UPDATE
The revised GP-OGF is no longer available for public comment. DEQ is working on revising the proposed updates for 12-month recordkeeping.
On April 1, 2025, the Oklahoma Department of Environmental Quality (DEQ) proposed a revised permit and memorandum for the General Permit for Oil & Gas Facilities (GP-OGF) to be called 2022 GP-OGF Version 3. The revisions impact 12-month rolling emissions recordkeeping requirements, address Legally and Practically Enforceable (LPE) limits for facilities affected by NSPS OOOOb, and miscellaneous changes for emergency engines, glycol dehydration units, NSPS Kc, NSPS OOOOb, as well as clarifications for various terms.
12-Month Rolling Emissions Recordkeeping
Starting January 1, 2026, all facilities permitted under the GP-OGF must perform actual facility emissions calculations on a 12-month rolling basis in accordance with Part 2, Section I.E of the GP-OGF to demonstrate compliance with the 12-month rolling total emission limits listed in Part 2, Section I.B. Version 2. Actual emissions must be calculated and documented on a monthly basis for storage tanks, blowdowns, combustion equipment, fugitives, maintenance, startup, and shutdown (MSS), and other non-de minimis sources. De minimis sources, as defined in Appendix H of OAC 252:100, may be estimated as 5 tpy per defined activity or emission unit if specific monitoring is not in place for those sources. If representative gas and liquid analyses are used in lieu of facility-specific data, the analyses must meet the criteria listed in DEQ’s
Representative Sampling Guidance document.
NSPS OOOOb and LPE Limits for Storage Tank Vessel-Affected Facilities
The revised GP-OGF now addresses NSPS OOOOb-affected facilities and applicable recordkeeping requirements. Applicants whose storage tank vessel-affected facilities are potentially subject to NSPS OOOOb may elect to comply with the LPE limits listed in Part 2, Section II.D by using an unassisted flare, an unassisted enclosed combustion device, or a vapor recovery unit. If using an unassisted flare or an unassisted enclosed combustion device, the applicant must ensure that the closed vent system is sufficiently designed to ensure all gases, vapors, and fumes from the storage vessels are routed to the control device, the combustion destruction efficiency is at least 95%, and the device meets the requirements in Appendix A, Section F of the GP-OGF. If using a vapor recovery unit, the applicant must ensure that the closed vent system is sufficiently designed to ensure all gases, vapors, and fumes from the storage vessels are routed to the control device, and the openings of the storage vessels are closed and sealed during normal operation. Any downtime must be recorded in rolling emissions calculations for demonstrating compliance with the LPE limits.
Miscellaneous Changes and Clarifications
The following changes and clarifications were also made in the proposed 2022 GP-OGF Version 3:
- Facilities using emergency diesel engines equipped with Selective Catalytic Reduction (SCR) or Selective Non-Catalytic Reduction (SNCR) for the purposes of reducing emissions in accordance with 40 CFR Part 1039 or Tier 4 standards are no longer excluded from being permitted under the GP-OGF. Note that facilities using non-emergency engines equipped with SCR or SNCR technology are not eligible for coverage under the GP-OGF.
- “Annual” has been replaced by “calendar year” for various requirements to clarify that compliance is dependent upon a calendar year basis. Additionally, facilities that are covered by the GP-OGF after July 1 may demonstrate compliance with applicable monitoring, recordkeeping, or reporting requirements starting with the next calendar year except for equipment subject to engine testing requirements as prescribed in Part 2, Section IV.E. of the GP-OGF.
- Various Chapter 37 applicability language has been clarified. Part 2, Section I.M. clarifies exemptions for crude oil, condensate, and methanol stored, processed, treated, loaded, and/or transferred at a drilling or production facility prior to custody transfer. Part 2, Section I.N. describes requirements for vapor-loss control devices and mechanical seals. Part 2, Section III.C. clarifies exemptions for loading operations at natural gas compressor stations such as gathering, boosting, and transmission compressor stations.
- Emissions calculations for glycol dehydration units must use, at a minimum, 100℉ for the condenser. The monitoring requirements for condenser outlet temperatures have been removed.
- Appendix A of the GP-OGF has been revised to clarify collection efficiency versus combustion efficiency for use in determining allowable values.
- NSPS Kc requirements have been incorporated into the GP-OGF for applicable equipment.
What’s Next?
The proposed revised GP-OGF (2022 GP-OGF Version 3) is available for public comment starting April 4, 2025, and ending May 5, 2025.
Click here to view and submit comments on the revised GP-OGF permit and memorandum. Similar to the Minor Oil and Natural Gas Facilities PBR July 2024 update, we expect to see revised GP-OGF application forms to address NSPS OOOOb applicability and LPE limits if the revisions proposed in Version 3 are approved.
If you have any questions or need assistance with the proposed revisions, please contact Trinity’s
Oklahoma office or call
918.622.7111.
