The standard oil and gas air (SOGA) permit authorizes construction, operation, and modification of crude oil and natural gas production facilities that meet certain eligibility requirements. Permit eligibility is limited to air emissions from oil and gas facilities for which the primary Standard Industrial Classification (SIC) Code is:
· 1311 - Crude Petroleum and Natural Gas
Coverage and Eligibility
Facilities must maintain eligibility to operate under this standard permit. This permit does not authorize operations that are not compliant with the established eligibility conditions. Prior to initiating any modification to the facility that would prohibit it from being covered under this standard permit, the permittee must request an “individual” site-specific air permit. If a modification rendering the facility ineligible for this standard permit is effected without a site-specific permit in place, the modification would be deemed unauthorized from the date construction commenced and subject to enforcement action.
Facilities excluded from coverage
The SOGA permit does not authorize air emissions at:
1. Major sources as defined in LAC 33:III.502.
2. Facilities that emit or have the potential to emit criteria pollutants and/or toxic air pollutants (TAP) in amounts greater than or equal to those listed in the following table. Limits are given in tons per year (TPY).
|
Pollutant
|
Emissions
|
|
|
|
|
PM10
|
25
|
|
SO2
|
25
|
|
NOx (attainment parishes)
|
95
|
|
NOx (nonattainment parishes)
|
47.5
|
|
CO
|
95
|
|
Total VOC (attainment parishes)
|
95
|
|
Total VOC (nonattainment parishes)
|
47.5
|
|
Total TAPs (including, but not limited to the following)
|
20
|
|
|
8
|
|
|
8
|
|
|
8
|
|
|
8
|
|
|
8
|
|
|
8
|
|
|
8
|
3. Facilities subject to any federal requirements contained in 40 CFR Parts 60, 61, 63, or 64, except that facilities subject to 40 CFR 61.145, National Emission Standard for Asbestos-Standard for demolition and renovation may be covered. See LAC 33:III.501.B.3.a.
4. Facilities subject to other regulatory requirements described in Section IV-Equipment Restrictions that exclude them from coverage under this standard permit.
5. Facilities subject to LAC 33:III.Chapter 59-Chemical Accident Prevention or 40 CFR Part 68-Chemical Accident Prevention Provisions.
6. Facilities that formerly operated as major sources if Best Available Control Technology (BACT) or Lowest Achievable Emission Rate (LAER) controls were installed and are being maintained on an existing point source.
7. Facilities located in Pointe Coupee Parish with equipment subject to LAC 33:III.2115.
8. Facilities with steam generating units (e.g., boilers) and/or turbines.
Equipment Restrictions
Storage vessels eligible to be covered under a SOGA permit must not be subject to the following regulations:
· 40 CFR 60 Subpart K-Standards of Performance for Storage Vessels for Petroleum Liquids for Which Construction, Reconstruction, or Modification Commenced After June 11, 1973, and Prior to May 19, 1978;
· 40 CFR 60 Subpart Ka-Standards of Performance for Storage Vessels for Petroleum Liquids for Which Construction, Reconstruction, or Modification Commenced After May 18, 1978, and Prior to July 23, 1984;
· 40 CFR 60 Subpart Kb-Standards of Performance for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, or Modification Commenced After July 23, 1984; or
· LAC 33:III.2103.B.
Fugitive emissions eligible to be covered under a SOGA permit must not be subject to the following regulations:
· Subpart KKK-Standards of Performance for Equipment Leaks of VOC From Onshore Natural Gas Processing Plants;
· LAC 33:III.2121-Fugitive Emission Control; or
· LAC 33:III.2122-Fugitive Emission Control for Ozone Nonattainment Areas and Other Specified Areas.
Loading facilities eligible to be covered under a SOGA permit must not:
· employ a control device to restrict VOC emissions from marine loading for purposes of compliance with LAC 33:III.2108;
· load gasoline; or
· load compounds (other than crude or condensate) having a true vapor pressure at loading conditions of 1.5 psia or greater at a rate of 20,000 gallons per day or more (averaged over any 30-day period).
Natural gas sweetening units eligible to be covered under a SOGA permit must not be subject to the following regulation:
· 40 CFR 60 Subpart LLL-Standards of Performance for Onshore Natural Gas Processing: SO2 Emissions.
Modifications
Within seven (7) calendar days after effecting any modification to a facility authorized to operate under a SOGA permit (generally commencement of construction), the permittee shall submit an updated Emission Point List, Emissions Inventory Questionnaire (EIQ), emissions calculations, and certification statement as described in LAC 33:III.517.B.1 to the Air Permits Division. The cover letter for this submittal should read “Updated SOGA Application,” and include the Agency Interest No. and Activity No. found on the signature page of the issued permit.
The current application on file with LDEQ, not the limits of the SOGA permit itself, establish the potential to emit (PTE) for the facility. As such, applicable regulations are based on each facility’s PTE. Coverage under a SOGA permit does not obligate a permittee to comply with requirements that would not otherwise be applicable (simply because they are identified in the SOGA template).
Also, the current application on file with LDEQ should reflect the best available emissions data. For example, assume a compressor engine is stack tested. The results indicate that NOx emissions from the engine were underestimated by 5 TPY; however, the facility still meets the eligibility requirements of the SOGA permit. Though this may be the case, the permittee must submit an updated application to reflect the new data.