LDEQ Air Permitting: SOGA to MSOG Permits - Monday, August 20, 2012
August 20, 2012
LDEQ Air Permitting: SOGA to MSOG Permits
The Louisiana Department of Environmental Quality (LDEQ) is implementing a procedure to convert existing Standard Oil & Gas Air Permits (SOGA) into Minor Source Oil & Gas General Permits (MSOG) as part of phasing out SOGA permits. The MSOG was developed to offer oil and gas production sites the flexibility needed for site operations, as is provided by SOGA permits, while addressing the expanded applicability to oil and gas operations of Federal Air Quality Standards such as NSPS Subparts IIII and JJJJ, and NESHAP Subpart ZZZZ.
The general process is for the Agency to request sites operating under a SOGA permit to apply for a MSOG permit through submittal of a General Permit Applicability Questionnaire – Crude Oil and Natural Gas Production. A site can also request a standard minor source permit through submittal of a complete application. SOGA permits will become less likely to be applicable to oil and gas production sites as time goes by; therefore, the LDEQ has noted it is in your best interest to obtain a MSOG or Minor Source Permit for sites currently operating under a SOGA Permit even if not directly requested by the Agency.