Oil & Gas
Oil and gas facilities must contend with a variety of regulatory and environmental compliance demands, and Trinity is particularly well qualified to assist organizations in meeting these requirements. Trinity has assisted oil and gas facilities with more than 900 projects, and this extensive experience equips us to meet your environmental compliance needs quickly, accurately, and within budget.
Client Testimonial
"Trinity Consultants has been very helpful by providing quick and thorough responses to regulatory questions, saving valuable time and effort when responding to high priority situations. Trinity has also assisted us in the permitting process, allowing us to reduce cumbersome recordkeeping and reporting tasks and save money associated with application fees."
Levi F. Poe, Associate Environmental Specialist, Sunoco Logistics LP
Regulatory Round Up
- On July 8, 2005, EPA published a proposed rule update to Oil and Natural Gas Production Facilities MACT (40 CFR Part 63 Subpart HH). This proposed rule affects triethylene glycol (TEG) dehydrators at area sources. Area sources have potential emissions of less than 10 tons per year (TPY) of a single hazardous air pollutant (HAP) or emissions of less than 25 TPY of aggregate HAPs. TEG dehydrator units that process less than 3 MMSCFD or emit less than 1 TPY of benzene are not affected by the rule. In the proposed rule, EPA is considering the following two options. 1) Require all affected TEG dehydrator units be subject to the rule. 2) Require only TEG dehydrator units located in urban areas be subject to the rule (urban status based on the U.S. Census Bureau's most current decennial census data). The proposed rule would require a 95% reduction in HAP emissions from the dehydrator vents and implementation of the corresponding NESHAP requirements, including a start-up, shutdown, and malfunction (SSM) plan.
- In August 2004, EPA published an update to the final rule that extended the deadlines by which facilities must amend their Spill Prevention Control and Countermeasures (SPCC) plans. As a result, facility owners/operators in operation prior to August 16, 2002 must amend their SPCC plans by February 17, 2006 and fully implement their plans to conform with the newly promulgated requirements no later than August 18, 2006. Facilities that commenced operation after August 16, 2002 should currently be complying with the updated rules. An SPCC plan is required for total above ground storage of greater than 1,320 gallons or 42,000 gallons of under ground storage.
- In April 2003, EPA published a final rule that extended the deadlines by which facilities must amend their Spill Prevention Control and Countermeasures (SPCC) plans. As a result, facility owners/operators must amend their SPCC plans by August 17, 2004, and fully implement their plans to conform with the newly promulgated requirements of 40 CFR Part 112 no later than February 18, 2005. An SPCC plan is required for above ground storage of greater than
- The MACT standard for Organic Liquid Distribution (OLD), was published in the Federal Register in April 2002, and finalized in August 2003. Existing sources must comply within three years of the effective date of the rule. Organic liquids are all crude oils other than black oil and liquids (except gasoline) that contain more than five percent by weight of a hazardous air pollutant (HAP). Facilities that transfer less than 7.29 million gallons per year are not subject to the proposed standards. Organic liquid distribution systems that are subject to regulation under other MACT subparts (e.g., Hazardous Organic NESHAP) are not subject to the OLD MACT.
Project Profiles:
- For a national oil and gas company, Trinity completed a CALPUFF screening analysis to evaluate the visibility impact on a nearby Class I area created by emissions of NOx and SO2 from a proposed project. The maximum extinction change was determined to be below the threshold value of five percent, indicating that the impact to visibility would be acceptable to the regulatory agencies.
- Trinity provided a variety of environmental consulting services for an oil and gas company, including Acid Rain Program assistance, Title V Annual Compliance Certification, NSPS Subpart GG monitoring and reporting, and MACT "Hammer" Part I application (for combustion turbine units). As a result, the organization met its permitting requirements and learned to better manage its environmental compliance efforts.
- An international oil and gas company proposed to install a new amine unit at one of its facilities. Trinity worked with the facility to quickly and efficiently prepare and submit the permit application to the state regulatory agency. The project included identification and quantification of all associated emissions increases in order to document PSD non-applicability, along with an examination of regulatory applicability for NSPS Subparts GGG and QQQ. The agency issued the construction permit within the time frame allowed by the company’s proposed schedule.
- Trinity provided a variety of environmental consulting services for a Texas greenfield natural gas processing plant, including construction storm water permitting, NPDES permitting, SPCC plan development, emission source construction permitting, and Title V permitting.
- Trinity has prepared several Offshore and Costal Dispersion Modeling (OCD) analyses for Gulf of Mexico Exploration and Production (E&P) facilities, including drilling and production platforms. The U.S. Minerals Management Service environmental programs, as defined in 30 CFR Part 250 Subpart C (Pollution prevention for Oil and Gas operation in the outer continental shelf), require an analysis of potential air emissions from offshore E&P operations. If potential air emissions from these operation exceed U.S. MMS defined allowable rates, the U.S. MMS will request OCD Modeling analysis to show compliance with costal ambient air quality standards. Trinity has consistently provided quick OCD project turn around times, which is essential for time sensitive offshore projects.
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