Modified General Permit for Oil and Gas Facilities and Oil & Gas Applications
On September 20, 2023, Oklahoma Department of Environmental Quality (DEQ) issued updates to the General Permit for the Oil and Gas Facilities (GP-OGF). Many of these updates were made due to comments regarding the revised GP-OGF that went into effect July 1, 2022. The 2023 draft received no comments during public review; therefore the modification was finalized and published on the website on December 1, 2023. The modified GP-OGF went into effect starting December 1, 2023. Any NOI applications submitted after that date and all authorizations to operate issued after that date will be authorized under the modified permit. All existing facilities currently authorized under the 2022 GP-OGF will automatically be authorized under the 2023 modified GP-OGF.
Updates to the GP-OGF include:
- Changes to Appendix A (Requirements for Control Devices):
- NSCR/Oxidation Catalyst maximum allowed control efficiency was removed.
- Removed requirement for NSCR/Oxidation Catalyst to document the O2 concentration.
- Updated requirements for Glycol Dehydration Units and Amine Units.
- Updated flares or enclosed combustion devices requirements section.
- Clarify that only one amine unit can be present to meet the GP modeling criteria for H2S.
- Language in Part 1, Section III.C.1 of the permit was modified to reflect that fuel-burning equipment firing low sulfur diesel is not prohibited by the GP-OGF.
The GP-OGF application was updated accordingly and must be used for all applications on or after January 1, 2024.
The individual minor source oil and gas application was also updated and must be used for all applications on or after January 1, 2024.
Modified Applications for “Affected Facilities” or “Affected Units”
DEQ has updated applications, as needed, to indicate that all “affected facilities” or “affected units” subject to requirements under 40 CFR Part 60 (NSPS) and Part 63 (NESHAP) should be included in the application, with exception of pneumatic controller affected facilities subject to NSPS OOOO/OOOOa. Non-applicability for potentially applicable subparts should be addressed as well. Revised application forms should be used for any applications submitted on or after January 1, 2024.
Keep an eye on DEQ’s website for the updated forms. If you have any questions about how these changes will affect your operations, or if you need assistance switching over to the new GP-OGF, please contact Trinity’s Tulsa Office at 918.622.7111 or email Kensi Jackson.
