air permitting in louisiana & texas a guide to compliance requirements presented by: shonta’...
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Air Permitting in Louisiana & Texasa guide to compliance requirements
presented by: Shonta’ Moore, MSAir Permitting Specialist - Environmental Division
Client Focused. Technology Driven.
• 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
BACKGROUND
STATE ENVIRONMENTAL AGENCIES
Louisiana Department of Environmental Quality
Texas Commissionon Environmental Quality
State agency responsible for upholding the federal air standards in Texas
State agency responsible for upholding the federal air standards in Louisiana
FEDERAL REGULATIONS
Clean Air Act (CAA)Clean Air Act of 1963Amended 1970Amended 1977Amended 1990
These federal regulations established National AmbientAir Quality Standards (NAAQS) that each state must uphold.
NATIONAL AMBIENT AIR QUALITY STANDARDS (NAAQS)
EPA has set national limits forthese 6 “Criteria Pollutants”:
(SO2)
(NO2)
(CO)
(PM10)
Lead
Ozone
Sulfur Oxides
Nitrogen Oxides
Carbon Monoxide
Particulate Matter
(Pb)
(O3)
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
AscensionIbervilleEast Baton RougeWest Baton RougeLivingston
TEXAS OZONE NONATTAINMENT COUNTIES
BrazoriaChambersCollinDallasDentonEl PasoEllisFort BendGalvestonHarrisJohnsonKaufmanLibertyMontgomeryParkerTarrantWallerWise
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 limitsVariances
• 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
• Line Heaters
• Glycol Dehydrator
• Compressors
• Flares
• Flash Gas Losses
• Waste Gas Waste Gas Disposal
• Produced Water Storage Tanks
• Oil/Condensate Storage Tank
• Gas driven pumps
• Generators
• Amine Units
• Marine/Truck Loading
• Fugitive Emissions
FUEL COMBUSTION EQUIPMENT
Examples:Heater treater burnersLine heater burnersGlycol dehydrator reboiler burnersAmine unit reboiler burnersFlares
limited to 0.6 lbs/hr PM per MMBTU of heat
input smoke from combustion must not exceed shade requirements
PM, SO2, NOx, CO, and VOC Emissions
INTERNAL COMBUSTION ENGINES
NOx, CO, and VOC Emissions
Examples:Compressor EnginesGenerator EnginesSaltwater Pump Engines
>500 HP require testing: w/o converter = semi annually w/ converter = annual testing
STORAGE VESSELS
VOC Emissions
Examples:Produced Water Storage TanksOil/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 TanksHeater TreatersSeparators
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 & AnswersShonta’ N. Moore, MS
Environmental SpecialistFENSTERMAKER
5005 Riverway Dr., Suite 300Houston, TX 77056
713.840.9995 ext. 1435shonta@fenstermaker.com
Client Focused. Technology Driven.
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