ERM Seminar: TCEQ’s New Permit by Rule and Standard Permit

23 March 2011

What Now?!?! Compliance Challenges for Upstream Oil and Gas

On Wednesday, January 28, TCEQ adopted complex new rules that significantly revise the existing permit by rule and standard permit authorization mechanisms for oil and gas handling and production facilities in Texas. These rules will apply to new or modified facilities starting on April 1, 2011 in Barnett Shale counties and to all other new or modified facilities in the State of Texas on January 5, 2012. The TCEQ is currently seeking additional feedback from the regulated industry, and based upon that feed back, will potentially revise and reissue the rule in late 2011.  Companies with assets in the Barnett Shale and other areas of Texas need to understand the scope and requirements of these new rules, from equipment and control requirements to emission limits based on impacts evaluation. 

There are also Best Management Practices for PBRs and Best Available Control Technology (BACT) requirements for Standard Permits.  For facilities outside of Barnett Shale, it is not too late to impact the language in the Standard Permit and PBR.  Existing crude oil and natural gas production facilities (in Barnett Shale and other parts of Texas) must also act to authorize their planned maintenance, startup, and shutdown (MSS) emissions in accordance with these new provisions by January 5, 2012.  If the agency revises the newly issued Standard Permit and PBR, it plans to issue the revision in November or December of 2011.  With the MSS deadline of January 5, 2012 that does not provide companies much time to prepare MSS applications.

ERM is offering a Free Lunch Seminar on the new PBR and Standard Permit rules. ERM air quality experts will provide an overview of the new rules and walk through strategies companies can undertake to prepare their existing sites and non-Barnett Shale sites for the authorizing MSS emissions by January 2012.  We will use case studies of hypothetical facilities to illustrate new permitting considerations to evaluate and authorize new upstream handling and production sites and demonstrate effective ways to achieve compliance and manage risks under this new and evolving regulatory environment. 

Time:11:00AM - 1:30PM

Key Speakers

Deever Bradley, PE - Partner with ERM
Jill Hartman, PE - Partner with ERM

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