Hot Topics Federal Standards for the Oil and Gas Industry

Anne Inman, P.E.Air Permits Division

Texas Commission on Environmental QualityEnvironmental Trade Fair 2013

Hot Topics Federal Standards for the

Oil and Gas Industry

New◦NSPS OOOO

Revised◦NESHAP HH and HHH

Proposed August 23, 2011 Final Published August 16, 2012 Effective Date October 15, 2012

New and Revised Federal Requirements

Affected Facilities◦Natural gas well completions◦Storage vessels◦Compressors◦Pneumatic controllers◦Glycol dehydrators ◦Gas plants fugitives and treatment units

NSPS OOOO, NESHAP HH AND HHH

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

Fracked Natural Gas Wells

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

Common Questions

Well Completion/Flowback Notification Form

Applicable Statewide or Just at the Wellhead?

Temporary Tanks(<180 days)

After Controls?Potential to Emit (PTE) is on a Per Tank

BasisOnce In – Always In?

Common Tank Questions

Centrifugal & Reciprocating Compressors (Manufactured, Initially Installed but Not Relocated)

New and Replacement Pneumatic Controllers From Gas Wells to Processing Plants

Additional Requirements Summary

Sweetening Units & Fugitives at Gas Plants Glycol Dehydrators (Small and Large at

Major Sites)

Additional Requirements Summary

(cont’d)

August 23, 2011 Applicability Based on New or Modified

August 23, 2011 ApplicabilityBased on New or Modified

Hydraulically Fractured Natural Gas Well Completion (Flowback)

Tanks

Centrifugal Compressors With Wet Seals

Reciprocating Compressors

Small and Large Dehydrators

October 15, 2012 Applicability

Reciprocating Compressors Rod Packing Tracking

o 3-year, or

o 26,000 run-time hours

Continuous Bleed Pneumatic Controllers at Gas Plants With No Bleed Controllers

October 15, 2012 Applicability

Well Flowback Emissions to Flare (or Voluntary to REC)

Centrifugal Compressors (Wet Seals) Controlled 95%

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)

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%

January 15, 2015 Applicability

January 15, 2015 Applicability

Gas Well Flowback Emissions to REC and Flare (100% Capture/Control)

October 15, 2015 Applicability

October 15, 2015 Applicability

Existing Small Dehydrators (Value)

Existing Large Dehydrators (95%)

If New Site/New EquipmentShow compliance with or non-applicability of NSPS OOOO in application using PI-7-CERT or APD-CERT

If Existing Site/EquipmentUse APD-CERT to show compliance with or non-applicability of NSPS OOOO

Applicability Forms

Enforceable Limit Control/Destruction Efficiency Claims Operating Hours

Why/When Do I Need to Certify?

www.texasoilandgashelp.org [email protected] Air Permits Main line: (512) 239-1250 Small Business and Environmental

Assistance: 1-800-447-2827 or www.TexasEnviroHelp.org

Where to Find More Information

Questions?