Compliance & Assurance Project

Compliance and Assurance Services

Confidential Client Permian and Eagle Ford Basins

Solution Overview


Confidential client

Business Challenge:

  • Our client needed to gather and track data from over 300 sites for New Source Performance Standards (NSPS) OOOO and OOOOa reporting


  • Gathered operational data from over 300 sites
  • Evaluated regulatory applicability for each piece of equipment
  • Generated compliance reports
  • Assisted with air permitting and compliance needs in the Permian Basin


  • Apex continues to provide regulatory updates and address the client’s air permitting and compliance needs


With the release of the NSPS OOOOa for oil and natural gas facilities in 2016, our client needed to gather operational data for their equipment needs including well completion, compressors, pneumatic devices, storage tanks, control devices, and fugitive leak detection surveys from over 300 sites including tank battery, compressor station, salt water disposal, and produced water recycling facilities. To track the data, they requested a single spreadsheet for reporting the facilities subject to NSPS OOOO as well as NSPS OOOOa regulations.


Apex Companies developed an Excel-based tracking spreadsheet. We gathered operational data from over the sites, evaluated the regulatory applicability for each equipment, and generated compliance reports. We worked diligently to identify the subtle differences between NSPS OOOO and NSPS OOOOa regulations to ensure reporting accuracy.

Impressed with our quality of work, attention to detail, and in-depth understanding of state and federal regulations, our client asked us to assist with their air permitting and compliance needs in the Permian Basin.

We provided specific air permitting services including process modeling using ProMax, calculated sitewide emissions, identified the permitting mechanism under the Texas Commission on Environmental Quality’s (TCEQ’s) New Source Review Program, conducted National Ambient Air Quality Standard (NAAQS) impacts assessment using SCREEN3 modeling, prepared air permitting packages, and addressed TCEQ’s follow-up questions. TCEQ’s air permitting mechanisms primarily used for permitting these facilities include permit by rule (PBR) and standard permit (SP) for oil and gas facilities.

Additionally, we helped our client develop a detailed equipment fugitive count by coordinating the data collection with their engineering and field teams. Over the last couple years, the client has started relying on Apex’s team for preparing air permit applications for their produced water treatment and recycling plants in addition to their typical tank battery and salt water disposal facilities.


The Apex air team is consistently praised by the client for our response time and attention to detail as they continue to rely on us to provide regulatory updates and address their air permitting and compliance needs in the Permian Basin.

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