Transcript Air Permitting in Louisiana & Texas

Air Permitting in Louisiana & Texas
a guide to compliance requirements
presented by: Shonta’ Moore, MS
Air Permitting Specialist - Environmental Division
Client Focused. Technology Driven.
BACKGROUND
• 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
STATE ENVIRONMENTAL AGENCIES
Louisiana Department
of Environmental Quality
Texas Commission
on Environmental Quality
State agency responsible for upholding
the federal air standards in Louisiana
State agency responsible for upholding the
federal air standards in Texas
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”:
Sulfur Oxides
(SO2)
Particulate Matter (PM10)
Nitrogen Oxides
(NO2)
Lead
(Pb)
Ozone
(O3)
Carbon Monoxide (CO)
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
• Produced Water Storage Tanks
• Line Heaters
• Oil/Condensate Storage Tank
• Glycol Dehydrator
• Gas driven pumps
• Compressors
• Generators
• Flares
• Amine Units
• Flash Gas Losses
• Marine/Truck Loading
• Waste Gas Waste Gas Disposal
• Fugitive Emissions
FUEL COMBUSTION EQUIPMENT
PM, SO2, NOx, CO, and VOC Emissions
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
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 77056
713.840.9995 ext. 1435
[email protected]
Client Focused. Technology Driven.