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Hot Topics Federal Standards for the Oil and Gas Industry

Hot Topics Federal Standards for the Oil and Gas Industry. Anne Inman, P.E. Air Permits Division Texas Commission on Environmental Quality Environmental Trade Fair 2013. New and Revised Federal Requirements. New NSPS OOOO Revised NESHAP HH and HHH Proposed August 23, 2011

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Hot Topics Federal Standards for the Oil and Gas Industry

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  1. Hot Topics Federal Standards for the Oil and Gas Industry Anne Inman, P.E. Air Permits Division Texas Commission on Environmental Quality Environmental Trade Fair 2013

  2. New and Revised Federal Requirements • New • NSPS OOOO • Revised • NESHAP HH and HHH • Proposed August 23, 2011 • Final Published August 16, 2012 • Effective Date October 15, 2012

  3. NSPS OOOO, NESHAP HH AND HHH • Affected Facilities • Natural gas well completions • Storage vessels • Compressors • Pneumatic controllers • Glycol dehydrators • Gas plants fugitives and treatment units

  4. Fracked Natural Gas Wells Focuses on reducing VOCs from hydraulically fractured natural gas wells during the flowback period. • Phased Requirements for Green Completions • Exceptions for Wildcat, Delineation, and Low Pressure Wells • Includes Pre-completion Notification and Annual Reporting Requirements

  5. Common Questions • Jurisdiction? • Any New Guidance? • How Do I Notify? Well Completion/Flowback Notification is now done through e-mail using a form that can be found on our website. Well Completion / Flowback Notification

  6. Well Completion/Flowback Notification Form

  7. Common Tank Questions • Applicable Statewide or Just at the Wellhead? • Temporary Tanks (<180 days) • After Controls? • Potential to Emit (PTE) is on a Per Tank Basis • Once In – Always In?

  8. Additional Requirements Summary • Centrifugal & Reciprocating Compressors (Manufactured, Initially Installed but Not Relocated) • New and Replacement Pneumatic Controllers From Gas Wells to Processing Plants

  9. Additional Requirements Summary(cont’d) • Sweetening Units & Fugitives at Gas Plants • Glycol Dehydrators (Small and Large at Major Sites)

  10. August 23, 2011 Applicability Based on New or Modified • August 23, 2011 Applicability • Based on New or Modified • Hydraulically Fractured Natural Gas Well Completion (Flowback) • Tanks • Centrifugal Compressors With Wet Seals • Reciprocating Compressors • Small and Large Dehydrators

  11. October 15, 2012 Applicability • October 15, 2012 Applicability • Well Flowback Emissions to Flare (or Voluntary to REC) • Centrifugal Compressors (Wet Seals) Controlled 95% • Reciprocating Compressors Rod Packing Tracking • 3-year, or • 26,000 run-time hours • Continuous Bleed Pneumatic Controllers at Gas Plants With No Bleed Controllers

  12. October 12, 2012 Applicability (cont’d) • Fugitives at Gas Plants LDAR (500 ppm) • Sweetening Units at Gas Plants (Up to 99.9%) • New Small Dehydrators (Value) • New Large Dehydrators (95%) • ALL No Exceptions for Start-up, Shut-downs, or Malfunctions (VOC and SO2)

  13. October 15, 2013 Applicability • October 15, 2013 Applicability • Continuous Bleed Pneumatic Controllers at Wellhead to Gas Plants With Low Bleed Controllers • Tank VOC Reduction 95%

  14. January 15, 2015 Applicability • January 15, 2015 Applicability • Gas Well Flowback Emissions to REC and Flare (100% Capture/Control)

  15. October 15, 2015 Applicability • October 15, 2015 Applicability • Existing Small Dehydrators (Value) • Existing Large Dehydrators (95%)

  16. Applicability Forms • If New Site/New Equipment Show compliance with or non-applicability of NSPS OOOO in application using PI-7-CERT or APD-CERT • If Existing Site/Equipment Use APD-CERT to show compliance with or non-applicability of NSPS OOOO

  17. Why/When Do I Need to Certify? • Enforceable Limit • Control/Destruction Efficiency Claims • Operating Hours

  18. Where to Find More Information • www.texasoilandgashelp.org • airog@tceq.texas.gov • Air Permits Main line: (512) 239-1250 • Small Business and Environmental Assistance: 1-800-447-2827 or www.TexasEnviroHelp.org

  19. Questions?

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