TCEQ Air Quality 101 Blog Series – PBR for Oil and Gas Handling and Production Facilities
Posted: June 11th, 2018Author: All4 Staff
As the summer months roll around the corner, many are focused on the hot summer activities: swimming, picnics, trips to the beach, and generally taking it easy. If you’re in the Oil and Gas industry, there’s one more way you can take it easy: Permit by Rule (PBR) 30 Texas Administrative Code (TAC) 106.352: Oil and Gas Handling and Production Facilities! With just a little bit of knowledge, and a few small steps, you can bypass the permitting stress, and cool off the rest of your summer! For this installment of ALL4’s Texas Commission on Environmental Quality (TCEQ) Air Quality 101 Blog Series, we provide a brief overview of this PBR and how it applies to different facilities.
First things first, you have to understand what a PBR is to use one. PBRs are the permitting option between a facility with greater than de minimis emissions and a facility with emissions less than Standard Permit options. Most PBRs are a quick and relatively painless way of saying that your facility meets a set of established standards, and doesn’t need to meet the additional compliance obligations that may come from a Standard Permit. To determine if you even qualify for a PBR in the state of Texas, check 30 TAC 106.4 Requirements for Permitting by Rule and the applicability checklist known as the TCEQ-10149 to decide if this is an option for you. If you think it is the right option, confirm that your facility can comply with the PBR conditions. Once you do, you can complete a TCEQ-10228 Form, pay your registration fee, and begin constructing worry free! But, that’s not all! Once you’ve registered a PBR, there is no expiration date! That means that once the PBR has entered the system, your facility does not need to renew its PBR unless you make significant modifications or add new equipment.
Non-Barnett Shale PBR
After determining if a PBR is right for you, you will then determine which section of 30 TAC 106.352 applies to you. If your facility is located in the Barnett Shale region (Cooke, Dallas, Denton, Ellis, Erath, Hill, Hood, Jack, Johnson, Montague, Palo Pinto, Parker, Somervell, Tarrant, and Wise counties) and constructed after April 1, 2011, then 30 TAC 106.352 (a) – (k) applies to you, otherwise, oil and gas handling and producing facilities only have to meet the requirements for 30 TAC 106.352(l). 30 TAC 106.352(l) is straightforward and less stringent. The regulation references additional requirements in 30 TAC 106.492 for Flares and 30 TAC 106.512 for Stationary Engines and Turbines. The regulation then sets forth emissions limits and additional requirements for sour gas facilities [facilities with greater than 24 ppm hydrogen sulfide (H2S) in their natural gas]. The requirements include a minimum stack height of 20 feet for units emitting H2S, a distance of ¼ mile between any receptors and sulfur producing units, and a PI-7 registration for sour gas facilities. Sour gas facility notifications under this section are subject to a 30-day review period prior to being accepted. As long as these requirements are met, a production facility is able to obtain a PBR under 30 TAC 106.352(l). As of February 1, 2018, all PBRs and standard permits must be submitted electronically through State of Texas Environmental Electronic Reporting System (STEERS) with a fee of $450 for 30 TAC 106.352(l) PBRs.
Barnett Shale PBR
Facilities in the Barnett Shale region however, need to meet the minimum requirements set forth in 30 TAC 106.352(e) Best Management Practices (BMP) and Minimum Requirements, such as a maintenance plan, leak detection and repair (LDAR) program, and control equipment requirements. A facility must also meet the most stringent [30 TAC 106.352(g) Level 1 Requirements] emissions limits or less stringent [30 TAC 106.352(h) Level 2 Requirements] emissions limits depending on the outcome of their impact evaluation. The impact evaluation required by 106.352(k) Emission Limits Based on Impacts Evaluation, determines the impact on nitrogen oxides (NOx), sulfur dioxide (SO2), and H2S and the evaluation is based on both emissions level and distance of property line and receptor location criteria. Level 1 requirements are implemented if there is a property line or receptor within ¼ mile and can meet the limits of 15 tons per year (tpy) volatile organic compounds (VOC), 100 tpy NOX and SO2, and 20.6 tpy H2S. Level 2 requirements are implemented for facilities that must meet the 25 tpy VOC, 250 tpy NOX and SO2, and 25 tpy H2S limits, but the closest receptor is at least ½ mile away.
A facility in this region must also follow the requirements listed in 30 TAC 106.352(f) Notification, Certification, and Registration Requirements, such as submitting a Core Data Form, records of maintenance, startup, and shutdown (MSS) activities, and register maximum emissions estimates. These permits must also be must be submitted electronically through STEERS with a fee of $175 for Level 1 registration and $400 for a Level 2 registration. Once the facility has notified the TCEQ, they have up to a 30-day review period prior to being approved. The rule further lists recordkeeping, sampling, and monitoring required for each site based on engine type, size, and manufacture date.
With such a streamlined process and shortened air permitting timeline, this oil and gas PBR is sure to help you get on to construction and begin operating sooner so you can free up your schedule for more summer fun. If you think you might qualify for this PBR, or you have questions on this blog do not hesitate to contact us. Stay tuned for our next installment of our TCEQ Air Quality 101 Blog Series (www.all4inc.com/texas). Thanks for reading!