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

Workload

o Submittals – Complete applications: - Include site-specific or justification o Pre-application meetings o e-Permits o Enhanced Application Review o AIROG o Electronic replies

ePermitting o 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

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

o Purpose o AIROG notification o Expectations – necessary or critical items o Reply

Electronic submittals e-Permits or.xls Agency correspondence Faster replies Easily distributed

o Notifications o Certifications o Voluntary registrations o Registrations o Registration & certifications (PBR and SP) o Case-by-case permits (state & federal NSR)

o Authorization Processing: - Spreadsheet updates - Quality/Quick/Quantity processing

o Default emission estimates available o Production of primarily crude oil o Equipment = atmospheric separation, tanks, loading only o Must meet all of the following: bbl/day crude oil bbl/day water 3. Max 10,000 ppm H 2 S (1/4 mile limit) 4. Loading: submerged and dedicated normal 5. Minimum vent heights (> 20 feet)

o Need detailed process description: - Wide variety of equipment configurations o Identify air contaminant: - Mixtures, concentrations - Varies by source and type o Possible authorizations under PBR include §§ , , , , , ,

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

o Claim, register, or certify o Default calculations for maintenance o Guidance is now available: - Inclusive of all emissions related to root-cause

o Proposal published in Federal Register on July 17, 2014 o EPA refers to this as NSPS 1.5 o Final rule scheduled prior to January 1, 2015 REC compliance date

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

o 3 Distinct Stages of Well Completions: 1. Initial Flowback Stage 2. Separation Flowback Stage 3. Production Stage

o Can use open top tank, frac tank, lined pit, or other vessel o No control requirement o Gas can be vented

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

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

o EPA is currently addressing the NSPS and NESHAP issues separately: - NSPS-1, Storage vessel implementation revisions - NSPS-1.5, Time-critical clarification of well completion requirements - NSPS-2, Remaining issues - NESHAP

o Supreme Court decision effect on permitting o EPA White Papers

o 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 o July 24, 2014 EPA memo: - “Anyway” sources – business as usual - “Non-anyway” sources – permitting requirement no longer enforced

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

o 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

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

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