Permitting for Oil and Gas Waste Treatment and Disposal Facility

New Source Review (NSR) Permitting

Client: Confidential Client | Location: Texas 

Weaver Consultants Group’s (WCG) Air Permitting Team provided air permitting assistance to one of the largest Oil and Gas Waste Treatment and Disposal Facilities in Texas.

The facility accepts both solid and liquid exploration and production (E&P) waste from the oil and gas industry. The facility utilizes surface treatment operations and processing tanks to separate liquid and solid waste and recover oil.  After oil recovery, the separated liquids are pumped to evaporation ponds or taken to a saltwater injection well for disposal. The separated solids are disposed in landfill disposal cells. The facility also includes thermal treatment operations to thermally treat solid waste with high oil content to efficiently separate solids and hydrocarbons from the waste. The treated solids will be either directed to disposal cells or beneficially reused as road base material.  The facility’s emissions include volatile organic compounds (VOCs) and hazardous air pollutants (HAPs) from the waste treatment. Particulate and combustion emissions are also generated from additional sources at the facility.

Although most E&P waste facilities in Texas are typically authorized through a Permit by Rule (PBR), the complex operations at this facility resulted in the site requiring a case-by-case New Source Review permit to authorize air emissions.  WCG’s Air Permitting Team worked alongside TCEQ air permit reviewers to develop emission calculation methodology for these types of facilities, which had not been previously established. The process also included developing an extensive waste sampling plan to accurately estimate emissions from the sources at the facility. In addition, WCG conducted a detailed impact analysis by conducting refined air dispersion modeling for the entire facility using AERMOD model and completed an in-depth review of Best Available Control Technology (BACT) for the facility.  

WCG successfully negotiated permit conditions with TCEQ to increase the clarity and flexibility of permit requirements to assure compliance.  The NSR permit for the facility is anticipated to be issued by TCEQ shortly.   After years of working in conjunction with the client and TCEQ; WCG has successfully completed the air permitting process.