The Texas Commission on Environmental Quality (TCEQ) has completed the five-year renewal of the four Oil and Gas General Operating Permits (GOP 511, 512, 513, and 514) under 30 TAC Chapter 122, Subchapter F, effective October 15, 2025. These GOPs cover oil and gas operations statewide and include facilities under SIC codes 1311 (Crude Petroleum), 1321 (Natural Gas Liquids), 4922 (Natural Gas Transmission), and 4923 (Natural Gas Distribution).

The renewed permits incorporate several important updates aimed at improving clarity, aligning with current state and federal requirements, and correcting outdated citations. Key revisions include:

• Integration of recent federal and state rule changes, including updates to 40 CFR Part 60 and 63 subparts applicable to oil and gas operations.
• Revisions to the Periodic Monitoring and Requirements Tables to ensure consistency with current regulatory language and applicable MACT, NSPS, and NESHAP standards. In this renewal, periodic monitoring changes only impact cold solvent cleaners.
• Corrections to citation and administrative language to improve readability and compliance tracking across all GOPs.
• Region-specific revisions, such as additional ozone-related updates for Bexar County (GOP 513) and enhanced VOC/HAP control requirements for nonattainment areas under GOP 511 (including the Houston-Galveston-Brazoria and Dallas-Fort Worth regions).

What Facilities Need to Do

All current GOP holders should evaluate if this renewal requires a revision to the site’s GOP permit. If so, the permit holder should apply for a new Authorization to Operate (ATO) by means of a GOP revision application under the renewed permit by January 12, 2026. If none of the site’s emission units, applicability determinations, or basis for the applicability determinations are affected by the revisions in the renewed GOPs, then no action is required. This renewal process presents an opportunity to confirm that your permit information and applicability determinations remain accurate.

Trinity recommends that facilities:

1. Review the Statement of Basis for the applicable GOP (511–514) to identify specific regulatory changes affecting emission units at your site.
2. Confirm emission unit applicability and verify that your operations remain appropriately covered under the renewed GOP.
3. Evaluate new Periodic Monitoring and Requirements Tables to ensure monitoring, recordkeeping, and reporting procedures align with the revised conditions.
4. Update internal compliance tools and permit-tracking systems to reflect new rule references and administrative changes.
5. Prepare and submit the updated ATO before the January 12, 2026 deadline to maintain continuous authorization.

TCEQ’s updates are designed to streamline administrative consistency and ensure all GOPs incorporate the latest federal and state standards. For many oil and gas facilities, this renewal cycle will not only involve a revision application but also a review of compliance documentation and internal systems to confirm alignment with the new requirements. Note that the Statement of Basis for each GOP contains the detailed changes. Notably, 40 CFR Part 60, NSPS OOOOb is not included in the permit tables of this renewal as the rule is being reconsidered. Changes are noted for NSPS OOOO and OOOOa in the Statements of Basis.

If you have questions about how the renewed GOPs affect your operations or need assistance with ATO submittals, please contact your local Trinity Consultants Texas office.