Air Permitting in Louisiana & Texas a guide to compliance requirements presented by: Shonta’ Moore, MS Air 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 Commission on 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 1963 Amended 1970 Amended 1977 Amended 1990 These federal regulations established National Ambient Air Quality Standards (NAAQS) that each state must uphold.

NATIONAL AMBIENT AIR QUALITY STANDARDS (NAAQS) EPA has set national limits for these 6 “Criteria Pollutants”: (SO 2 ) (NO 2 ) (CO) (PM 10 ) Lead Ozone Sulfur Oxides Nitrogen Oxides Carbon Monoxide Particulate Matter (Pb) (O 3 )

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 Ascension Iberville East Baton Rouge West Baton Rouge Livingston

TEXAS OZONE NONATTAINMENT COUNTIES Brazoria Chambers Collin Dallas Denton El Paso Ellis Fort Bend Galveston Harris Johnson Kaufman Liberty Montgomery Parker Tarrant Waller Wise

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 limits Variances 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 burners Line heater burners Glycol dehydrator reboiler burners Amine unit reboiler burners Flares limited to 0.6 lbs/hr PM per MMBTU of heat input smoke from combustion must not exceed shade requirements PM, SO 2, NO x, CO, and VOC Emissions

INTERNAL COMBUSTION ENGINES NOx, CO, and VOC Emissions Examples: Compressor Engines Generator Engines Saltwater Pump Engines >500 HP require testing: w/o converter = semi annually w/ converter = annual testing

STORAGE VESSELS VOC Emissions Examples: Produced Water Storage Tanks Oil/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 Tanks Heater Treaters Separators 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 & Answers Shonta’ N. Moore, MS Environmental Specialist FENSTERMAKER 5005 Riverway Dr., Suite 300 Houston, TX ext Client Focused. Technology Driven.