Texas Oil and Gas Air Permitting: A Practitioner s Guide

Transcription

1 Texas Oil and Gas Air Permitting: A Practitioner s Guide B RYA N O S BORNE SA LLY B I T TI CK, P. E. Z E P H YR E N VI RONMENTAL C O RP OR ATI ON NOVEMBER 28-29, 2017 HOUSTON, TEAS

2 Purpose NOVEMBER 28-29, 2017 HOUSTON, TEAS

3 Intent Background Presentation Overview Specifics Case Studies

4 Authorization Overview Documentation Options De Minimis Activities Preconstruction Permits Operating Permits Permits by Rule (PBR) Title V Standard Permits Case by Case Permits NOVEMBER 28-29, 2017 HOUSTON, TEAS

5 Unregistered Permits Under what conditions do sites not require registration with the TCEQ? Sites with engines < 240 horsepower Sweet sites (< 24 ppm H2S) NOVEMBER 28-29, 2017 HOUSTON, TEAS

6 Registered Permits When does a site require registration with the TCEQ? Sites with engines > 240 horsepower Sour sites (> 24 ppm H2S) Sites requiring controls to meet permit limits Modifications to existing registrations Engine replacements Addition/Removal of equipment Change in operations Increase in production

7 Permits by Rule (PBR) Simple oil and gas sites Low site-wide emission limits (<25 tpy VOC or SO2) No receptors within ¼ mile of a sour site [ (l) only] Minimal monitoring and recordkeeping requirements Can construct and operate immediately No permit expiration date, $450 Registration fee Common O&G PBR Authorizations Oil & Gas [30 TAC (a)-(k) or (l)] Flares [30 TAC ], Engines/Turbines [30 TAC ] MSS Activities [30 TAC ]

8 Permit by Rule: 352(l) Category Permit Specifics Timing Sweet Gas Sites no waiting period Sour Gas Sites up to 30 days for TCEQ review Control/Emission Requirements Follow (flare design) & 512 (engine NOx limits and NOx impacts eval.) Minimum vent height of 20 for H2S sources higher depending on lb/hr rate MSS Activities Can be authorized under either: (l) (general O&G PBR) (MSS specific PBR) Impact Assessments Sweet Gas Sites NAAQS Sour Gas Sites no receptors within 1/4 mile Tech. Requirements Very few specific requirements other than referenced PBRs

9 Permit by Rule: 352(a)-(k) Barnett Shale PBR Category Permit Specifics Timing Immediate notification, up to 30 days for TCEQ review Control/Emission Requirements Equip. distance to property line, engine requirements, open top tanks, quarterly LDAR, destruction efficiency, combined control MSS Must be included in PBR (a)-(k) Impacts Required for NO2, SO2, H2S, and Benzene unless trivial Tech. Requirements Much more prescriptive than (l)

10 Standard Permits Two Types of Standard Permits for Oil & Gas Sites: 1. Section (Installation and/or Modification of Oil and Gas Facilities) 2. Non-rule (Barnett Shale) Standard Permit for Oil and Gas Effective February 2011 and optional for sites located outside of Barnett Shale Suitable for oil and gas sites with higher emission rates Increased monitoring and recordkeeping requirements (vs PBR) Increased control requirements (vs PBR) Impacts evaluation demonstrating compliance Can operate within 45 days ( ) or immediately (w NRSP notification) Permit is good for 10 years, $900 registration fee

11 Standard Permit: Category Permit Specifics Timing Up to a 45 day TCEQ review Control/Emission Requirements MSS Activities Impact Assessments Tech. Requirements Follow & requirements Emission limits subject to /262 review (<6 lb/hr of each speciated VOC) Std. Pmt or PBR VOC/H2S subject to /262 review NO2 and SO2 (SCREEN3 is common) May require LDAR

12 NonRule Standard Permit (NRSP) Category Permit Specifics Timing Immediate notification, up to 30 days for TCEQ review Control/Emission Requirements Equip. distance to property line, engine requirements, open top tanks, quarterly LDAR, destruction efficiency, combined control MSS Activities Must include in NRSP (no PBR option) Impact Assessments NO2, SO2, H2S, and Benzene Tech. Requirements More prescriptive than Std. Pmt.

13 NRSP: Emission Limits

14 Confused? NOVEMBER 28-29, 2017 HOUSTON, TEAS

15 Aggregation Issues What equipment (facilities) should be included in the permit? SB1134 from the 82nd Legislature, effective 6/17/2011, applies to PBRs and Std. Permits Aggregation of facilities: Are under common control Belong to the same first two digits of the SIC code Operationally dependent Located not more than ¼ mile from each other Owned Leased

16 Facility Size Timing Authorization Selection Criteria Emission Limits Technical Requirements Operational Flexibility NOVEMBER 28-29, 2017 HOUSTON, TEAS

17 O&G Permit Sweet Spots PBR Scenario STD. PERMITS NRSP Low prod., basic equip., sweet gas Higher Prod., basic equip., sweet gas High H2S (sour site) Compression Central Facilities (tanks, loading, compression) Gas Processing (Midstream) Multi-train Gas Processing CASE BY CASE NSR

18 O&G Permit Sweet Spots PBR Scenario STD. PERMITS NRSP Low prod., basic equip., sweet gas Higher Prod., basic equip., sweet gas High H2S (sour site) Compression Central Facilities (tanks, loading, compression) Gas Processing (Midstream) Multi-train Gas Processing CASE BY CASE NSR

19 O&G Permit Sweet Spots PBR Scenario STD. PERMITS NRSP Low prod., basic equip., sweet gas Higher Prod., basic equip., sweet gas High H2S (sour site) Compression Central Facilities (tanks, loading, compression) Gas Processing (Midstream) Multi-train Gas Processing CASE BY CASE NSR

20 O&G Permit Sweet Spots PBR Scenario STD. PERMITS NRSP Low prod., basic equip., sweet gas Higher Prod., basic equip., sweet gas High H2S (sour site) Compression Central Facilities (tanks, loading, compression) Gas Processing (Midstream) Multi-train Gas Processing CASE BY CASE NSR

21 O&G Permit Sweet Spots PBR Scenario STD. PERMITS NRSP Low prod., basic equip., sweet gas Higher Prod., basic equip., sweet gas High H2S (sour site) Compression Central Facilities (tanks, loading, compression) Gas Processing (Midstream) Multi-train Gas Processing CASE BY CASE NSR

22 O&G Permit Sweet Spots PBR Scenario STD. PERMITS NRSP Low prod., basic equip., sweet gas Higher Prod., basic equip., sweet gas High H2S (sour site) Compression Central Facilities (tanks, loading, compression) Gas Processing (Midstream) Multi-train Gas Processing CASE BY CASE NSR

23 O&G Permit Sweet Spots PBR Scenario STD. PERMITS NRSP Low prod., basic equip., sweet gas Higher Prod., basic equip., sweet gas High H2S (sour site) Compression Central Facilities (tanks, loading, compression) Gas Processing (Midstream) Multi-train Gas Processing CASE BY CASE NSR

24 O&G Permit Sweet Spots PBR Scenario STD. PERMITS NRSP Low prod., basic equip., sweet gas Higher Prod., basic equip., sweet gas High H2S (sour site) Compression Central Facilities (tanks, loading, compression) Gas Processing (Midstream) Multi-train Gas Processing CASE BY CASE NSR

25 What if I need something bigger? More operational flexibility? NOVEMBER 28-29, 2017 HOUSTON, TEAS

26 Case by Case Permits New Source Review (NSR) or Case-by-Case Permit Oil & gas site that cannot meet Standard Permit Limits or those that need more flexibility. Permitting time is months Public notice is required Best Available Control Technology (BACT) Requirements Detailed dispersion modeling required, including MSS emissions Expect detailed permit conditions including recordkeeping Registration fee is variable based on capital cost (up to $75,000) Permit is good for 10 years

27 Even bigger? NOVEMBER 28-29, 2017 HOUSTON, TEAS

28 Prevention of Significant Deterioration (PSD) Major oil & gas site that exceeds 250 tpy of a criteria pollutant OR a named source (refineries, petroleum storage/transport >300k bbl, sulfur recovery) that exceeds 100 tpy of a criteria pollutant Permit time is months Public notice is required Significant modeling effort Permit will have major source modification triggers

29 Case Studies NOVEMBER 28-29, 2017 HOUSTON, TEAS

30 Case Studies NOVEMBER 28-29, 2017 HOUSTON, TEAS

31 Case Study A An existing unauthorized production facility and associated saltwater disposal handling sour gas with VOC emissions <25 tpy are being permitted. The site is close to a structure that appears to have RV style trailers parked nearby. Sour gas must be registered, 352(l)? Proximity to RV trailers may prohibit 352(l) 352(a)-(k)? NOVEMBER 28-29, 2017 HOUSTON, TEAS

32 NOVEMBER 28-29, 2017 HOUSTON, TEAS

33 What is considered a receptor? (l) TCEQ Definitions: Homes, Schools, daycare, hospital, places of worship, parks, etc. Exclusions: Structures owned by mineral lease holders who have a financial stake in the O&G operation Hunting Camps Storage Sheds

34 Case Study A (cont.) An existing unauthorized production facility and associated saltwater disposal handling sour gas with VOC emissions < 25 tpy are being permitted. The site is close to a structure that appears to have RV style trailers parked nearby. Sour gas must be registered, 352(l)? Proximity to RV trailers 352(a)-(k)? Staff in area advised that the RV trailers were part of a hunting camp. Recommendation: TCEQ opinion did not consider the hunting camp a receptor since it was used seasonally/sporadically. PBR 352(l). NOVEMBER 28-29, 2017 HOUSTON, TEAS

35 Case Study B An existing tank battery handling sweet hydrocarbons (authorized under a non-registered 352(l) PBR) will soon have several sour wells tied in, but VOC emissions are expected to stay below 25 tpy. Operations tells the EHS group that more well additions may be happening in the future. The tank battery is near a home, but this wasn t a problem when the site was handling sweet fluids. Sour fluids, will require registration 352(a)-(k) Emission limits 352(a)-(k) NOVEMBER 28-29, 2017 HOUSTON, TEAS

36 352(a)-(k) v. NRSP NOVEMBER 28-29, 2017 HOUSTON, TEAS

37 Case Study B (cont.) An existing tank battery handling sweet hydrocarbons (authorized under a non-registered 352(l) PBR) will soon have several sour wells tied in, but VOC emissions are expected to stay below 25 tpy. Operations tells the EHS group that more well additions may be happening in the future. The tank battery is near a home, but this wasn t a problem when the site was handling sweet fluids. Sour fluids, will require registration 352(a)-(k) Emission limits 352(a)-(k) or NonRule Std. Permit Recommendation: While the site could be permitted under PBR 352(a)-(k), the BMP s, recordkeeping & monitoring requirements are so similar to those in the NonRule, that the NonRule is appealing for the higher emission limits (especially considering future expansion). NOVEMBER 28-29, 2017 HOUSTON, TEAS

38 Case Study C An existing gas plant is permitted under a NonRule Std. Permit with VOC totals ~60 tpy. The owner has plans to build a nearly identical second processing train at the same site. Along with the second train, operations requested that annual turnarounds be permitted for both trains. Proposed Sitewide VOC total ~120 tpy NonRule, or NSR Timeline NonRule, or NSR NOVEMBER 28-29, 2017 HOUSTON, TEAS

39 Case Study C (cont.) An existing gas plant is permitted under a NonRule Std. Permit with VOC totals ~60 tpy. The owner has plans to build a nearly identical second processing train at the same site. Along with the second train, operations requested that annual turnarounds be permitted for both trains. Proposed Sitewide VOC total ~120 tpy NonRule, or NSR Timeline NonRule, or NSR What if construction needs to begin in six months? NOVEMBER 28-29, 2017 HOUSTON, TEAS

40 Case Study C (cont.) An existing gas plant is permitted under a NonRule Std. Permit with VOC totals ~60 tpy. The owner has plans to build a nearly identical second processing train at the same site. Along with the second train, operations requested that annual turnarounds be permitted for both trains. Proposed Sitewide VOC total ~120 tpy NonRule, or NSR Timeline NonRule, or NSR What if construction needs to begin in six months? MSS hourly MSS limits in NonRule are likely too low NOVEMBER 28-29, 2017 HOUSTON, TEAS

41 NRSP: Emission Limits

42 Case Study C (cont.) An existing gas plant is permitted under a NonRule Std. Permit with VOC totals ~60 tpy. The owner has plans to build a nearly identical second processing train at the same site. Along with the second train, operations requested that annual turnarounds be permitted for both trains. Proposed Sitewide VOC total ~120 tpy NonRule, or NSR Timeline NonRule, or NSR What if construction needs to begin in six months? MSS hourly MSS limits in NonRule are likely too low Recommendation: Std. Pmt PBR for MSS (no PBR hourly emission limits). Some timing flexibility is lost without the ability to submit NonRule notifications. NOVEMBER 28-29, 2017 HOUSTON, TEAS

43 Thanks! NOVEMBER 28-29, 2017 HOUSTON, TEAS

44 Thank you! Bryan Osborne Sally Bittick, P.E. Zephyr Environmental Corporation Visit us at and

45 Standard Permit : Speciation TCEQ Memo 1/18/2006 O&G Standard Air Permit Guidelines Natural gas speciated to C3 through C5, and BTE Condensate speciation for components making up 1% or more of the liquid C10+ v. extended analysis Crude oil does not require speciation ( , 6 lb/hr & 10 tpy) H2S L-value of 10 instead of published value of 1.1 in

46 Standard Permit : LDAR Leak Detection and Repair (LDAR) LDAR requirements for facilities < 500 ft from receptor None: Less than 10 tpy of uncontrolled fugitives LDAR requirements for facilities 500 ft from receptor None: Less than 25 tpy of uncontrolled fugitives H2S or SO2 emitting facilities < ¼ mile from receptor Daily auditory and visual checks

47 Standard Permit : E=L/K Calculating Emission Rates of same compound from different EPNs for Weighted Average Method Example E=L/K H2S L value of 10 mg/m3 K value based on distance to nearest offsite receptor EPN 1-10% of project lb/hr at 1000 ft: K=34 EPN 2-40% of project lb/hr at 2000 ft: K=14 EPN 3-50% of project lb/hr at 3000 ft: K=8 E=(10% x 10/34)+(40% x 10/14)+(50% x 10/8) = 0.94lb/hr

48 NRSP: Notifications Step 1: Prior to construction or implementation of changes for any project which meets this standard permit a notification shall be submitted through the e-permits system. *Emission limits are established immediately after notification even if an application has not yet been submitted.* Step 2: Within 90 days after start of operation or implemented changes (whichever occurs first), the facilities must be registered with a PI-1S Standard Permit Application.

49 NRSP: Turbines Compression turbines must meet Table 6 emission limits (25ppm NOx, 50ppm CO). Power turbines [operated < 876 hours/yr] can operate at Table 6 limits (25ppm NOx, 50ppm CO) if no reliable electric power is available. Power turbines [operated > 876 hours/yr OR those installed in locations with reliable electric service] may be authorized if they can meet emission limits set in the TCEQ EGU Standard Permit, which will likely require SCR catalyst.