New source air permitting of Oil and gas processing equipment ranges from fairly simple procedures under the Texas Natural Resource Conservation Commission (TNRCC) standard exemption list and the New Mexico Environment Department (NMED) registration regulations to an extremely complicated procedure requiring a federal Prevention of Significant Deterioration (PSD) and/or non-attainment review. The following topics relating to obtaining air pollution construction permits for processing equipment will be addressed in this paper:

  • Type of permit/exemption/registration necessary for construction

  • Specific permit/exemption/registration requirements

  • New Source Performance Standards (NSPS) Subparts KKK, LLL, GG, K, Ka, and Kb

Concepts outlined in this paper pertain to air pollution New Source Review (NSR). Owners and operators of Oil and gas processing and production facilities that propose new or modified facilities should be aware of the regulations and interpretations contained in this paper.

The primary effects of the 1990 clean Air Act amendmentson NSR requirements are identified.

Type of Permit/Exemption Necessary for Construction

Before equipment can be installed in Texas, the requirements of the TNRCC standard exemption list must be met, or state and/or federal permitting review is required. The installation of a compressor engine, turbine, sweetening unit (with associated sulfur recovery unit or flare), or a heater/boiler will require one of the following:

  • TNRCC standard exemption

  • State (TNRCC) construction permit (Regulation VI)

  • State (TNRCC) construction permit and federal (PSD) permit

  • State (TNRCC) construction permit and federal non-attainment review

  • State (TNRCC) construction permit, federal (PSD) permit, and federal non-attainment review

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