Our clients benefit from our interdisciplinary approach that combines subject-matter knowledge with skilled advocacy by experienced practitioners at the administrative, legislative, trial and appellate levels. Admin. is a privately held independent oil and gas company headquartered in Dallas, Texas. EPA Region 9 is responsible for issuing permits on Tribal Lands in California. that the TCEQ uses. From the TCEQs perspective these facilities do not have a large enough impact on the environment to regulate them. there are nearby off-site receptors. For all new projects or modifications to site located in Barnett Shale counties (Counties included in the Barnett Shale area are Cooke, Dallas, Denton, Ellis, Erath, Hill, Hood, Jack, Johnson, Montague, Palo Pinto, Parker, Somervell, Tarrant, and Wise counties). TCEQ currently issues Standard Air Permits for specific operations that are well characterized. In addition, unless electronically filing a new Barnett Shale project, a PI-1S Form, Core Data form, and all supporting documentation must be submitted. conditions of the Standard Permit. While complying with these requirements carries a certain additional burden and expense to operators in Texas, the alternative to proactively managing and complying with these requirements is less desirable for both the operators and the State. project is going to emit VOCs, it is highly recommended that Table 10 be National Emission Standards for Hazardous Air Pollutants, Federal regulations that may apply to your facility are indexed at, Subpart H Organic Hazardous Air Pollutants for Equipment Leaks, Subpart V Equipment Leaks (Fugitive Emission Sources), Subpart HH Oil and Natural Gas Production Facilities, Subpart VV Oil-Water Separators and Organic-Water Separators, Subpart HHH Natural Gas Transmission and Storage Facilities, Subpart YYYY Stationary Combustion Turbines, Subpart ZZZZ Stationary Reciprocating Internal Combustion Engines, Subpart A General Provisions (included requirements for flares), Subparts K and Ka Storage Vessels for Petroleum Liquids, Subpart Kb Volatile Organic Liquid Storage Vessels (including Liquid Storage). December 19, 2022 The Railroad Commission of Texas (RRC) has adopted new versions of the Irrevocable Letter of Credit (Form P-5LC) and Performance Bond (Form P-5PB), related to the execution, and filing of financial security by oil & gas and pipeline operators under their jurisdiction. Planned Maintenance, Start-ups and Shutdowns (MSS) The two most common for oil and gas facilities are Standard Permits and Permits by Rule. These facilities dont require a permit to operate nor do they have to be registered with the TCEQ. For projects located outside the Barnett Shale counties which are constructed or modified on or after April 1, 2011, companies may voluntarily register under the new requirements in (a)-(k). Families on the front lines of mining, drilling, and fracking need your help. Despite this, TCEQ did not shutdown the the site. your facility and aids in reducing the friction of the regulatory quagmire. This designation is used for an operation that emits below certain pollution thresholds established by the TCEQ. Copyright 2015 Breitling Consulting, LLC. a rq for oil is a discharge of oil in such quantities that the administrator has determined may be harmful to the public health or welfare or the environment of the united states and includes discharges of oil that violate applicable water quality standards or causes a film or sheen upon, or a discoloration of the water surface or adjoining It wasnt until, four months after Earthworks initial complaint that the TCEQ investigated the sitenot by actually physically visiting the site, but by simply doing a file reviewand discovered that the operator did not have an air quality permit for the site. Please click here to see any active alerts. The standard permit must include a list of authorized facilities and activities as well as general and operational requirements. It is however a means to bring clarity, greater operational flexibility and a more expeditious process for the construction, modification and operation of MLOs. The agencys decision was a departure from its proposal last fall to adopt rules that would affect oil and gas facilities statewide. Click "accept" below to confirm that you have read and understand this notice. Furthermore, compliance on a proactive basis is more cost-effective and less disruptive to production than reacting to enforcement actions. The type of authorization required will depend on the type of facility and amount of contaminants emitted. NSPS OOOOa. We help you prove and permit your emissions so you can focus on the task of getting your resources to the load line, pipeline or sales point. Pickpocket 21 was supposed to be a De Minimis Facility. In December of 2020, the Texas Commission on Environmental Quality (TCEQ) proposed a new non-rule Standard Permit (non-rule SP) for Marine Loading Operations (MLOs). Unfortunately, in a landscape dotted by thousands of well sites, even small amounts of pollution can add up to a significant impact. There was a problem processing your signup. Standard Permits, unlike PBRs, must be renewed opportunity for comments before the Commission. To prevent similar incidents from occurring on intrastate hazardous liquid pipelines, Governor Jerry Brown signed into law pipeline safety billsSB 295andAB 864later that year. The TCEQ's Small Business and Local Government Assistance Section offers free, confidential help to small businesses and local governments working to comply with state environmental regulations. Despite operating the site without a permit and polluting above claimed levels, MDC was allowed to continue business as usual and given a grace period to get that permit. The proposed non-rule SP, if finalized, would apply to MLOs at both new minor source sites and existing sites and would provide operational flexibility to applicants. Thus, state and local air agencies may have either more rules than what is submitted for SIP approval. Key highlights of the Non-Rule Standard Permit include: The Non-Rule Standard Permit is The highlights Air Quality Standard Permit for Oil and Gas Facilities, Air GOP No. Additional Information. 511: Oil and Gas General Operating Permit, Air GOP No. Copyright 2015 Breitling Consulting, LLC. EN English Deutsch Franais Espaol Portugus Italiano Romn Nederlands Latina Dansk Svenska Norsk Magyar Bahasa Indonesia Trke Suomi Latvian Lithuanian esk Unknown JavaScript appears to be disabled on this computer. Please click on one of the following links for more information about oil and gas compliance. Copyright 19962023 Holland & Knight LLP. inspections, monitoring, and repairs must be maintained. // < ! Johnson, Montague, Palo Pinto, Parker, Somervell, Tarrant, and Wise. This link leads to an external site which may provide additional information. Each facility must be operated at least 50 feet to be applied for by the majority of the State of Texas with the exception of The two most common for oil and gas facilities are Standard Permits and Permits by Rule. Electronic Notifications to the OSFM - Pipeline Safety Division, Pipeline Operators to notify the Office of the State Fire Marshal, Encroachments into or on Pipeline Easements, California State Fire Marshal Information Bulletin 03-001, Issued: June 20, 2003 (Revised September 25, 2019), ENCROACHMENTS INTO or ON PIPELINE EASEMENTS, Jurisdictional Evaluation Rural Gathering Pipeline, Jurisdictional Evaluation CA Government Code, Investigation reviews of accidents Review, Review of reported information data to OSFM and PHMSA, Employee Testing (i.e., drug and alcohol, training, certifications, and refreshers). Pollution Control Services coordinates with both the TCEQ Region 12 Office located in Houston (713) 767-3500 and the Central Office located in Austin (512) 239-1000 concerning activities that require and issuance of air permits. Inspection length depends on many factors, such as: company size, how many miles of pipeline, the complexity of the pipeline system, and the location of the pipelines. Air Quality Standard Permit for Oil and Gas Handling and Production Facilities Links to the rule and detailed information on the Standard Permit for Oil and Gas Handling and Production Facilities. every 10 years or the permit will expire. On October 8th, Earthworks sent an open letter to the Texas Commission on Environmental Quality (TCEQ) and Railroad Commission (RRC) outlining a history of misconduct at the MDC Pickpocket 21 drilling site. week well examine the Non-Rule Standard Permit. September 23, 2013: The EPA has published the direct final adoption of the changes to 40 CFR 60 NSPS Subpart OOOO. Yes. As a result of Earthworks complaints, TCEQ determined this to be the case when it investigated Pickpocket 21. Each inspection can take anywhere from one week for smaller operators to 12 days for larger operators. Permits go before the TCEQ Commissioners for approval, and the public has an These distance triggers could require the It is impossible to produce oil and gas without actual emissions or the potential to emit. As such, you need to register and permit your facilities, or register and retain the test data and support documentation in your lease files proving why you do not require permitting at that time. // < ! Instead, the operators were given more than three months to apply for the permit that they needed, during which time they continued to operate. be used for authorization if the facility is located within any of the above Federal Register Publication of Final Rules - Safety of Hazardous Liquid Pipelines. The two most common for oil and gas facilities are Standard Permits and Permits by Rule. the Non-Rule Standard Permit. No Harm Letter Review In addition, the standard permit section of the TCEQ website includes a background document and a copy of the permit. Air Quality Standard Permit for Oil and Gas Handling and Production Facilities, https://www.tceq.texas.gov/permitting/air/newsourcereview/chemical/oil_and_gas_sp.html, https://www.tceq.texas.gov/@@site-logo/TCEQ-1072x1072.png, Oil and Gas Vertical Fixed Roof Tank Workbook, 106.261 and 106.262 Single Project Workbook, Types of New Source Review Authorizations, Rule Registration Section: Planned Maintenance, Startup, and Shutdown, Small Business and Local Government Assistance, Oil and Gas Facilities: Compliance Resources, Status of Air Permits and Permit Applications, State, Federal and Historic Air Permitting Rules, The current standard permit Section 116.620 is applicable. By its action, the TCEQ replaced the current Permit by Rule (PBR) for oil and gas production facilities with a new PBR for those facilities (30 Tex. Share sensitive information only on official, secure websites. considerably more restrictive than the Rule Standard Permit. e-mail: airog@tceq.texas.gov notification. Submit the TCEQ permit application to the Railroad Commission's Injection-Storage Permits Unit with a cover letter requesting the Class I Oil and Gas No Harm letter. June 3, 2016: The EPA has published the direct final adoption of the changes to 40 CFR 60 NSPS Subpart OOOOa. For example, in some cases the TCEQ has granted permits to operators stating that they will use best practices to reduce emissions despite the absence of any explanation of what those practices will be. Site Help | Disclaimer | Site Policies | Accessibility | Website Archive | Our Compact with Texans | TCEQ Homeland SecurityStatewide Links: Texas.gov | Texas Homeland Security | TRAIL Statewide Archive | Texas Veterans Portal 2002-2022 Texas Commission on Environmental Quality. In each of these cases, operators submit a request to TCEQ for the type of permit they want. Ash Street Cottages Neighborhood Parking. This blog series will focus on the intricacies of Texas Operators determine which permit their facility needs based on their own emissions estimates (higher emitting facilities generally require Standard Permits while lower polluting facilities use Permits by Rule) and then apply for approval of the permit by the TCEQ. Instructions for participation are provided in the notice. Code 116.620). Standard Permit. Although following the applicable conditions of a Standard Air contaminants from upstream oil and gas operations are of concern to the TCEQ. Next The May 2015 pipeline incident at Refugio Beach in Santa Barbara County spilled over 100,000 gallons of crude oil into the Pacific Ocean and impacted over 25 miles of coastline. Oil and Gas Permitting is housed within the Office of Air. Written authorization is required prior to commencement of construction. EPA rules in 40 Code of Federal Regulations ("CFR . Title V Operating Permits In addition to the air authorizations previously discussed, sites designated as major sources of air pollutants, as defined in 30 TAC 122.10 (13) are required to obtain a Title V Operating Permit. An emissions inventory must be submitted for facilities (sites) that have the potential to emit 100 tons per year (. Since some of these sites arent registered with the TCEQ at all, it is difficult if not impossible to fully gauge the aggregate impact of De Minimis Facilities. Obtain a temporary parking permit to park along city streets. OSFM Pipeline Safety Division staff inspect pipeline operators to ensure compliance with federal and state pipeline safety laws and regulations, and consist of engineers, Geographical Information System (GIS)/mapping staff, analytical staff, and clerical support located throughout California. Formaldehyde (CH. Currently, MLOs are permitted in Texas either with a group of permits by rule (PBRs) that do not provide much operational flexibility or with a case-by-case New Source Review (NSR) permit. Official websites use .gov Benzene, among others, is of particular interest because it is a known carcinogen and is often present in hydrocarbon emissions from these facilities. Such activities may include exploration for crude petroleum and natural gas; drilling, SIC Code 1321 covers establishments primarily engaged in producing liquid hydrocarbons from oil and gas field gases. In addition to the required inspections, OSFM must also respond to intrastate pipeline accidents, investigate significant intrastate pipeline releases, inspect pipeline construction and relocation projects, respond to train derailments near pipelines, and meet with state and local governments to discuss various pipeline safety issues. mentioned in the previous post can be echoed for the Non-Rule Standard Standard Permit Facilities that cannot meet a PBR may qualify for a standard permit. typically require air emissions permits from TCEQ may be eligible for authorization through a standard air quality permit for oil and gas facilities, a new source review permit, or a specific air permit by rule for projects in the 15 counties located over the Barnett Shale. Does this relate to you and your operations? 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