The Texas Commission on Environmental Quality (TCEQ) formerly Texas Natural Resource Conservation Commission (TNRCC) is presently implementing new rules to permit Grandfathered facilities in Texas. This will have tremendous impacts for the oil and gas industry. Oil and gas facilities that were once exempted from New Source Review (NSR) under the Grandfathered rules will have to obtain permits and have required control equipment installed in accordance with the new regulations. This paper describes the anticipated rule requirements and discusses the impacts and compliance measures on the oil and gas industry.
Grandfathered facilities are sources of air pollution that were operating prior to the beginning of the Texas New Source Review (NSR) Permitting program. These facilities were exempted from the NSR permitting program. Generally these are facilities that were constructed prior to August 30, 1971.
Exploration and production operators may find that they have many sources of facilities that were "grandfathered." Grandfathered facilities may include compressor engines, gas treating equipment, tanks, flares, vents or other equipment that did not need to be permitted then, but does require a permit now. A good "rule of thumb" when determining if you need a permit is to decide whether, if you were installing that equipment now as a new item, if a permit would be required.