Compliance & Assurance Project

Compliance & Assurance Services for Confidential Client

Permian and Eagle Ford Basins

Solution Overview

Client:

Confidential Client

Business Challenge:

The client needed to gather operational data for their equipment needs from over 300 sites.

Solution:

Apex gathered operational data from over the sites, evaluated the regulatory applicability for each equipment, and generated compliance reports. We also assisted with air permitting and compliance needs in the Permian Basin.

Results:

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

Challenge

With the release of the New Source Performance Standards (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.

Solution

Apex 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 the 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, calculating sitewide emissions, identifying the permitting mechanism under the Texas Commission on Environmental Quality’s (TCEQ’s) New Source Review Program, conducting National Ambient Air Quality Standard (NAAQS) impacts assessment using SCREEN3 modeling, preparing air permitting packages, and addressing 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.

Results

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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