Obtaining a Texas Commission on Environmental Quality, or TCEQ air permit by rule has always been complex. Recent TCEQ changes made it even more complex for certain types of operations to obtain authorizations. If you are involved with an oil and gas processing facility, a marine terminal, or a chemical manufacturing plant that involves flaring activities, obtaining a permit is much harder than before recent policy changes were implemented by the TCEQ. At ESE Partners, however, we have extensive experience working with the agency and we know how to help make the permitting process go as smoothly as possible.
New Constraints and Expenses
As a result of TCEQ air permit by rule changes, many companies are finding they have much less flexibility than before – and spending much more money and time. Many projects that would previously have been able to easily obtain a permit are now subject to NSR (new source review) permits. Not only are these permits more complex to obtain, they also increase the strain on TCEQ’s already limited resources. This adds yet another layer of uncertainty, raising the distinct possibility of costly delays.
The policy shift chiefly impacts emissions from new or existing flaring activities. For nearly 20 years, the TCEQ air permit by rule process routinely allowed authorization of pilot gas and waste stream emissions under PBR 106.492. But new, more stringent constraints are now in place requiring that PBR 106.492 be registered, whereas as it formerly did not require registration, and it can no longer be used to authorize emissions from the waste stream. Waste stream emissions will now have to be authorized under PBRs 106.261/106.262. ESE Partners has extensive experience authorizing emissions under PBRs 106.261/106.262.
Keeping Up With the Changes
You have enough on your plate already without having to deal with the added responsibility of staying on top of TCEQ air permit by rule policy shifts. Let ESE Partners take on that burden instead. Working with an experienced company like ESE Partners will help you navigate any policy changes that may occur, either now or in the future.
We will apply our practical understanding of the TCEQ air permit by rule to help reduce the risks associated with the application process. If you would like to speak with one of our experts, get in touch with one of our offices at your earliest convenience.
