See the latest EHS federal and state regulatory updates due to COVID-19

On April 24, 2020, the Texas Commission on Environmental Quality (TCEQ) released draft updates to Oil and Gas General Operating Permit (GOP) Nos. 511, 512, 513, and 514. GOPs provide a streamlined Title V application and permit process for sites that have similar operations, equipment, and applicable state and federal equipment. The four Oil and Gas GOPs apply to facilities according to the county in which the operations are located.

After the revisions to the GOPS are finalized, current permit holders will be required to submit a revision application for a new authorization to operate (ATO) if any of the emission units, applicability determinations, or the bases for the applicability determinations are affected by the revisions in the renewed GOPs.

The list below summarizes the proposed revisions that may affect current or potential permit operators:

  • Permitting tables are proposed to be added for each of the revised draft Oil and Gas GOPs.
    • The majority of these tables are related to New Source Performance Standards (NSPS) Subparts OOOO and OOOOa and include applicable requirements for affected facilities, including storage vessels, gas sweetening units, fugitive emissions, and well sites.
    • Process heaters and boilers subject to Maximum Available Control Technology (MACT) Subpart DDDDD applicable requirements tables are proposed to be separated, resulting in the creation of a new table specific to process heaters.
    • Additionally, applicable requirements tables for surface coating processes subject to Title 30 of the Texas Administrative Code (30 TAC) Chapter 115, Subchapter E are proposed to be added to GOP Nos. 511 and 512.
  • Existing permit tables are proposed to be revised for consistency with the TCEQ Decision Support System.
    • These changes are primarily administrative in nature.
    • Sites operating under an existing index number may need to update their applications if applicability determinations have changed.
  • A new periodic monitoring option (PMG-OG-PM-001) is proposed for acid gas only flares subject to the opacity emission limits in 30 TAC Chapter 111, Subchapter A, Division 1 (Visible Emissions).
    • This periodic monitoring option requires quarterly visible emissions observations.
    • If visible emissions are observed, either a deviation must be reported or the opacity must be measured using U.S. Environmental Protection Agency (EPA) Test Method 9.
  • Permit term 514(b)(15), concerning surface coating operations, is proposed to be removed from GOP No. 514, as the condition does not apply to the counties regulated by GOP No. 514.
  • Conditions related to bakery ovens are proposed to be removed, as bakery ovens are not at oil and gas sites.

A public hearing for the draft GOPs is scheduled to be held in the Austin TCEQ office on May 26, 2020, at 10:00am Though open discussion will not occur during the hearing, a TCEQ representative will be available to discuss the draft GOPs both 30 minutes prior to and immediately following the hearing. Note that due to the COVID-19 pandemic, the public will not be allowed to attend in person but may participate via telephone. Register to attend the hearing via telephone on the TCEQ website.

Comments may also be mailed or emailed to Ms. Sherry Davis, TCEQ Air Permits Division. Comments must be received by 5:00pm on May 27, 2020.

For more information on how these changes may affect your existing GOPs or an upcoming GOP application, please contact us at 800.229.6655 or find your local Texas office.