Oil and Gas Air Permitting : Guidance and Updates Samuel Short, Manager Air Permits Division Texas Commission on Environmental Quality

Topics for Discussion Permit Options Application Process Federal Updates Frequently Asked Questions Topics for Discussion Permit options Barnett Shale Non-Barnett Shale Application Process Hardcopy ePermits Federal Updates NSPS OOOa Information Collection Request Frequently Asked Questions

Non-Barnett Shale Oil and Gas Options 30 TAC §106.352(l) - Oil and Gas Handling and Production Facilities 30 TAC §106.492 - Flares 30 TAC §106.512 - Stationary Engines and Turbines Voluntarily use Barnett Shale mechanisms 30 TAC §116.620-Installation and/or Modification of Oil and Gas Facilities Standard Permit PBRs we see the most in oil and gas. TAC- Texas Administrative Code

Barnett Shale Counties Oil and Gas Options Non-Rule Standard Permit for Oil and Gas Handling and Production Facilities 30 TAC §106.352 (a)-(k) New – Projects constructed or modified on or after April 1, 2011 New equipment and upstream downstream affects must be done under new rules. 116.620 Installation and/or Modification of Oil and Gas Facilities Standard Permit 30 TAC §106.352 (l) Existing – Projects that are constructed or modified after April 1, 2011 are considered “new.” Barnett Shale Counties- 15 counties (Cook, Dallas, Denton, Ellis, Erath, Hill, Hood, Jack, Johnson, Montague, Palo Pinto, Parker, Somervell, Tarrant, and Wise)

30 TAC §106.352(l) Sour (> 24 ppm H2S): Sweet: Vent heights no less than 20 feet Keep records. Meet condition of the rule and 106.4 limits No registration required Sour (> 24 ppm H2S): Registration required ¼ mile distance limit 4.0 lb/hr limit of sulfur compounds (not including sulfur oxides) Vent height requirements change based on sulfur compound limit ppmv = parts per million by volume lb/hr = pounds per hour

Other Related PBRs 30 TAC §106.353 Temporary Oil and Gas Facilities 90 days to test the content of a subsurface stratum to establish the proper design of a permanent facility 4.0 lb/hr limit of sulfur compounds (not including sulfur oxides) Vent height requirements Salt Water Disposal (Petroleum) 30 TAC §106.351 Requires registration ¼ mile distance requirements for sour sites 30 TAC §106.512 Stationary Engines and Turbines Requires registration, if >240-hp Requires NAAQS compliance demonstration 30 TAC §106.492 Flares Specific design requirements ¼ distance limit for sour sites

30 TAC §106.352(a)-(k) Notification and registration are required to be submitted using the ePermits system Notification - Prior to construction or implementation of changes Registration Level 1 - Within 180 days from start of operation Level 2 - Within 90 days from start of operation E-Notify prior to construction or implementation of changes Level 1 PBR register within 180 days from start of operation or implementation of changes Level 2 PBR register within 90 days from start of operation or implementation of changes

Impacts Review (Hourly and Annual) Effects Screening level (ESL): Benzene at the nearest receptor within specified distance ¼ mile – Level 1 ½ mile – Level 2 State and Federal ambient air standards compliance demonstration NO2 SO2 H2S Contaminants That Require Impacts Evaluation: Benzene short-term ESL= 170 µg/m3, long-term ESL= 4.5 µg/m3 H2S NAAQS = 108 µg/m3 SO2 NAAQS = 196 µg/m3 NO2 NAAQS = 188 µg/m3 Evaluation Thresholds in lb/hr: Benzene = 0.039 H2S = 0.025 SO2 = 2 NOX = 4 No impacts review necessary for a given contaminant if the lb/hr emissions are below de minimis levels as stated in the rule. No ESL review (for benzene) required if no receptor within specified distance of registration. No ambient air quality standard review (for NO2, SO2, and H2S) required if no property line within specified distance of registration. 1/4 mile - PBR Level 1 1/2 mile - PBR Level 2 1 mile - Standard Permit 30 TAC §106.352 (a) – (k)

30 TAC § 116.620 Standard Permit Why use: Sour sites that can’t meet ¼ mile limit in §106.352(l) VOCs are >25tpy VOCs must be speciated using E=L/K Calculation techniques, emissions summary tables, etc. – same as a PBR application VOCs must be speciated and meet the emissions limits of E=L/K as explained in the rule. More information regarding E = L/K can be found at http://www.tceq.texas.gov/permitting/air/permitbyrule/subchapter-k/emission_distance.html.

Non-Rule Standard Permit Notification & registration online – STEERS (ePermits) system Notify - Prior to construction or implementation of changes Register Within 90 days from the start of operation Impacts – Same as §106.352 (a)-(k) STEERS = State of Texas Environmental Electronic Reporting System Very similar in scope to the Barnett Shale rule. Impacts evaluations may need to be performed based on emissions totals and/or distances to off-property receptors or property lines. E-Notify prior to construction or implementation of changes. Standard permit - register within 90 days from the start of operation or implementation of changes. Fees.

Planned Maintenance, Startup, and Shutdown (MSS) Planned MSS emissions may be authorized under: 106.359- Non-Barnett Shale Used in conjunction with 106.352(l) or 116.620 Standard Permit 106.352 (a)-(k), or the Non-Rule Standard Permit- Barnett Shale Planned MSS emissions do not include unplanned MSS, upsets, or emissions events.

Administrative Documents Preferred Order Cover Letter Core Data Form PI-7, PI-7 Cert, APD-CERT Copy of Check / epay Voucher Cover Letter The cover letter states the purpose of the application. The letter can also include facility information and company contact information. The cover letter should explain who you are and why you are coming in for a permit registration. Your Core Data Form should have all pertinent information filled out completely this includes driving directions. PI-7 or APD-Cert Form is going to depend on if you plan on certifying the sites emissions or not. So why would we certify versus register? We will talk about that in the next slide The reviewer needs should be able to verify that the fee has been paid. Please add a copy of the check or epay voucher in you application.

When do I need to Certify? Emission limitations for Title V applicability. Federal applicability Control/destruction efficiency claims Operating hours

Technical Documents Preferred Order Introduction Table of Contents Process and Flow Diagram Summary of Emissions Emission Calculations Rule Compliance Demonstration Applicability (NESHAP, NSPS, MACT) Lab Analysis Maps Supporting Documentation NAAQS = National Ambient Air Quality Standards   References Completing FOP Applications - Additional Guidance http://www.tceq.state.tx.us/assets/public/permitting/air/Guidance/Title_V/additional_fop_guidance.pdf

Technical Documents Preferred Order Introduction Table of Contents Process and Flow Diagram Summary of Emissions Emission Calculations Rule Compliance Demonstration Applicability (NESHAP, NSPS, MACT) Lab Analysis Maps Supporting Documentation

Introduction On behalf of XYZ Inc., I am submitting the enclosed permit by rule registration to authorize a sweet production facility in Anderson County. Equipment at the site consists of production separators, crude oil storage tanks; a produced water tank, a flare, loading, two heater treaters, and process fugitives. As documented in the enclosed registration package, these facilities are authorized under 30 TAC §106.352 and §106.492. If you have any questions, please call me at (512) 234-5678. Introduction The introduction should include relevant information about the submittal. The introduction can include: type of application, project description, associated permits, fee payment information, and reference to confidential information.  

Technical Documents Preferred Order Introduction Table of Contents Process and Flow Diagram Summary of Emissions Emission Calculations Rule Compliance Demonstration Applicability (NESHAP, NSPS, MACT) Lab Analysis Maps Supporting Documentation

Table of Contents TABLE OF CONTENTS PROCESS DESCRIPTION AND FLOW DIAGRAM.............................................................. 1 TABLE 1A AND SUMMARY TABLE........................ 2 EMISSIONS CALCULATIONS................................ 4 APPLICABILITY………………............................ 34 LAB ANALYSIS………………………..…..…….36 MAP.………………..……………..….….…..….37 MANUFACTURER DOCUMENTATION………....38

Technical Documents Preferred Order Introduction Table of Contents Process and Flow Diagram Summary of Emissions Emission Calculations Rule Compliance Demonstration Applicability (NESHAP, NSPS, MACT) Lab Analysis Maps Supporting Documentation

Process Description Produced fluids enter the site and flow through production separators and a heater treater to separate the oil, water, and gas. The crude oil is sent to six 500-bbl crude oil storage tanks and then trucked off site. Water is stored in two 500-bbl water tanks and then trucked off site. Emissions from the tank battery are controlled by a flare. The gas is sent to the sales pipeline. Fugitive emissions from valves, connectors, etc. are represented by EPN FUG. Process Description The purpose of the process description is to give reviewers using the application file a general sense of the processes taking place at the site requesting the permit. The term “process” refers to a collection of units or devices that have a physical relationship, where a regulatory requirement is potentially applicable to the process as a whole. The process description should describe the process with emphasis on the type of units, their applicable requirements (in general), and emissions that are generated from the units. The term “unit” has the meaning of “emission unit” as defined in Title 30 Texas Administrative Code Chapter 122 (30 TAC Chapter 122). Each major step in the process should be discussed and should refer to the process flow diagram where appropriate.1

VRU Case Study Flow Diagram Separator VRU Compressor Tank 1 Tank 2 Gas Sales Crude Tank 1 Tank 2 Separator Incoming Product Crude Pipeline Gas VRU Process Flow Diagram The flow diagram should be sufficiently descriptive to enable the APD staff member reviewing the application the ability to determine the raw materials to be used in the process, major processing steps, major equipment items, individual emission points associated with each process, major emission abatement devices, and major waste streams, including wastewater streams, that have associated emissions. Piping and instrumentation drawings are not required. Detailed block flow diagrams are usually sufficient. Process steps which should normally be indicated on the flow diagram include: raw material handling and storage, chemical reactions, mixing, separation and/or application, and product storage/loading. Referenced equipment numbers, process nomenclature, and emission point numbers should be consistent with the information contained in the process description and emissions calculations.1

Technical Documents Preferred Order Introduction Table of Contents Process and Flow Diagram Summary of Emissions Emission Calculations Rule Compliance Demonstration Applicability (NESHAP, NSPS, MACT) Lab Analysis Maps Supporting Documentation

Summary of Emissions Summary of Emissions An Emission Point Summary Table (Table 1(a)) or equivalent is required in the application. This table identifies the air contaminant emission rates at each emission point. The emissions point number (EPN) and/or the facility identification number (FIN) should be consistent with other materials in the application.

Technical Documents Preferred Order Introduction Table of Contents Process and Flow Diagram Summary of Emissions Emission Calculations Rule Compliance Demonstration Applicability (NESHAP, NSPS, MACT) Lab Analysis Maps Supporting Documentation

Emissions Calculations For oil and gas production sites and surface coating facilities, the TCEQ has developed an emission calculation spreadsheet to determine compliance with PBR or standard permit emission limits. Oil and Gas Spreadsheet http://www.tceq.state.tx.us/assets/public/permitting/air/NewSourceReview/oilgas/spreadsheet-revisions.pdf For other PBR facilities, all necessary calculations should be included in the application to determine if emissions meet the limits of the PBR.

Technical Documents Preferred Order Introduction Table of Contents Process and Flow Diagram Summary of Emissions Emission Calculations Rule Compliance Demonstration Applicability (NESHAP, NSPS, MACT) Lab Analysis Maps Supporting Documentation

Rule Compliance Demonstration Compliance demonstrations show how the company will meet every part of the rule, as well as other applicable chapters in 30 TAC. Completed applicable PBR checklists may also accompany the submitted application. If the facility, operation, or equipment cannot comply with the conditions indicated in the checklists, see Types of New Source Review Authorizations for other options. Impact Analysis / NAAQS https://www.tceq.texas.gov/permitting/air/guidance/authorize.html

Applicability Federal Standards Compliance (Applicability) NAAQS §115, §117, §112 NSPS, MACT, NESHAP Federal Standards Compliance (Applicability) Federal standards include New Source Performance Standards (NSPS), National Emissions Standards for Hazardous Air Pollutants (NESHAP), and Maximum Achievable Control Technology (MACT). The company should identify applicable facilities and as necessary demonstrate the subjected facilities compliance to these standards. The more common federal standards are also included on the PBR checklists.   If you happen to be in an nonattainment or attainment county do not forget to check 30 TAC §115 and §117.

Technical Documents Preferred Order Introduction Table of Contents Process and Flow Diagram Summary of Emissions Emission Calculations Rule Compliance Demonstration Applicability (NESHAP, NSPS, MACT) Lab Analysis Maps Supporting Documentation

Lab Analysis Lab Analysis Oil and Gas PBRs and Standard Permits require a copy of an actual gas and liquid lab analysis of the site. The data should be analyzed by a state accredited laboratory. The lab analysis should include the following: sample location, site name, testing conditions, and method used. If the sample is taken from a representative site, a justification must be given as to why it is representative. Whether or not another site would be considered representative will depend on factors such as distance from actual site, if it draws from the same gas field, formation and depth. For more information on representative lab analysis, please refer to the website below. Representative Analysis Criteria http://www.tceq.texas.gov/assets/public/permitting/air/NewSourceReview/oilgas/rep-analysis-criteria.pdf

Technical Documents Preferred Order Introduction Table of Contents Process and Flow Diagram Summary of Emissions Emission Calculations Rule Compliance Demonstration Applicability (NESHAP, NSPS, MACT) Lab Analysis Maps Supporting Documentation

Maps 1532 ft Area Map The area map must show the location of the property relative to prominent geographical features such as highways and roads. If the property is located within a city or town, a city map is adequate to present this information. If outside a city or town, a U.S. Geological Survey or county map is acceptable, provided the required information is represented on the map.1  Site map Identification numbers on the plot plan should be consistent with and correspond to other parts of the application. The plot plan should include a plant benchmark, true north, and the property lines and/or process unit boundaries. The emission units, emission points, groups of emission units and/or processes should be representative of the location respective to the property lines.1  

Technical Documents Preferred Order Introduction Table of Contents Process and Flow Diagram Summary of Emissions Emission Calculations Rule Compliance Demonstration Applicability (NESHAP, NSPS, MACT) Lab Analysis Maps Supporting Documentation

Miscellaneous Supporting Documents Miscellaneous Engine Manufacture data sheet Flare Control device manufacture data Other Modeling data Software reports Miscellaneous Miscellaneous items are items that help support information in the application. These items may include the following: engine manufacture data sheet, modeling data, software reports, and control device manufacture data.

Hardcopy Submittal Mail Room Admin Staff Received by RR Check In Delivery to Air Admin Staff Admin Staff First Look Deficiency Notification Process File Transfers to Reviewing Section Received by RR Review of Application Letter of Authorization or …. Mail Room Projects checked in and delivered to APIRT APIRT Looks over administrative paperwork. Will notify you if there is any missing administrative paperwork, information or fees. Received and processes information Transfers project to appropriate section Received by R&R Reviewer looks over project for deficient information Contacts technical contact to request deficient information. Assuming everything that is needed is returned. The reviewer will then continue the review and authorize the project, however, if the needed information is not received or other discrepancies arrive more time is added to the review process.

STEERS ePermitting System What can I register with it? All PBRs Oil and Gas Standard Permits Am I required to use it? All permits by rule (PBRs) and Oil and Gas Standard Permits can be registered using the State of Texas Environmental Electronic Reporting System (STEERS) system. The following are currently available through ePermits: General MSS Registrations Notifications and registrations for Barnett Shale (BSH) PBRs and standard permits Registrations for PBRs and standard permits 116.620 New Source Review (NSR) Administrative Action(s): Submit an Air NSR Change of Ownership New Source Performance Standard (NSPS-OOOO): Submit a Well Completion/Flowback Notification (40 CFR §60.5360-5430) General Maintenance, Startup, and Shutdown (MSS) Registrations: Submit an APD MSS registration for un-registered facilities Submit an APD MSS registration for registered facilities APD Certifications: Submit an APD Certification for un-registered facilities Submit an APD Certification for registered facilities Notifications and registrations for Barnett Shale (BSH): Submit an Oil and Gas Site (OGS) Historical Notification Submit OGS New Project Notification for New and Existing Registrations Submit OGS PBR Level 1 and 2 New and Existing Registration Submit OGS Non-rule Standard Permit for New and Existing Registrations Registrations for Permits By Rule and Standard Permits for Non-BSH: Submit a §106.352(l) or Standard Permit 116.620 - New Registration Submit a §106.352(l) - Revision to Existing Registration Submit a Standard Permit 116.620 - Existing Registration - Notification is required for projects constructed or facilities modified on or after 4/1/2011 and subject to §106.352 (a)-(k) or the non-rule standard permit (a-k). - Level 1 and 2 Registration is required either 90 or 180 days after submitting the OGS New Project Notification; a more detailed registration is required through ePermits. - Non-Rule OGS New Project Registration is required 90 days after submitting the OGS New Project Notification; a more detailed registration is required through ePermits - All other PBRs are now available through ePermits and some will get a same day response. We highly encourage all applicants to submit projects through STEERs.

STEERS – Oil and Gas Projects Same-day response (if specific parameters); Company will receive authorization letter; and Staff will periodically review these submittals manually. The TCEQ STEERS ePermitting system has been updated to assist the agency in providing applicants with faster reviews of certain oil and gas applications.  The updated system uses information provided by the applicant to determine if the representations in the application comply with the authorization(s) being registered.  In specific instances, upon completion of the STEERS ePermit submittal and based on the information provided by the applicant, an approval letter may be issued within that same day.   Application submittals that receive approval in this manner will be periodically reviewed by staff.  Non-automated reviews will also be conducted if the system is not able to confirm that an application meets all of the requirements.  All facilities must be in compliance and operate in accordance with all applicable rules and regulations.    We encourage the use of the STEERS ePermitting system and the efficient service it provides in processing oil and gas applications.

NSPS OOOOa Overview What is NSPS OOOOa? What does it address? Applicable to Oil and Natural Gas facilities What does it address? BSER for additional equipment and activities for VOCs and GHGs Compliance If site is in compliance with NSPS OOOOa, it is assumed to be in compliance with NSPS OOOO The U.S. Environmental Protection Agency (“EPA”) issued a final New Source Performance Standard (“NSPS”) Subpart OOOOa June, 3 2016. The Rule applies to Oil and Natural Gas facilities for which construction, modification or reconstruction commenced after September 18, 2015 and reflects today’s technology, referred to as Best System of Emission Reduction (“BSER”), considering costs. Building on it’s 2012 requirements to reduce VOC emissions, EPA has added the requirements that the industry reduce emissions of greenhouse gases (GHGs), specifically methane, and Volatile Organic Compounds (“VOCs”) by addressing additional equipment and activities in the oil and gas production chain and applying updated emission control requirements to reflect the BSER. The standards apply across a variety of emission sources in the oil and natural gas source category (i.e., production, processing, transmission, and storage). NSPS OOOOa includes the same requirements that apply to sources that are subject to subpart OOOO. Therefore, if you are in compliance with the requirements outlined here for Subpart OOOOa, you are considered to be in compliance with Subpart OOOO.

Modifications to Proposed Rule Modifications to NSPS OOOOa from proposed rule Modifications to Proposed Rule Fixed schedule Method 21 Six months to meet green completion requirements Sets a fixed schedule for monitoring leaks and provides owners and operators one year from final rule when published in the Federal Register or 60 days from the startup of production, whichever is later, to conduct an initial leaks monitoring survey. Schedule for monitoring: Twice per year for well sites, including low-production well sites Quarterly for Compressor stations and gas production gathering and boosting stations The final rule allows owners/operators to use “Method 21” with a repair threshold of 500 parts per million (ppm) as an alternative for finding and repairing leaks in addition to optical gas imaging. The final rule also allows for the use of emerging, innovative technologies to monitor leaks with prior approval. Owners/operators will have six months from the time the final rule is published in the Federal Register to meet the green completion requirements. Owners/operators of hydraulically fractured oil wells will be required to reduce emissions using combustion controls until the green completion requirement takes effect.

NSPS OOOOa What sources are affected? Any source that has been constructed, modified, or reconstructed after September 18, 2015: Centrifugal compressors Reciprocating compressors Pneumatic controllers Pneumatic pumps Well completions of hydraulically fractured wells Fugitive emissions from well sites, gathering and boosting stations, and compressor stations Equipment leaks at natural gas processing plant This rule applies to sources that are constructed, modified ,or reconstructed after September 18, 2015 and reflects today’s technology, referred to as best system of emission reduction (“BSER”), considering costs. Affected sources for VOCs include: Centrifugal compressors Reciprocating compressors: Replace the rod packing on or before 26,000 hours of operation or 36 calendar months or route emissions from the rod packing to a process through a closed vent system under negative pressure. Pneumatic controllers Pneumatic pumps: 95 percent control if there is an existing control or process on site. 95 percent control not required if; - Emissions are routed to an existing control that achieves less than 95 percent or - It is technically infeasible to route emissions to the existing control device or process (non-greenfield sites only). Well completions of hydraulically fractured wells Fugitive emissions from well sites, gathering and boosting stations, and compressor stations Equipment leaks at natural gas processing plant

NSPS OOOOa What entities and affected facilities are potentially subject to the rule? Category NAICS Codea Examples of Regulated Entities Industry Type 211111 Crude Petroleum and Natural Gas Extraction 211112 Natural Gas Liquid Extraction 221210 Natural Gas Distribution 486110 Pipeline Distribution of Crude Oil 486210 Pipeline Transportation of Natural Gas Many industries are potentially subject to NSPS OOOOa. As noted in the preamble of the rule, the table shown here is not intended to be exhaustive, but rather a guide for entities that are likely to be regulated by the rule. Other entities that are not listed on the table could potentially be affected as well. For example: If a company owns a salt water disposal facility that has not gone through a custody transfer from the wellhead to the site, the sources at the salt water disposal site could potentially be applicable to NSPS OOOOa. a. North American Industry Classification System

How do I determine if my well is an affected facility? NSPS OOOOa How do I determine if my well is an affected facility? Single well is affected facility if: It conducts a well completion operation after hydraulically fracturing of a well that commenced construction after September 18, 2015, or It conducts a well completion operation after hydraulically refracturing for which refracturing commenced after September 18, 2015 Single well is affected facility if: It conducts a well completion operation after hydraulically fracturing of a well that commenced construction after September 18, 2015, or It conducts a well completion operation after hydraulically refracturing for which refracturing commenced after September 18, 2015 Please note that the well completion standards in the final NSPS OOOOa rule apply to both natural gas and oil well completions.

NSPS OOOOa Well site exceptions: EPA defines a well site as one or more surface sites that are constructed for the drilling and subsequent operation of any oil well, natural gas well, or injection well. This includes a separate tank battery surface site collecting crude oil, condensate, intermediate hydrocarbon liquids, or produced water from wells not located at the well site (e.g., centralized tank batteries). When is a site not subject to NSPS OOOOa? The EPA defines a well site as one or more surface sites that are constructed for the drilling and subsequent operation of any oil well, natural gas well, or injection well. This includes a separate tank battery surface site collecting crude oil, condensate, intermediate hydrocarbon liquids, or produced water from wells not located at the well site (e.g., centralized tank batteries). A modification occurs when either: a new well is drilled at your existing well site, a well at your existing well site is hydraulically fractured, or a well at your existing well site is hydraulically refractured. When is a site not subject to NSPS OOOOa? Well site exceptions: The site is not subject to the requirements in Subpart OOOOa if the well site contains only one or more wellheads (i.e., the well site does not have any equipment associated with the wellheads such as separators, compressors, heaters, or dehydrators). The affected facility status of a separate tank battery surface site has no effect on the affected facility status of a well site that only contains one or more wellheads. [§60.5365a(i)(2)] Therefore, if you add a new well, hydraulically fractured or refractured, at your well site after September 18, 2015, you are now subject to the fugitive monitoring requirements in Subpart OOOOa.

LDAR & NSPS OOOOa TCEQ will continue to evaluate LDAR programs: Must use TCEQ recognized LDAR for reductions Non-Rule Standard Permit and §116.620 LDAR As the TCEQ continues to evaluate our Leak Detection and Repair (LDAR) programs, we may, in the future, develop LDAR programs or reductions to coincide with NSPS OOOOa. For current permitting purposes, compliance with the fugitive monitoring of OOOOa does not in itself come with any claimable reductions. If a company is looking to claim reductions for a site based on fugitive monitoring, it will have to implement one of the TCEQ recognized LDAR programs (such as 28AVO, 28M, etc – see full list here: https://www.tceq.texas.gov/permitting/air/guidance/newsourcereview/fugitives/nsr_fac_eqfug.html). LDAR programs are already established in the Non-Rule Standard Permit and §116.620 and should continue to be utilized as required. Applicants may have to add additional inspections and techniques on top of those required by the rules in order to meet NSPS OOOOa.

Updates On March 2, 2017 EPA withdrew the 2016 information collection request for the oil and gas industry. On April 4, 2017 EPA announced it is reviewing the 2016 Oil and Gas NSPS OOOOa and, if appropriate, will initiate reconsideration proceedings to suspend, revise, or rescind the rule.

Frequently Asked Questions (FAQs) I am using a representative analysis for my oil and gas site; the site is sour. Do I need a site specific analysis for the H2S? Do sites authorized under a PBR get 25 tpy VOC for planned MSS activities and 25 tpy for normal operations? My floating roof tank is applicable to NSPS Kb. Do I have to comply with NSPS OOOO Certification to limit tank emissions below the 6 tpy of VOC threshold 1. I am using a representative analysis for my Oil and Gas site; the site is sour. Do I need a site specific analysis for the hydrogen sulfide (H2S)? Yes! Per TCEQ Representative Analysis Criteria, a site specific analysis for the H2S is always required at a sour site. This applies to Salt Water Disposal Sites as well: https://www.tceq.texas.gov/assets/public/permitting/air/NewSourceReview/oilgas/rep-analysis-criteria.pdf 2. Do sites authorized under a PBR get 25 tpy VOC for planned MSS activities and 25 tpy for normal operations?- no- The sitewide limits of 30 TAC §106.4 apply for all PBRs claimed or registered at the site 3. My floating roof tank is applicable to NSPS Kb. Do I have to comply with NSPS OOOO Not for that specific tank. The control requirement for NSPS OOOO states “(2) If you use a floating roof to reduce emissions, you must meet the requirements of §60.112b(a)(1) or (2) and the relevant monitoring, inspection, recordkeeping, and reporting requirements in 40 CFR Part 60, Subpart Kb.” By meeting Kb, the tank is in compliance. 4. Certification to limit tank emissions below the 6 tpy of VOC threshold After further evaluation and review of 40 CFR §60.5365(e) and EPA’s Response to Comments on the amendment to NSPS OOOO regarding storage vessel affected facilities, if an owner or operator complies with the specific rule requirements* and determines that the emissions from a tank (uncontrolled) are less than 6 tpy of VOCs, the tanks would not be subject to NSPS OOOO requirements.  No certification of the tank emissions is required, however it is recommended that owners and operators maintain a copy of the calculations as documentation.     When tanks are authorized by a permit by rule (PBR), and controls (flare, combustor, etc.) are used to limit tank emissions so that they are below the 6 tpy threshold for NSPS OOOO applicability, certification is required consistent with 30 TAC §106.6.  An APD certification may be filed to establish the federally enforceable limit in compliance with 40 CFR §60.5365. In addition, when a VRU is being used to recover VOC emissions from the tanks, and this results in tank emissions below 6 tpy, no certification is required; however, all monitoring and recordkeeping requirements must be met as stated in §60.5365(e)(1-4). *Specific Rule Requirements:  40 CFR 60.5365 : The potential for VOC emissions must be calculated using: 1.       A generally accepted model or calculation methodology, and site specific or equivalent product composition.  TCEQ calculation methodologies can be found by following these links: a.      http://www.tceq.texas.gov/assets/public/permitting/air/NewSourceReview/oilgas/spreadsheet-revisions.pdf b.      http://www.tceq.texas.gov/assets/public/permitting/air/NewSourceReview/oilgas/rep-analysis-criteria.pdf c.       http://www.tceq.texas.gov/permitting/air/permitbyrule/subchapter-o/oil_and_gas.html 2.       Be based on the maximum average daily throughput determined for a 30-day period of production prior to the applicable emission determination deadline specified in this section.

More FAQs What does TCEQ consider a sour site? ProMax, HYSYS, WinSim Can I submit a §106.352 (a)-(k) project (Barnett Shale) as a hard copy? My site is currently authorized under §116.620. Can I use §106.352 to add a piece of equipment? 1. What does TCEQ consider a sour site? The TCEQ defines a sour site as handling ≥ 24 ppm of H2S. It is very important to keep in mind that §106.352(l)(3) states that “any facility handling sour gas” is applicable to the requirements of a sour site. If at any point, sour gas is handled at a site, the site is considered sour. For example, gas enters an Amine unit as sweet gas (<24 ppm H2S) but as it exits the amine unit, it becomes sour. This site is now considered a sour site because a facility is handling sour gas. 2. While ProMax, Hysys and WinSim are TCEQ approved calculation simulators, we will still require the input pages to be attached to the application. The TCEQ permit reviewer will require this page in order to confirm compliance. 3. Can I submit a §106.352 (a)-(k) project (Barnett Shale) as a hard copy? No, the company must use STEERs. Per §106.352(a)-(k) “…the facilities must be registered through ePermits form "APD OGS PBR Level 1 and 2 Registration" (or if not available, submittal of hard-copy).” The STEERs system has not been unavailable for over 24 hours since start-up. 4. My site is currently authorized under §116.620. Can I use §106.352 to add a piece of equipment? No. The standard permit is inclusive of all oil and gas facilities at the site. Authorizing a piece of equipment covered under the standard permit by using §106.352 would be dual authorization of that piece of equipment.

E-Permit Contact Information STEERS Helpline (512) 239-6925 Sabrina Coty-Butler (512)239-1225 sabrina.coty-butler@tceq.texas.gov Amber Huddle (512) 239-1595 amber.huddle@tceq.texas.gov Britany Gilman (512) 239-944 britany.gilman@tceq.texas.gov For General questions and questions on how to set up a new STEERS account should go to the STEERS Helpline.

Contact Information Samuel Short (512) 239-5363 samuel.short@tceq.texas.gov Air Permits Main Line: (512) 239-1250