The TCEQ has proposed revisions to the Permit by Rule (PBR) and Standard Permit New Source Review (NSR) Authorization mechanisms for oil & gas operations. Driven largely by the increased public scrutiny of the natural gas exploration and production activity taking place in the Barnett Shale, the proposed revisions to PBR 352 and the associated Standard Permit greatly increase the registration, reporting, and control technology requirements for oil & gas operators from the wellhead through transmission. Under the current PBR, oil & gas sources can be authorized to install and operate equipment without the installation of emission controls as long as emissions of volatile organic compounds (VOCs) and other criteria pollutants do not exceed given levels. Currently, registration with the TCEQ is only required if engines or turbines will also be installed at the site. Under the proposed PBR, all O&G sites seeking authorization under the PBR must register with the TCEQ. For many sources, registration is allowed to take place up to 180 days following installation and operation; however, for many others, registration must occur prior to commencing construction and operation. In addition, sources may be required to implement Best Management Practices or install controls to ensure off-property impacts are managed. Other requirements include site-specific emission calculations, record keeping, and air dispersion modeling to demonstrate compliance with the National Ambient Air Quality Standards. The impact on industry includes longer lead times to install equipment, additional site-specific gas and liquids sampling, increased record keeping burden, and additional capital expenditures for emissions control.
The comment period for the proposed rule is currently underway and ends on September 17, 2010. A public hearing is scheduled in Austin for September 14, 2010. Trinity is offering luncheons throughout the state to present the proposed PBR requirements and registration procedures in detail. Please click here for cities, dates, and a link to register for the lunch seminar.