Hot Topics in Oil and Gas Permitting

Oil and Gas NSPS OOOOa, CTG and Source Determination Rule in Texas Samuel Short, Manager Air Permits Division Texas Commission on Environmental Quality Topics for Discussion ePermits Updates to NSPS Draft CTG for the Oil and Natural Gas Industry

Aggregation of Oil and Gas Sites STEERS ePermitting System What can I register with it? All PBRs Oil and Gas Standard Permits Am I required to use it?

STEERS How fast is it? All 75 PBRs that dont require registration will have a same-day response. STEERS Oil and Gas Projects Ne w! Same-day response (if specific parameters);

Company will receive authorization letter; and Staff will periodically review these submittals manually. Methane and VOC Standards Proposal to amend NSPS OOOO and OOOOa by setting standards for methane and VOC

Proposal published in Federal Register on September 18, 2015 Sources Affected Compressors (centrifugal and reciprocating) Pneumatic controllers and pumps Hydraulically fractured wells (well completions) Well site and compressor station fugitives

Natural gas processing plant equipment leaks Pneumatic Pumps New, modified, and reconstructed natural gas- driven and diaphragm pumps Requires emission control by 95% in all source categories except natural gas processing plants

For natural gas processing plants, emissions of methane and VOC must be zero Hydraulically Fractured Wells Non-exploratory & non-delineation wells Exploratory &

delineation wells Reduced emissions Combustion device completions aka green completion Combustion device

Fugitive Emissions Monitoring Defines fugitive emission components Requires use of optical gas imaging Sets leak monitoring schedule: Includes incentives for minimizing leaks Includes requirements for repairing leaks and resurveying

Electronic Reporting Requires electronic submittal of reports (CEDRI) May require reporting quantitative environmental results on corporate websites TCEQ Comments on NSPS OOOOa

Impact on Regulatory Agency Workload Independent third party verification Electronic reporting TCEQ Comments on NSPS OOOOa Impact on Industry Number of active wells

Cost of implementation Proposed timelines Support for prosed exemptions for low production well sites TCEQ Comments on NSPS OOOOa Leak Detection and Repair Program (LDAR) Use of Optical Gas Imaging

Existing LDAR programs Repair time for leaking components Sonic Flares and Control Technology Control Techniques Guidelines Draft published in Federal Register on September 18, 2015

Recommendations for evaluation of VOC RACT for existing sources in ozone nonattainment areas classified as moderate or above Sources Affected by Control Changes Storage vessels Equipment leaks from natural gas processing

plants Compressors and pneumatics Fugitive emissions TCEQ Comments on Draft CTG Draft CTG Use Due Date for SIP revisions Model Rule Language

Pneumatic Controllers and Pumps/ closed vent systems and equipment leaks Fugitive Emissions from Well Sites and Compressor Stations Source Determination EPA Proposal Option 1 - within

mile Option 2 - within mile or greater than mile with functional interrelatedness Texas Statute Within mile and

operationally dependent TCEQ Comments on Source Determination General Comments on finalization of either option Probable increase in number of major source

permitting Permitting Timeframes Daisy Chaining Recent Updates April 2016, EPA sent the proposed final rule to the Office of Management and Budget for review with anticipation to issue by June.

March 10, 2016, EPA announced its next step in reducing emissions from the oil and natural gas industry: Moving to regulate emissions from existing sources. The EPA will begin with an Information Collection Request to gather a broad range of information on existing sources Contact Information

Samuel Short Air Permits Division (512) 239-5363 [email protected] Air Permits Main Line: (512) 239-1250 [email protected]

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