The upstream oil and gas sector presents unique air permitting challenges due to its dynamic operations and constantly evolving regulatory landscape. In Texas, most upstream sites and some midstream sites rely on Permit by Rule (PBR) or Standard Permit (SP) registrations as their primary air authorization mechanisms. Successfully navigating these options requires a clear understanding of each permit’s data requirements and the common hurdles that operators face. Drawing on decades of experience supporting upstream clients, Trinity’s experts have identified five key considerations for effectively permitting oil and gas operations in Texas.
1. Process Data and Recordkeeping
Accurate and comprehensive process data is one of the most critical (and often underestimated) aspects of upstream and midstream air permitting. Emissions calculations frequently rely on modeling tools such as BR&E’s ProMax or GRI-GLYCalc, which require detailed inputs like throughput rates, operating pressures and temperatures, and process stream compositions. Maintenance, Startup, and Shutdown (MSS) emissions calculations may also depend on parameters such as event duration, volume, and equipment-specific conditions. While estimates can be used, they are often overly conservative in the absence of reliable data, potentially complicating the permitting process. Robust recordkeeping not only improves accuracy but also enables operators to leverage data from similar company-owned sites to refine emissions estimates for new or modified facilities.
Trinity’s team understands what data is needed to streamline emissions calculations and minimize permitting delays. Our Digital Solutions experts also assist clients in building scalable data and asset management systems, empowering upstream and midstream operators to efficiently collect, store, and apply site-specific data where it matters most.
2. Permitting Timelines
Keeping up with permitting timelines can be difficult in a fast-moving and asset-intensive industry. PBRs and SPs each carry different timing requirements that dictate when construction or operation may begin. For instance, under 30 TAC 106.352(a)–(k), a facility may begin operating with a simple construction notification but must submit their registration within 180 days (Level 1) or 90 days (Level 2) of startup. In contrast, facilities authorized under 106.352(l) must register before operation begins, though operators may also leverage PBR 106.353 for additional flexibility during early design phases. Standard Permits come with their own timelines dependent on the type of Oil and Gas Standard Permit selected. The 30 TAC 116.620 SP requires TCEQ approval prior to construction which may take up to 45 days, while the None-Rule SP requires a construction notification followed by a registration following start of operations.
Trinity helps clients stay on track by identifying applicable permit timelines early, aligning internal startup goals with regulatory deadlines, and ensuring timely, compliant submittals to avoid costly delays or enforcement risk.
3. Keeping Up with the Regulations
Understanding how state and federal regulations apply to your site is a critical, but often overlooked, part of the air permitting process. These compliance obligations are typically separate from the permit itself and may be referenced only briefly. For example, the TCEQ’s Oil and Gas Non-Rule Standard Permit (NRSP) cites state requirements in 30 TAC §§116.610–116.615 without further detail. Federally, sites must comply with applicable portions of 40 CFR Parts 60, 61, and 63, covering NSPS, NESHAP, and MACT standards. Determining which rules apply, and staying current as they evolve, is the responsibility of the owner/operator. These regulations impact not just permitting, but ongoing compliance once a site is operational. The recent adoption, reconsideration, and changes to NSPS OOOOb highlight just how quickly the regulatory landscape can shift.
Trinity helps clients confidently manage both state and federal requirements by identifying applicable rules early, monitoring regulatory changes, and supporting compliance throughout the facility lifecycle.
4. Air Dispersion Modeling
All oil and gas sites must comply with National Ambient Air Quality Standards (NAAQS), regardless of permit type, even if a formal modeling demonstration isn’t required. Common constituents of concern include hydrogen sulfide (H₂S), benzene, nitrogen dioxide, and sulfur dioxide. In particular, H2S can present modeling challenges at sites processing sour gas (≥ 24 ppmv H2S). Understanding process streams early allows for targeted emission control strategies that can reduce hourly emissions and, in many cases, help avoid the need for sitewide air dispersion modeling. Still, refined modeling may be necessary even with controls in place.
We help clients assess emission sources, recommend practical capture and control measures, and determine when modeling is necessary, minimizing permitting delays while ensuring NAAQS compliance.
5. Advancements in Equipment Technology
Staying current with evolving oil and gas technologies and how those technologies function in the field is essential for ensuring compliance with TCEQ expectations. Not all control or capture techniques perform in the way intended. For instance, redundancy is a great way to eliminate downtime for a vapor recovery unit. However, some operators that have implemented redundant recovery systems continue to experience routine instances where both VRUs are down while production operations continue. This prompted those operators to install supplemental control devices to ensure control in all scenarios. Similarly, the efficiency of various control techniques around glycol dehydration units has come under scrutiny, leading to a shift toward more robust solutions.
Trinity works with clients to evaluate the real-world performance of emission control technologies, incorporate regulatory expectations, and implement forward-looking solutions that help maintain compliance and avoid costly retrofits.
While this article highlights five key considerations, upstream and midstream oil and gas air permitting involves many additional nuances. Trinity brings decades of experience supporting clients across the full facility lifecycle: from initial site planning and permitting through ongoing compliance and reporting.
We’re here to help you stay ahead of regulatory requirements and keep your operations running smoothly.
If you have questions or need guidance on how Trinity can support your air permitting or compliance strategy, please don’t hesitate to contact one of our Oil & Gas experts below.
Katie Jeziorski – Managing Consultant, O&G Business Development Manager – Dallas, TX
Jared Murdock, P.E. – Managing Consultant, O&G Subject Matter Expert – Austin, TX
