Maintenance, Startup, and Shutdown for Oil and Gas

1. Erin Selvera, J.D. Special Assistant, Air Permits Division September 11, 2012 Maintenance, Startup, and Shutdown for Oil and Gas

2. Why a new MSS Authorization? • MSS Schedule in 30 TAC § 101.222(h) January 5, 2012 • SB 1134 moved the deadline for Oil and Gas to January 5, 2014 • The number of potential sources needing to authorize MSS

3. Texas Active Oil and Gas Wells January 2012

4. Projects Issued by APD

5. Projects Issued in FY 2012 632

6. Oil and Gas Standard Permit and PBR Registrations over the last four years Total Projects FY 2009 = 2246 FY2010 = 1455 FY 2011 = 2756 FY2012 = 3821

7. General Approach • Permit By Rule – PBR 106.359 • Best Management Practices – BMPs • Basic Recordkeeping for Enforceability • No Registration* • Electronic permitting options

8. Why a PBR? • Provides streamlined authorization mechanism for industry • Allows the TCEQ to focus its resources on sources and more complex facilities with the potential for higher levels of emissions • Provides clarity to the regulated community regarding expectations • Continued protection of human health and the environment

9. Why BMPs? Image of the Eagle Mountain Lake Monitor area

10. 2011 Average Benzene Concentrations at Texas Air Monitoring Sites

11. Research and Evaluation • Oil and gas registrations submitted claiming MSS emissions • Suma canister sample results • Monitoring data in areas with high density of oil and gas facilities • Site activity information coupled with monitoring data for impacts/modeling evaluation • Consultation with other APD experts and review of other permitted facilities to identify expected MSS activities and verify approaches to MSS control and authorization for similar larger facilities. • Petroleum Extension Service texts describing processes for startup and maintenance of equipment • Oil and gas service company procedures and controls addressing MSS • Other states’ approaches to evaluating MSS activities

12. Blowdowns

13. Degassing

14. Miscellaneous MSS Activities

15. What will the PBR cover? Examples: • Routine engine maintenance • Boiler refractory replacements and cleanings • Heater and heat exchanger cleanings • Pressure relief valve testing • Maintenance of sludge from ponds, sumps, and water conveyances • Abrasive blasting, surface prep, and coating • Degassing or purging of tanks • Truck cleaning • Oil and gas well completion (start-up) emissions for NSPS OOOO applicable sources

16. Which PBR do I use for MSS?

17. Additional Constraints and Guiding Requirements For any new PBRs or Standard Permits or revisions to PBRs or Standard Permits A. Conduct a regulatory analysis in accordance with the government code B. Conduct an evaluation of credible air quality monitoring data to determine if emission limits or emissions-related requirements are needed to ensure protection of public health C. Use credible air quality monitoring data and credible air quality modeling that is not based on worst-case scenarios to determine emissions limits D. Consider whether the requirements of the permit should be imposed on particular geographic regions of the state

18. General Timeline • Research and analysis – End of September • Stakeholder meetings - Late September – Early October • Proposal – Late January 2013 • Adoption – Late June 2013 • Compliance Deadline – January 5, 2014

19. Outreach and Stakeholder Participation • Stakeholder meetings are being scheduled for: • Austin • Midland • San Antonio • Arlington • Outreach and Notice • Email • GovDelivery • Web Postings

20. For Additional Information • www.texasoilandgashelp.org • airog@tceq.texas.gov • Air Permits Main line: (512) 239-1250 • Small Business and Environmental Assistance 1-800-447-2827 or www.TexasEnviroHelp.org

21. Questions? Erin Selvera, J.D. Special Assistant, Air Permits Division Erin.Selvera@tceq.texas.gov (512) 239-6033