

• Title III Compliance

CHANGE OF OWNERSHIP

• Must report within 90 days (LDEQ); 30 days (TCEQ)

• LDEQ/TCEQ may change permit, if necessary

• If not reported w/in 30/90 days, permit is invalid.

• If operating w/ invalid permit = potential penalties

• Penalties = as high as $25,000/day

• Must use appropriate forms

PERMIT OPTIONS

Applications• New facilities• Existing facilities w/o permit• Existing facilities w/ permit and facility

changes:• equipment added• equipment deleted• production rates increase over permitted

rates• equipment tests over permit limitsVariances

• Well test flaring or venting• Other temporary emission sources

Administrative Amendments• Change permit limits due to testing if

changes are <5 TPY• Other administrative changes (typos,

etc.)

SERVICES PROVIDED BY FENSTERMAKER

• Permit Applications

• Permit Modifications

• Emission Inventory Questionnaire (EIQ)

• Administrative Amendments

• Variances

• Changes of Ownership

• Emission Inventory Submittal (EIS) reporting

• Greenhouse Gas reporting

• Toxic Emission Data Inventory (TEDI) reporting

• Complete permit compliance assistance: coordinate required testing and

record keeping

• Interface with LDEQ/ TCEQ

WHAT TYPE OF EQUIPMENT REQUIRES PERMITTING?

Point Source Emission Equipment - Any and all points of origin of air contaminants

• Heater Treaters

• Line Heaters

• Glycol Dehydrator

• Compressors

• Flares

• Flash Gas Losses

• Waste Gas Waste Gas Disposal

• Produced Water Storage Tanks

• Oil/Condensate Storage Tank

• Gas driven pumps

• Generators

• Amine Units

• Marine/Truck Loading

• Fugitive Emissions

FUEL COMBUSTION EQUIPMENT

Examples:Heater treater burnersLine heater burnersGlycol dehydrator reboiler burnersAmine unit reboiler burnersFlares

limited to 0.6 lbs/hr PM per MMBTU of heat

input smoke from combustion must not exceed shade requirements

PM, SO2, NOx, CO, and VOC Emissions

INTERNAL COMBUSTION ENGINES

NOx, CO, and VOC Emissions

Examples:Compressor EnginesGenerator EnginesSaltwater Pump Engines

>500 HP require testing: w/o converter = semi annually w/ converter = annual testing

STORAGE VESSELS

VOC Emissions

Examples:Produced Water Storage TanksOil/Condensate Storage Tanks

> Standing and Working Losses > Flash Gas Losses

GLYCOL DEHYDRATORS

VOC Emissions including BTEX & N-Hexane

Exemptions:• If uncontrolled <9 TPY, then no control

required• If operates <200 hrs/year, then no control

required• If constructed prior to Oct 20, 1994, then

70% control efficiency required• If constructed after to Oct 20, 1994, then

85% control efficiency required

FLASH GAS LOSSES

VOC Emissions

Storage TanksHeater TreatersSeparators

Results from depressurization of crude oil or condensate when it is transferred from a higher pressure to a lower pressure tank, reservoir, or other container.

Can be a significant source of VOC emissions.

OTHER VOC SOURCES

Loading Losses

Waste Gas Disposal

Fugitive Emissions

Questions & AnswersShonta’ N. Moore, MS

Environmental SpecialistFENSTERMAKER

5005 Riverway Dr., Suite 300Houston, TX 77056

713.840.9995 ext. 1435shonta@fenstermaker.com

Client Focused. Technology Driven.