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Sand is used in hydraulic fracturing operations (commonly known as "fracking") associated with oil and gas exploration and production operations. With the increase in demand for fracking sand (or frac sand), there is a significant increase in frac sand processing operations, especially in the Permian Basin. Frac sand processing operations typically include sand mining, sizing, drying, screening and loading operations, which result in air emissions that require authorization from the Texas Commission on Environmental Quality (TCEQ). Depending on the specific operations, such as the process rate, sand characteristics (e.g., moisture content, silt content, etc.), sand dryer size, and drying mechanisms, these operations may be permitted via Permits by Rule (PBRs) or Case-by-Case New Source Review (NSR) permits.

Since the permitting timelines and procedures vary significantly between PBRs and NSR permits, evaluating the most appropriate permitting option through conducting a fatal flaw analysis is a key element of the permitting strategy. Trinity has assisted several clients in conducting fatal flaw analyses of frac sand processing operations, including quantification of emissions, compliance with applicable PBR requirements and emission limits, potential concerns with obtaining a NSR permit, and evaluation of strategies to meet the applicable requirements for a simpler permitting option (i.e., a PBR) in order to prepare and submit the appropriate PBR registration or NSR permit application.

Please contact the Dallas Office at (972) 661-8100, if you would like to obtain more details on the permitting options and procedures for the sand processing plants in Texas.