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Monday, September 6, 2010

TCEQ conducting a public hearing on new standard permit and permit by rule for oil and gas production facilities

After reviewing the below changes regarding TCEQ permit by rule program it seems like a step in the right direction but further changes should be required.

Some of the changes to the new rule include defining "Receptor" to include hospitals, out-patient care facilities, day-care facilities, early childhood centers, retirement homes and retirment communities. The new TCEQ rule regards receptors as residences and dwellings by definition.

The fifty-foot setback for the Oil and Gas sites from a receptor is not acceptable. The new set-backs should be changed to a minimum of 250 to 500 ft and the measurement needs to be from the receptor located on the outermost area of the Oil and Gas site and not the center.

Oil and Gas sites should be defined as the area in which all pieces of subject equipment are located. The new rule would allow "picking the center of the equipment and drawing a line 1/4 of a mile outward.
Drawing a line around the outermost equipment to define the Oil and gas site. This would "prevent creative spacing of equipment as a method of avoiding the new regulatory regime".

We would like the new permitting process not allow old Oil and Gas sites to be "grandfathered" in the new permit by rule program. This is an important issue especially when you look at some of the newer sites. It seems gas production companies have seen this change coming and are creating larger vacant areas on the new sites for future expansion.

Comments are due by October 1, 2010 and can be submitted electronically to http://www5.tceq.state.tx.us/rules/ecomments Please go to this website and follow the link to post your comments and concerns regarding the new changes proposed by the TCEQ. YOU CAN REST ASSURED OIL AND GAS ARE EXPRESSING THEIR COMMENTS AND CONCERNS. BE PROACTIVE AND BE INVOLVED THIS AFFECTS US ALL.

July 29, 2010: Air Quality Standard Permit and Permit by Rule for Oil and Gas Production Facilities

The TCEQ will conduct a public hearing on a new standard permit and permit by rule for oil and gas production facilities.

On September 14, 2010 the TCEQ will conduct a public hearing to receive comments on a proposed standard permit for oil and gas production facilities, the repeal of Title 30, Texas Administrative Code Section 116.620, Installation and/or Modification of Oil and Gas Facilities, and the concurrent modification of the Chapter 106 permit by rule, Section 106.352, Oil and Gas Production Facilities. Details of the standard permit and permit by rule and the repeal of Section 116.620.

The hearing will be held at 10:00 a.m. in Bldg. E, Room 201S at the TCEQ central office located at 12100 Park 35 Circle, Austin. This is a public meeting, and no pre-registration is required.

TCEQ seeks to accomplish the following through this standard permit development and rulemaking:

Update administrative and technical requirements
Include practically enforceable monitoring, sampling, and recordkeeping requirements
Address and authorize planned maintenance, startup, and shutdown (MSS) activities
Allow the commission to more effectively focus resources on facilities that significantly contribute air contaminants to the atmosphere
Make appropriate changes to registration and notification requirements
Ensure that air emissions from specific facilities are protective
The hearing is structured for the receipt of oral or written comments by interested persons. Individuals may present oral statements when called upon in order of registration. Open discussion will not be permitted during the hearing; however, commission staff members will be available to discuss the proposal 30 minutes prior to the hearing. Persons who have special communication or other accommodation needs who are planning to attend the hearing should contact Michael Parrish, Office of Legal Services at (512) 239-2548. Requests should be made as far in advance as possible.

Written comments may be submitted to Michael Parrish, MC 205, Office of Legal Services, Texas Commission on Environmental Quality, P.O. Box 13087, Austin, Texas 78711-3087, or faxed to (512) 239-4808. Electronic comments may be submitted at: http://www5.tceq.state.tx.us/rules/ecomments. File size restrictions may apply to comments being submitted via the eComments system. All comments should reference Rule Project Number 2010-018-106-PR. The comment period closes September 17, 2010. Copies of the proposed rulemaking can be obtained from the commission's Web site at http://www.tceq.state.tx.us/nav/rules/propose_adopt.html.

The commission is seeking comments from stakeholders on the following issues:

All common facilities at oil and gas sites traditionally using this permit by rule and standard permit so a comprehensive review can be assured
Use of various truck types and liquid loading operations at OGS, particularly information on the various operations and technical specification of vacuum trucks
Appropriate control reductions for the proposed PBR fugitive monitoring program
Proposed timeframe to paint existing, unchanged tanks under the standard permit
Proposed record parameters may already be compiled and kept in various formats for other regulatory agencies
Usage rates, chemical composition, and potential emissions of treatment chemicals used. This would include methanol injection, amines, and any others.
Potential planned MSS emissions associated with molecular sieves
The use of iron sponge units and associated iron sulfide emissions
Inorganic or organic treatment chemicals for cooling towers and when cooling towers are used at OGS
The commission proposes to not specify control requirements for planned MSS tanks and vessel degassing operations. Further information on appropriate controls based on estimated emissions and operations for degassing is needed specific to the oil and gas industry is needed. Planned MSS degassing operations will be addressed in separate rule making.
Qualitative, quantitative, and/or updated information about any planned MSS activities
Additional information on quantification for formaldehyde from engines
On April 8, 2010, TCEQ conducted a stakeholder meeting on a draft rule and standard permit for oil and gas facilities. Here is a summary of the most common comments on the draft proposals. The basis of the modeling analysis used for the proposed PBR and standard permit are modeling memo 1 and modeling memo 2, modeling data zip file 1 (og_sp_modeling_eng_fug.zip) and modeling data zip file 2 (og_sp_modeling_trans_fac3217.zip), along with the specific air contaminant analysis (.xls file) based on the commission’s modeling, and actual registrations (.xls file) used to confirm reasonable expectations of typical PBR and standard permitted facilities. To further assist understanding of the relevant limits proposed, staff has drafted a table. The commission also has provided the following hypothetical examples based on operations at a small oil and gas site (OGS) and a moderately complex oil and gas (OGS), to evaluate a site's estimated emissions against allowable emissions rates for the TCEQ Air Permits Division (APD) proposed OGS permit by rule (PBR) or standard permit authorization. In addition, the commission is considering the following standardized protocols for optional demonstrations of acceptable impacts.

Questions? We Can Help
For further information, please contact Anne Inman at 512-239-1276 or by e-mail at ainman@tceq.state.tx.us.

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