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Domestic oil and gas production has contributed to tremendous growth throughout the U.S. energy and petrochemical industries. Successful growth has been contingent upon effective environmental permitting and compliance; and this article presents some recent projects and critical environmental permitting considerations.

Sector growth is significantly higher in Texas due to the unprecedented increase in Permian Basin oil and gas production, and the opportunities to capitalize on international crude export and expanded petrochemical manufacturing along the Gulf Coast. The projects span from upstream to downstream, such as:

  • Oil and gas production, gas processing, and transmission
  • Crude transload
  • Liquid terminals (inland pipeline and coastal marine terminals)
  • Refined product terminals
  • Deepwater ports for crude export
  • Liquified Natural Gas (LNG) export terminals
  • Fractionation plants
  • Greenfield modular refineries
  • Integrated refinery optimization
  • Chemical plant expansions and construction

Successful energy sector projects employ the following tactics to assure environmental obligations do not delay construction or operation milestones:

  • Advanced permit feasibility and applicability analysis
    • A timely evaluation of project scope, potential emissions, and permit authorization options to properly define the permit authorization method (major source, minor source, expedited avenue), required tasks, and the associated timeline.
  • Complying with latest agency procedures and practices
    • Awareness of and competence with revised agency procedures for application submission, emission quantification, Best Available Control Technology (BACT), dispersion modeling, and public participation is needed.
    • Emissions quantification is becoming more of a significant issue recently with proposed AP-42 changes and a continued shift away from TANKS4.09d.
    • TCEQ, for example, has recently implemented new procedures for application submission through its integrated New Source Review (NSR) Workbook and Electronic Modeling Evaluation Workbook (EMEW). These changes require the applicant to proactively perform dispersion modeling (and resolve potential complications) well in advance of application submission.
    • Assessment of offset availability in nonattainment areas.
  • Comprehensive project scope identification, emissions quantification and dispersion modeling
    • Detailed identification and planning for broad product flexibility, material properties (volatility, sulfur content, temperature), facility throughput, and equipment design is necessary for accurate permit applicability, effective dispersion modeling, and ultimately timely permit issuance. Proper characterization of volatility has become a topic of focus recently for many state agencies with increased scrutiny on RVP representations, RVP/TVP correlations, bulk storage temperatures, and potential for flashing.
    • An important element for energy sector projects is thorough quantification and demonstration of acceptable impacts for short-term maintenance, startup, and shutdown events (e.g., storage tank roof landing and cleaning)
    • Applicants should consider generating summaries or digests of underlying emissions quantification and process simulations (ProMax, HYSYS, Gly-Calc, TankESP, etc.) to facilitate the agency's review and reduce the potential for permit issuance delays.

A variety of air permit and compliance solutions have been required for these projects. Using Texas air permitting as an example, the range of permitting and compliance solutions provided by Trinity include:

  • Expedited construction permitting
    • Permit by Rule (PBR) registrations - Trinity was the first to obtain authorization in 30 days through PBR for a modular crude oil refinery.
    • Standard Permit registrations - Trinity has authorized numerous oil and gas production, processing, transmission, tank farm, and fractionation facilities under standard permits, often receiving approval within one day to a week following registration.
    • Case-by-case NSR permits - Trinity has obtained authorization through case-by-case NSR permitting as quickly as 6 months from the time of submission.
  • Federal authorizations
    • PSD and Nonattainment NSR - Trinity has obtained numerous major source authorizations for marine terminal projects and expansions at integrated refineries and petrochemical plants.
    • Deepwater Ports (DWP) - Trinity effectively established the template for the Clean Air Act (CAA) authorizations required for the U.S. Maritime Administration (MARAD) and U.S. Coast Guard (USCG) DWP license application for crude oil export in Texas. Trinity has prepared the CAA applications for multiple crude oil export DWP licenses (including the very first application) which include Prevention of Significant Deterioration (PSD), Title V Federal Operating Permit, Maximum Achievable Control Technology (MACT) major source review, federal and state dispersion modeling, NEPA EIS air quality review, and state authorizations for associated onshore storage and transmission facilities.
    • LNG Export Terminals - Trinity has prepared the air quality environmental analyses required for multiple gulf coast LNG export terminals. These analyses are required for state permitting as well as licensing from the Federal Energy Regulatory Commission (FERC). Trinity has been at the forefront of these permitting activities for over a decade, and has the expertise to navigate unique dispersion modeling challenges involving LNG carriers.
  • Compliance audits (acquisitions and as-built review)
    • Many companies have recently expanded operations through acquisition. Performing environmental audits under privilege has provided an effective process to avoid potential compliance disruptions.
    • Audits have also been commonly employed to evaluate and resolve if necessary differences in as-built design and construction compared to original air permit representations.

Air quality permitting for energy projects requires significant advance planning to meet project objectives and timelines. Trinity can help you navigate the complicated landscape. For more information, contact us at 1-800-830-0796, email Brian Burdorf, or complete our Contact Us form on our website.