Annette Maxwell Liaison TCEQ Office of Compliance and Enforcement Program Support Section

1. Annette Maxwell Liaison TCEQ Office of Compliance and Enforcement Program Support Section NSPS OOOO Standards of Performance for Crude Oil and Natural Gas Production, Transmission, and Distribution

2. New Source Performance Standards, Subpart OOOO • 40 CFR Part 60, Sections 60.5360 - 60.5430 • Updates finalized September 23, 2013 • Rule addresses affected facility VOC and SO2 emissions • The rule includes (but is not limited to) • Notification, reporting, and recordkeeping requirements • 40 CFR 60.5420 • Additional recordkeeping and reporting requirements • Natural Gas Processing Plants 40 CFR 60.5421 & 60.5422 • Sweetening Units 40 CFR 60.5423 Note: This presentation is brief and focuses on notification and reporting. Additional requirements beyond those shown here may apply!

3. Reporting & Notification Notifications: • Well Completion / Flowback • Submit online • http://www.texasoilandgashelp.org/ • http://www.tceq.texas.gov/assets/public/permitting/air/Forms/20640.pdf • Through STEERS https://www3.tceq.texas.gov/steers/index.cfm • By fax – (512) 239-2101 • By mail Air Permits Division MC-163 Texas Commission on Environmental Quality PO Box 13087 Austin, TX 78711-3087

4. Well Completion/Flowback Notification

5. Annual Report • Annual report requirements are outlined in • 40 CFR 60.5420(1) – (6) • Due annually beginning January 15, 2014 • Previously submitted annual reports must be updated to comply with September 23, 2013 rule updates, if applicable. • Must include • Information for the following: gas wells, centrifugal compressors, reciprocating compressors, pneumatic controllers, and storage vessels • Note on the term “affected facility”: for the purposes of this rule, this includes specific pieces of equipment, not the entire site • Note on sweetening units: annual report requirements found in 40 CFR 60.5423

6. Annual Reports – Where to Submit • http://www.tceq.texas.gov/about/directory/region

7. Annual Report General Information • General Information • Company name • Address of the affected facility • Beginning and ending dates of reporting period • A certification by the responsible official • Truth • Accuracy • Completeness • Include the words: “Based on information and belief formed after reasonable inquiry, the statements and information in the document are true, accurate, and complete.” • Requested but not required: if an RN (site ID number) already exists, please note it in the report

8. Annual Report Gas Wells • Gas wells • Include records of well completion as specified in 40 CFR 60.5420(c)(1)(i) through (iv) for reporting period OR • A list of well completions with hydraulic fracturing and records specified in 40 CFR 60.5420(c)(1)(v) for reporting period And (for both choices above) • Records of deviations pursuant to 40 CFR 60.5420(c)(1)(ii)

9. Annual Report Centrifugal Compressors • Centrifugal compressors • Identification of each centrifugal compressor using a wet seal system and was constructed, modified, or reconstructed during the reporting period • Records of deviations specified in 40 CFR 60.5420(c)(2) • If 40 CFR 60.4380(a)(1) (regarding turbine excess emissions) applies, records of closed vent system and cover inspections specified in 40 CFR 60.5420(c)(6)

10. Annual Report Reciprocating Compressors • Reciprocating compressors • Cumulative number of hours of operation Or • The number of months since: • Initial startup, • October 15, 2012, Or • Most recent rod packing replacement (whichever is later) • Records of deviations specified in 40 CFR 60.5420(c)(3)(iii)

11. Annual Report Pneumatic Controllers • Pneumatic Controllers • Identification of each pneumatic controller constructed, modified, or reconstructed during the reporting period including information specified in 60.5390(b)(2) or (c)(2). • If applicable, document that use of pneumatic controller with bleed rate >6 scf/hr is required and why • Records of deviations specified in 40 CFR 60.5420(c)(4)(v) (operated not in compliance with 40 CFR 60.5390)

12. Annual Report Storage Vessels • Include notification for Group 1 (8/23/11-4/12/13) • Identity and location of storage vessel (lat/long) • Include notification for storage vessels (all Groups) that are removed from or returned to service • Documentation of VOC emission rate [60.5365(e)]

13. Annual ReportStorage Vessels, continued • Records of deviations as specified in 60.5420(c)(5)(iii) • A statement that requirements of 40 CFR 60.5410(h)(2) [VOC emissions, 60.5395(d)] and 60.5410(h)(3) [control requirements, 60.5395(e)] have been met

14. Annual ReportSweetening Units 40 CFR 60.5423 • Recordkeeping and Reporting requirements for sweetening units at natural gas processing plants • Excess emissions as specified in 60.5423(b) • Looks at sulfur emission reduction efficiency

15. Performance Tests • Submit performance test records directly to EPA • Generate file using electronic reporting tool (ERT) http://www.epa.gov/ttn/chief/ert/index.html • Submit file to EPA through the Compliance and Emissions Data Reporting Interface accessed through the Central Data Exchange located atwww.epa.gov/cdx or by mail to WebFIRE Administrator, MD C404-02, 4930 Old Page Rd., Durham, NC 27703 • TCEQ will not be a recipient for performance test documentation at this time

16. Natural Gas Processing Plants • Semiannual Reports Required 40 CFR 60.5422 • Due 6 months after startup • All semiannual reports must include information required in 60.487a(a), (b), (c)(2)(i) – (iv), and (c)(2)(vii) – (viii) • This includes information regarding • Valves, pumps, compressors, and connectors • Monthly leak numbers for • Leaking valve, pump, and connector detection • Leaking valve, pump, and connectors that were not repaired as required

17. Natural Gas Processing Plants, continued (40 CFR 60.5422) • Initial semiannual report • Number of pressure relief devices (see 60.5401(b)) that have detectable emissions (see 40 CFR 60.482-4a(a)) unless they comply with 40 CFR 60.487a(c)(2)(i) – (vi) • Additional requirements outlined in Subpart VVa (40 CFR 60.487a (a), (b), and (c)(2)(i) – (vi)) • Subsequent annual reports must include pressure relief device leak detection and repair required in 40 CFR 60.5401(b)(2) and (3)

18. Things to Remember • Recordkeeping requirements are generally five years (including all records required under 60.5420(c)) • Some are less – when in doubt, double check or keep for five years • Location requirements usually specify lat/longs in decimal degrees to five decimal places using NAD83

19. To conclude • This review is not all inclusive • Details, alternatives, and exclusions have been omitted for brevity • Additional recordkeeping requirements apply • Some of those records are referenced in the reporting requirements and must be included in the annual reports Take the time to read the applicable parts carefully.

20. My Contact Information • My request to you: • Email me questions that we can use to help us draft guidance for this rule. Annette Maxwell annette.maxwell@tceq.texas.gov