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Hot Topics for Oil & Gas Production Authorizations

Hot Topics for Oil & Gas Production Authorizations. Anne M. Inman, P.E. Manager, Rules Registration Section. Erin Selvera, J.D. Special Assistant to Director. Air Permits Division Texas Commission on Environmental Quality Advanced Air Permitting Seminar 2014. Topics for Discussion.

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Hot Topics for Oil & Gas Production Authorizations

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  1. Hot Topics forOil & Gas Production Authorizations Anne M. Inman, P.E. Manager, Rules Registration Section Erin Selvera, J.D. Special Assistant to Director Air Permits Division Texas Commission on Environmental Quality Advanced Air Permitting Seminar 2014

  2. Topics for Discussion Workload

  3. Authorization Processing • Submittals – Complete applications: - Include site-specific or justification • Pre-application meetings • e-Permits • Enhanced Application Review • AIROG • Electronic replies

  4. ePermitting • Currently available through e-Permitting (STEERS) for Barnett-Shale: - Historical notification (deadline Jan 5, 2015) - New/existing notifications for PBR or SP - New/existing Level 1 and 2 registrations - New/existing Non-rule SP registrations

  5. e-Permitting(continued) • Newly available in e-Permitting: - New/revision §106.352(l) - New/existing SP §116.620 - PBR §106.359 - APD Certifications - NSPS OOOO well completion/flowback notifications - Change of Ownership - All other PBRs and many SPs

  6. Enhanced Application Review • Purpose • AIROG notification • Expectations – necessary or critical items • Reply e.a.r

  7. Electronic Documents & Replies Electronic submittals e-Permits AIROG@tceq.texas.gov .pdf or .xls Agency correspondence Faster replies Easily distributed

  8. Authorization Types • Notifications • Certifications • Voluntary registrations • Registrations • Registration & certifications (PBR and SP) • Case-by-case permits (state & federal NSR)

  9. Authorization Tools • Authorization Processing: - Spreadsheet updates - Quality/Quick/Quantity processing

  10. Small Crude Oil Sites • Default emission estimates available • Production of primarily crude oil • Equipment = atmospheric separation, tanks, loading only • Must meet all of the following: • 10 bbl/day crude oil • 150 bbl/day water • Max 10,000 ppm H2S (1/4 mile limit) • Loading: submerged and dedicated normal • Minimum vent heights (> 20 feet)

  11. Oil Field Waste Water Recycling and Recovery • Need detailed process description: - Wide variety of equipment configurations • Identify air contaminant: - Mixtures, concentrations - Varies by source and type • Possible authorizations under PBR include §§106.261, 106.262, 106.183, 106.472, 106.478, 106.352, 106.351

  12. Flares & Combustion Devices • Document type of control & efficiency • Flares DRE 98% & 40 CFR §60.18 • “Sonic” flares • “Combustors” - NSPS requires certification of combustors by manufacturer or site-specific sampling demonstration, DRE range 90%-99.9%

  13. MSS Implementation • Claim, register, or certify • Default calculations for maintenance • Guidance is now available: • - Inclusive of all emissions related to root-cause

  14. Pending Updates to NSPS OOOO • Proposal published in Federal Register on July 17, 2014 • EPA refers to this as NSPS 1.5 • Final rule scheduled prior to January 1, 2015 REC compliance date

  15. Pending Updates to NSPS OOOO • Identify 3 distinct stages of well completions • Clarify requirements for storage tanks • Define low-pressure wells • Clarify certain requirements for leak detection at natural gas processing plants • Update requirements for reciprocating compressors • Update definition of “responsible official” • Remove affirmative defense (from civil penalties) provisions from startup, shutdown and malfunction

  16. Pending Updates to NSPS OOOO • 3 Distinct Stages of Well Completions: • Initial Flowback Stage • Separation Flowback Stage • Production Stage

  17. Initial Flowback Stage • Can use open top tank, frac tank, lined pit, or other vessel • No control requirement • Gas can be vented

  18. Separation Flowback Stage • Route gas to flow line or collection system • Re-inject gas, use as fuel, or for other useful purpose • No direct venting – flowback emissions must be combusted using completion combustion device • Liquids directed to completion vessel, storage vessel, re-injected into the well or another well (not required to route to “storage vessel”) • May revert to initial flowback stage if flowback becomes insufficient to maintain operation of separator

  19. Production Stage • Separated crude oil, condensate, and produced water must be routed to storage vessels • Begin 30-day process of estimating storage vessel VOC PTE • Must control no later than 60 days • NO venting or flaring of gas

  20. NSPS OOOO Strategy per EPA • EPA is currently addressing the NSPS and NESHAP issues separately: • NSPS-1, Storage vesselimplementationrevisions • NSPS-1.5, Time-critical clarification of well completion requirements • NSPS-2, Remaining issues • NESHAP

  21. Greenhouse Gas Regulation • Supreme Court decision effect on permitting • EPA White Papers

  22. Greenhouse Gas Permitting • June 23, 2014 opinion: - EPA may only require BACT for “anyway” sources if the source emits more than a de minimis amount of GHGs - 75,000 tpy may in fact be a reasonable de minimis level, but EPA has to justify it on proper grounds • July 24, 2014 EPA memo: - “Anyway” sources – business as usual - “Non-anyway” sources – permitting requirement no longer enforced

  23. EPA White Papers • April 15, 2014: Released for external peer review • June 16, 2014: Deadline submission of technical information from the public and for peer review to be completed • Fall 2014: EPA will determine how best to pursue further methane reductions • End of 2016: If EPA decides to develop additional regulations, complete those regulations

  24. EPA White Papers • Targets 4 key sources: • Landfills • Coal Mines • Agriculture • Oil and Gas: • Compressors • Completions and on-going production of hydraulically fractured oil wells • Leaks • Liquids unloading • Pneumatic devices

  25. Expedited Permitting • Implementation tools and guidance expected soon • Oil and Gas PBRs and Non-rule Standard Permit do not require sites to wait for confirmation of authorization to operate

  26. Where to Find More Information Air Permits Main Line: (512) 239-1250 airog@tceq.texas.gov www.texasoilandgashelp.org

  27. The Finish Line

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