1. Oil and Gas Air Quality Authorizations in Texas
This slide contains an image of the Texas Commission on Environmental Quality seal.
Kristyn Bower and David Reyna Air Permits Division Texas Commission on Environmental Quality

2. Today’s Topics Terminology Permitting Options Oil and Gas PBRs
Oil and Gas Standard Permit Options

3. Terminology Pollutants of Concern VOCs H2S CO NOx SO2 PM10 and PM2.5
VOCs = volatile organic compounds
H2S = hydrogen sulfide
CO = carbon monoxide
NO2 = nitrogen dioxide
SO2 = sulfur dioxide
PM10 = particulate matter equal to or less than 10 microns in diameter
PM2.5 = particulate matter equal to or less than 2.5 microns in diameter
Air pollution is hard to “see” unlike pollution in water or pollution from illegally dumped waste, for example.
VOCs are emitted from things like oil tank vents or open hatches, separator vents, small leaks from connections in piping and equipment (which we call fugitives), and the operation of loading tank contents into trucks for transportation. Sometimes VOC’s will need to be speciated into individual chemicals (i.e., propane, butane, BTEX) especially when applying for a standard permit, which we will discuss later.
Air contaminants that are emitted from oil and gas sites can include carbon monoxide, nitrogen oxides and sulfur oxides from combustions sources like engines and flares.

4. Terminology Facility –stationary equipment that emits pollutants
Engines
Tanks
Flares
Separators
Dehydrators
Facility –the easiest way to understand ‘facility’ is that they are pieces of equipment which are sources of emissions.
Above is only a partial list of stationary pollutants. Do note that while there is piping sitewide, fugitive emissions from all the piping are considered just one emissions source or facility.
Title 30 Texas Administrative Code (30 TAC) § (4) Facility--A discrete or identifiable structure, device, item, equipment, or enclosure that constitutes or contains a stationary source, including appurtenances other than emission control equipment. A mine, quarry, well test, or road is not a facility.
(Definition can also be found in the Texas Health and Safety Code (THSC), which also know as the Texas Clean Air Act (TCAA), (6).)
Stationary – on location for 12 months.
This slide contains an image of a flare.

5. Terminology Site – a group of oil and gas facilities at a property
Common control
Equipment that relies on each other
Within ¼ mile
Site – The state definition of a site is: The total of all stationary sources located on one or more contiguous or adjacent properties, which are under common control of the same person (or persons under common control).
30 TAC §122.10(27) Site--The total of all stationary sources located on one or more contiguous or adjacent properties, which are under common control of the same person (or persons under common control). A research and development operation and a collocated manufacturing facility shall be considered a single site if they each have the same two-digit Major Group Standard Industrial Classification (SIC) code (as described in the Standard Industrial Classification Manual, 1987) or the research and development operation is a support facility for the manufacturing facility.
This slide contains an image of a tank battery at an oil and gas site.

6. Andy’s Site Produced water tank Wellhead Oil tank Gunbarrel Separator
Here we have the wellhead, a gunbarrel separator, a produced water tank, and an oil tank. Each of these is a FACILITY. Additionally, the connections between them may have valves which could be a source of fugitive emissions.
These facilities collectively represent a SITE.
The more facilities you have at a site, normally the higher the emissions will be for a site, and this will affect which air permitting authorization will be the most appropriate for your site.
This slide contains an image of a sample oil and gas site.

7. Terminology
Receptor
Residence or other structure which is not used only by the O&G owner/operator
Recreational Area
Receptor is a nearby recreational area, residence, or structure that can be impacted by the emissions created by oil and gas facilities.
This slide contains an image of a cabin.

8. Andy and Nathan’s Property
Andy’s Property
Nathan’s Property
Nathan’s House
Andy’s House
Mechanic Shop
Here we have the wellhead, gunbarrel separator, produced water and oil tanks.
The oil and gas site is on Andy’s property, so his house is not a receptor because it is a residence occupied and used only by the mineral right owner. However, Andy leased the mechanic shop to someone else, so that is a receptor because it’s not used only by Andy.
Nathan has his house, and it is a receptor. (not used only by Andy who is the property owner the oil and gas site is on, and not used only by the owner/operator of the facilities)
You measure the distance from the nearest facility to the receptor. So, for Nathan’s house, the distance is measured from the (black circle) oil tank to his house. The gunbarrel separator (green rectangle) is the nearest facility to the mechanic shop, so that would be the distance to measure for rule requirements.
In this graphic, the shortest distance to the property line is from the produced water tank. (blue circle)
This slide contains an image of a sample oil and gas site and how it would relate to property lines and/or receptors.

9. Oil and Gas Permitting Options
De Minimis
Permit by Rule
Standard Permit
State Permit
NNSR and PSD
De Minimis
Permit by Rule
Standard Permit
State Permit
NNSR and PSD
Increasing
Levels of Emissions
The levels on the pyramid represent the different options for authorization under 30 TAC § (a).
This slide contains an image of the permitting pyramid, which shows the different levels of authorization corresponding to increasing levels of emissions:
De minimis
Permit by Rule
Standard Permit
State Permit
Nonattainment New Source Review (NNSR) and Prevention of Significant Deterioration (PSD)

10. De Minimis Pipeline isolation valve sites meeting certain criteria
The de minimis category is for negligible sources and is industry or activity specific.
Sources must meet all conditions exactly, and keep records. No paperwork is submitted.
Please review the de minimis criteria carefully before you claim that authorization. For oil and gas, there is currently one option on the de minimis list for pipeline isolation valve sites that meet certain criteria.
De minimis information can be found at

11. Oil and Gas Permitting Options
De Minimis
Permit by Rule
Standard Permit
State Permit
NNSR and PSD
De Minimis
Permit by Rule
Standard Permit
State Permit
NNSR and PSD
Increasing
Levels of Emissions
If your site cannot claim de minimis, the next level is the permit by rule level.
There are several permits by rule available for oil and gas facilities. We are going to briefly touch on them, but not into a high level of detail.

12. Permits by Rule Must meet all conditions exactly
Emission limits in TAC §106.4(a)(1)
25 tpy of VOCs/SO2
250 Nox,CO
25tpy H2S
PM/PM10and PM2.5
Meet all other applicable federal, state, and local requirements
tpy = tons per year
PBRs are specific to an industry or activity. For example, if you have a flare, you would use the PBR specific to that piece of equipment (facility).
You must meet each condition of the rule – no exceptions. For example, distance requirements are included in some PBRs, and if you do not meet the distance limit to the property line or receptor, you cannot claim that PBR.
You must also comply with the general requirements in §106.4 and the recordkeeping requirements in §106.8.
Oil and gas sites are limited to 25 tpy of VOCs from all sources authorized under the PBRs.
There may be additional federal rules that apply to oil and gas sites, and to claim a PBR as your authorization, you must be in compliance with those federal requirements.
Some PBRs will state in them that registration is required, and some do not require registration. You must keep records either way to demonstrate you are in compliance. If you do register for a PBR, the fee is $450 or $100 for a small business.
Remember to reference any federal rules that are applicable to your facility in your application for registration or in your records. Also include if your facility is exempt and why.
PBRs do not expire and are formerly known as standard exemptions.

13. PBR Options – Location In Barnett Shale counties
New - 30 TAC § (a)-(k)
Existing – 30 TAC § (l)
Not in Barnett Shale counties
New & Existing – 30 TAC § (l)
May voluntarily register under § (a)-(k)
PBR = permit by rule
Projects constructed/modified on or after April 1, 2011 are considered “new.”

14. Barnett Shale Counties
The PBR for oil and gas handling and production facilities has different requirements based on location of the site and the date of construction/modification.
The Railroad Commission (RRC) includes counties in their list of Barnett Shale Formation Counties that are not considered as part of this rule.
Counties that were recently removed from the list of counties required to use the new Barnett Shale rule are: Archer, Bosque, Clay, Comanche, Coryell, Eastland, Shackelford, Stephen. This revision took place November 2012.
This slide contains an image of the Barnett Shale counties for air permitting purposes.

15. § (l) – Sweet
No registration required
Meet §106.4 limits
Various facilities included
Vent height applicable if handling a sulfur compound
Flares follow §
Compressors follow §
The oil and gas permitting options will be presented in order of complexity not numerically.
(l) The requirements in this subsection are applicable to new and modified facilities except those specified in subsection (a)(1) of this section. Any oil or gas production facility, carbon dioxide separation facility, or oil or gas pipeline facility consisting of one or more tanks, separators, dehydration units, free water knockouts, gunbarrels, heater treaters, natural gas liquids recovery units, or gas sweetening and other gas conditioning facilities, including sulfur recovery units at facilities conditioning produced gas containing less than two long tons per day of sulfur compounds as sulfur are permitted by rule, provided that the following conditions of this subsection are met. This subsection applies only to those facilities named, which handle gases and liquids associated with the production, conditioning, processing, and pipeline transfer of fluids found in geologic formations beneath the earth's surface.
(1) Compressors and flares shall meet the requirements of § and § of this title (relating to Flares; and Stationary Engines and Turbines, respectively). Oil and gas facilities which are authorized under historical standard exemptions and remain unchanged maintain that authorization and the remainder of this subsection does not apply.
(2) Total emissions, including process fugitives, combustion unit stacks, separator, or other process vents, tank vents, and loading emissions from all such facilities constructed at a site under this subsection shall not exceed 25 tpy each of SO2, all other sulfur compounds combined, or all VOCs combined; and 250 tpy each of NOX and CO. Emissions of VOC and sulfur compounds other than SO2 must include gas lost by equilibrium flash as well as gas lost by conventional evaporation.

16. §106.352(l) – Sour 24 ppmv of H2S or greater = TCEQ sour
Registration required
¼ mile distance required
4.0 lb/hr limit of sulfur compounds (not including sulfur oxides)
Vent height based on sulfur compound limit
Vent height applicable if handling a sulfur compound
ppmv = parts per million by volume
lb/hr = pounds per hour
FEE is required when registering a permit.
NOTE: TCEQ definition of sour is 24 ppm. The RRC definition of sour is 100 ppm.
From the
(4) Total emissions of sulfur compounds, excluding sulfur oxides, from all vents shall not exceed 4.0 pounds per hour (lb/hr) and the height of each vent emitting sulfur compounds shall meet the following requirements, except in no case shall the height be less than 20 feet, where the total emission rate as H2S, lb/hr, and minimum vent height (feet), and other values may be interpolated:
(A) 0.27 lb/hr at 20 feet;
(B) 0.60 lb/hr at 30 feet;
(C) 1.94 lb/hr at 50 feet;
(D) 3.00 lb/hr at 60 feet; and
(E) 4.00 lb/hr at 68 feet.

17. § (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

18. PBR Level 1 Emission Limits
§ (a)–(k)
PBR Level 1 Emission Limits
Air Contaminant
Steady-state lb/hr
< 30 psig periodic lb/hr up to 150 hr/hr
≥ 30 psig periodic lb/hr up to 300 hr/yr
Total tpy
Total VOC 15
Total crude oil or condensate VOC
100
145
318
Total natural gas VOC
204
750
1,500
Benzene
1.95 7
15.4
2.8
Hydrogen sulfide
4.7
5.1
9.8
20.6
Sulfur dioxide 47
93.2 25
Nitrogen oxides
43.2
Carbon monoxide 45
PM2.5/PM10 10 5
This slide shows a table containing information about the emission limits for a Level 1 PBR.

19. PBR Level 2 Emission Limits
§ (a)–(k)
PBR Level 2 Emission Limits
Air Contaminant
Steady-state lb/hr
< 30 psig periodic lb/hr up to 150 hr/hr
≥ 30 psig periodic lb/hr up to 300 hr/yr
Total tpy
Total VOC 25
Total crude oil or condensate VOC
100
145
318
Total natural gas VOC
356
750
1,500
Benzene
3.35 7
15.4
4.8
Hydrogen sulfide 6
9.8
Sulfur dioxide 63
93.2
Nitrogen oxides
54.4
250
Carbon monoxide 57
PM2.5
12.7 10
PM10 15
This slide shows a table containing information about the emission limits for a Level 2 PBR.

20. §106.352(a)–(k) Impacts Emission impacts tables Screening modeling
Dispersion modeling
Air contaminant
lb/hr
Benzene
0.039
Hydrogen sulfide
0.025
Sulfur dioxide 2
Nitrogen oxides 4
ESL = Effects Screening Level
µg/m3 = micrograms per cubic meter
NAAQS = National Ambient Air Quality Standards
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
No impacts review necessary for a given contaminant if the lb/hr emissions are below what is stated in the slide.
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
TCEQ spreadsheet can be found at

21. Other PBRs related to oil and gas
Salt Water Disposal (petroleum) §
Temporary Oil and Gas Facilities (§ )
Air PBR : Pipeline Metering, Purging, and Maintenance (§ )
Stationary Engines and Turbines (§ )
Flares (§ )
These are some of the other PBRs available to the oil and gas industry and the most commonly used.
The PBR for Temporary Oil and Gas Facilities is 30 TAC Chapter
Stationary engines may be able to claim PBR §
Flares may be able to claim PBR §

22. Permit by Rule Guidance helpful Links
Federal Standards Applicability Table
Emissions Calculations Spreadsheet
Representative Gas and Liquid Analysis
Control Device Charts

23. Oil and Gas Permitting Options
De Minimis
Permit by Rule
Standard Permit
State Permit
NNSR and PSD
De Minimis
Permit by Rule
Standard Permit
State Permit
NNSR and PSD
Increasing
Levels of Emissions
The levels on the pyramid represent the different options for authorization under §

24. Standard Permit Options
Standard permit under §
“Old Standard Permit”
Non-rule standard permit
Applies to new projects and dependent facilities in the Barnett Shale counties
Sites in other counties can use it voluntarily
Like the PBR for oil and gas handling and production facilities, the permitting options may depend on your location.
New projects and dependent facilities constructed in the counties listed as “Barnett Shale Counties” may be eligible to register for the non-rule standard permit.
Companies outside of the Barnett Shale Counties are eligible to claim the “old” standard permit in 30 TAC § , but may voluntarily register under the new requirements in subsections (a)-(k) of the non-rule standard permit.
Standard permits are renewed by the TCEQ every ten years.
At the ten-year renewal of a standard permit, the entire site will be reviewed and permitted only if it meets the most recent rule requirements. If new rules have come out, or new federal requirements have been published, the facility will have to show compliance with these new rules even if nothing has changed at the site.
The fee for a standard permit is $900.

25. Standard Permit Under §116.620 “Old Standard Permit”
Sour sites that can’t meet ¼ mile limit in § (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

26. 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 § (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.

27. Non-Rule Standard Permit Emission Limits
Contaminant
Steady-state or < 30 psig
(lb/hr) (normal emissions)
> 30 psig Periodic
(lb/hr) (MSS, loading, etc)
Total (tpy)
Total VOC
250
Total Crude Oil or condensate VOC
145
318
Total natural gas VOC
750
1,635
Benzene 7
15.4
10.2
Hydrogen sulfide
10.8
9.8 47
Sulfur dioxide
93.2
Nitrogen oxides
121
Carbon monoxide
104
PM10/PM2.5 28 15
This slide shows a table containing information about the emission limits for a non-rule standard permit.

28. Oil and Gas Permitting Options
De Minimis
Permit by Rule
Standard Permit
State Permit
NNSR and PSD
De Minimis
Permit by Rule
Standard Permit
State Permit
NNSR and PSD
Increasing
Levels of Emissions
The levels on the pyramid represent the different options for authorization under 30 TAC §
State permit – also referred to as Minor New Source Review
Nonattainment NSR and PSD – for major sources
If your oil and gas site cannot qualify for PBR or a standard permit, you can call the Air Permits Division to discuss your options.

29. Contact information
Kristyn Bower: (512) David Reyna: (512) Air Permits Main Line : (512)