1. VOC and NO x Rules Related to the Oil and Natural Gas Industries Air Quality Division Bob Gifford Air Quality Specialist, Air Quality Division Presented to Environmental Trade Fair 2013

2. Air Quality Division Oil and Gas Rules BG May 1, 2013 Page 2 Overview Control strategies reduce ozone by limiting volatile organic compounds (VOC) and nitrogen oxides (NO x ) emissions from stationary sources. –Rules in Title 30 Texas Administrative Code –Chapters 115 (VOC) and 117 (NO x ) Rules affecting oil and gas (O&G) production and gas processing sites limit VOC and NO x emissions from: –water separators; –liquid loading; –dehydrators; –storage tanks; –gas processing equipment; –cleaning solvents; –heaters; and –engines.

3. Air Quality Division Oil and Gas Rules BG May 1, 2013 Page 3 Water Separators Control to 0.5 pounds per square inch (psia) vapor pressure or less if emissions are over 100 pounds/day Chapter 115, Subchapter B, Division 3, §115.132 Beaumont – Port Arthur (BPA) Area Dallas – Fort Worth (DFW) Area: El Paso County Houston- Galveston- Brazoria (HGB) Area

4. Air Quality Division Oil and Gas Rules BG May 1, 2013 Page 4 Liquid Loading and Transport Vessels Control by 90% or vapor balance if loading over 20,000 gallons/day Chapter 115, Subchapter C, Division 1, §115.212 BPA DFW HGB

5. Air Quality Division Oil and Gas Rules BG May 1, 2013 Page 5 Storage Tanks 90% control of crude oil and condensate tanks in HGB 95% in DFW Chapter 115, Subchapter B, Division 1, §115.112

6. Air Quality Division Oil and Gas Rules BG May 1, 2013 Page 6 Gas Dehydrators Control by 90% or to 20 parts per million by volume (ppmv) if emissions are over 100 pounds/day Chapter 115, Subchapter B, Division 2, §115.122

7. Air Quality Division Oil and Gas Rules BG May 1, 2013 Page 7 Vents at Gas Processing Plants Control by 90% or to 20 ppmv if emissions are over 100 pounds/day If not regulated by another rule in Chapter 115 Chapter 115, Subchapter B, Division 2, §115.122

8. Air Quality Division Oil and Gas Rules BG May 1, 2013 Page 8 Leak Repair at Gas Processing Plants Rules apply if over 250 components contact material over 1.0% VOC by weight Scheduled inspections: weekly to yearly Repair schedule: from one day to next shutdown depending on ability to repair while on-line Chapter 115, Subchapter D, Division 3,

9. Air Quality Division Oil and Gas Rules BG May 1, 2013 Page 9 Production, Compressor, & Gas Processing NO x Regulations Nonattainment Area Minor Sources Gas-fired boilers and heaters over 2 million British thermal units (MMBtu) per hour –0.036 lb NO x /MMBtu –§117.2010 HGB, if less than 25 tons per year (tpy) NO x Gas-fired engines rated 50 horsepower (hp) or more –0.5 to 0.7 grams NO x per horsepower-hour (g NO x /hp-hr) depending on design and install date –§117.2010 HGB –§117.2110 DFW (less than 50 tpy NO x ) Diesel engines rated 50 hp or more –2.8 to 11.0 g NO x /hp-hr depending on size, location, and install date –§117.2010 HGB, §117.2110 DFW

10. Air Quality Division Oil and Gas Rules BG May 1, 2013 Page 10 Production, Compressor, & Gas Processing NO x Regulations Nonattainment Area Major Sources Boilers and Heaters –0.020 to 0.10 lb NO x /MMBtu depending on design and location –§117.110 BPA (50 tpy NO x or more) –§117.310 HGB, and §117.410 DFW Gas-fired engines rated 50 hp or more –0.5 to 2.0 g NO x /hp-hr depending on design, size, and location –§117.310 and §117.410 Diesel engines –2.8 to 11.0 g NO x /hp-hr depending on size and location –§117.310 and §117.410

11. Air Quality Division Oil and Gas Rules BG May 1, 2013 Page 11 Statewide NO x Regulations Chapter 117, Subchapter E, Division 3 Gas-fired heaters rated 0.4 to 2 MMBtu/hr –0.037 lb NO x /MMBtu –§117.3205

12. Air Quality Division Oil and Gas Rules BG May 1, 2013 Page 12 East Texas Engines Chapter 117, Subchapter E, Division 4, § 117.3310 33 East Texas Counties

13. Air Quality Division Oil and Gas Rules BG May 1, 2013 Page 13 East Texas Engines NOx Regulations Gas-fired rich-burn engines 240 to 499 hp –1.0 g NO x /hp-hr –§117.3310 500 hp or more –0.5 g NO x /hp-hr –§117.3310

14. Air Quality Division Oil and Gas Rules BG May 1, 2013 Page 14 Storage Tank Rule Revisions to 30 Texas Administrative Code Chapter 115, Subchapter B, Division 1 New rules in the DFW area –Require controls on crude oil and condensate tanks prior to custody transfer (upstream) –Require 95% control of VOC emissions –Restrictions on floating roof tanks –Compliance date March 1, 2013

15. Air Quality Division Oil and Gas Rules BG May 1, 2013 Page 15 Crude Oil and Condensate Anticipated controls –Vapor recovery unit  Larger sources  Economical –Flare  Smaller sources  Must meet 40 Code of Federal Regulations §60.18 Many sources already controlled Testing required for controls –Efficiency demonstration –Flare design verification

16. Air Quality Division Oil and Gas Rules BG May 1, 2013 Page 16 Crude Oil and Condensate Produced water tanks –Applicability explicitly based on condensate rather than liquid throughput in the tank –Vaporizes as if all condensate –Only applies prior to custody transfer

17. Air Quality Division Oil and Gas Rules BG May 1, 2013 Page 17 Industrial Cleaning Solvents New rules in Chapter 115, Subchapter E, Division 6 Compliance required by March 1, 2013

18. Air Quality Division Oil and Gas Rules BG May 1, 2013 Page 18 Industrial Cleaning Solvents Applies to solvent cleaning operations on a property with at least 3.0 tpy of cleaning solvent VOC emissions –Does not apply to residential or janitorial cleaning –Solvent cleaning operations that are subject to or in compliance with another Chapter 115 regulation are exempt from Division 6 Control options: –0.42 pound of VOC per gallon of solution –8.0 millimeters of mercury vapor pressure –85% overall control efficiency

19. Air Quality Division Oil and Gas Rules BG May 1, 2013 Page 19 Contact Bob Gifford Bob.Gifford@tceq.texas.gov 512-239-3149