Environmental due diligence in permitting could save time, money

Brad Stevener, P.E., HSSE Director, USA, Oil & Gas, SNC-Lavalin

A primary driving factor in economics is speed to market, and this is especially true for the energy industry. A critical step, often overlooked in the planning phase, is the time it takes to acquire a construction permit (land use, air, etc.), a process that has become increasingly more complex with even longer review times. Since construction cannot typically begin prior to permitting, it is vital that the permitting process be properly managed. Otherwise, companies can experience construction or operational delays and, ultimately, lost revenue. At the outset, it is crucial to define emission impacts on required permitting and construct a plan to meet these standards as early in the project planning as possible.

For example, Texas has a tiered permitting system with different issuance times: immediate, 45-days and approximately 6 mos to 12 mos. These tiers are based on pollutant-specific site wide emission levels. By reducing emissions below certain thresholds, companies can greatly reduce the time it will take to obtain the air permit.

Equipment and control considerations

Engineering and operations teams can work in tandem with the environmental group when selecting equipment and controls for the facility. Communication is key: How can site-wide emissions be reduced further? Can the project use different types of equipment with fewer emissions? Could it use more efficient equipment? At what cost? These are important considerations when collaborating during the project planning phase to possibly avoid extending permitting timelines.

For example, engine selection alone can be crucial to a project's schedule. A customer was installing multiple engines at their site and trying to choose between two different engine types: rich-burn or lean-burn. After consulting with the environmental team, they selected the rich-burn engine that included the installation of a three-way catalyst in the muffler. This reduced the nitrogen oxides (NO_x) to a level lower than the lean-burn engine, which an oxidation catalyst was capable of, and that granted a quicker permitting turnaround.

Initially, the customer was unaware that one cannot add a catalyst to a lean-burn engine and reduce NO_x. An oxidation catalyst is used for lean-burn applications, but it only reduces carbon monoxide (CO) and volatile organic compounds (VOCs). By involving the environmental group up-front, the customer saved time, and of course, money, all while preserving the environment.

Expediting the process

Texas has started offering an expedited permitting route for a fee paid by the customer, depending on the type of permit. Louisiana already offers a similar process. In addition to this, it is important to work closely with the permitting agency at the outset of your project to avoid potential delays. Things to consider:

• Extended plans for the site: Will I need more engines a year down the road and should I permit them up-front to avoid another permitting exercise in the future?
• Aggregation of nearby sources: Do I need to include emissions from equipment at a nearby site which may mean a higher emissions threshold and thus a longer permitting timeframe?
• Pre-application meetings: Do I need to meet with the agency to develop a permitting strategy early on which may help avoid a public hearing down the road?

Early investment in project development for an environmental permitting strategy can reduce unnecessary delays and preserve a client’s capital, and the integrity of the environment.

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