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Oil and Gas MSS Permitting The NSR Perspective. Jeff Greif Air Permits Division Texas Commission on Environmental Quality Oil and Gas Facilities Workshop 2013. My Game Plan. Enhance Understanding of MSS Permitting Permitting options What is and is not planned MSS Highlight some grey areas

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Oil and gas mss permitting the nsr perspective

Oil and Gas MSS PermittingThe NSR Perspective

Jeff Greif

Air Permits Division

Texas Commission on Environmental Quality

Oil and Gas Facilities Workshop 2013


My game plan
My Game Plan

  • Enhance Understanding of MSS Permitting

    • Permitting options

    • What is and is not planned MSS

    • Highlight some grey areas

  • Clarify Expectations for an NSR O&G MSS Permit

    • Approach

    • Federal issues

    • BACT

    • Impacts


O g mss permit options
O&G MSS Permit Options

  • Permit by rule (PBR)

  • Std. Permit

  • NSR


Multiple permits one site
Multiple Permits, One Site

Site--

  • Normal

    • Facility 1

    • Facility 2

  • MSS

    • Activities


Mss activities
MSS Activities

  • Inside the Pipe

  • Outside the Pipe

  • Process by Process


Partial permitting and mss
Partial Permitting and MSS

  • Vessel MSS Activity

    • Depressure to flare

    • Open to atmosphere

    • Pump heel to frac tank

    • Rinse to waste water

      Keep it all together

Keep it all together


Alternate operating scenario
Alternate Operating Scenario

  • Glycol Dehydrator Needs Maintenance

  • Wet Gas


Fugitives planned mss
Fugitives & Planned MSS

  • Piping Component Leaks

    • Fugitive emissions

    • Expected

    • Accounted with normal emissions

  • Clearing That Pipe for Repair

    • Planned MSS activity emission

    • Expected

    • Accounted in MSS emissions


Upsets malfunctions
Upsets & Malfunctions

  • May be Controlled or Uncontrolled

  • Often Involve Shutdown and Startup

  • Report or Record Under Chapter 101

  • Should Not be Permitted

  • Predictable Recurring Problems - Controlled

  • The Grey Area


Nsr mss application approaches
NSR MSS Application Approaches

  • Separate Inside & Outside

    • Process fluids, clearing & cleaning fluids

    • Cleaning, blasting & painting

  • View Unit Op by Unit Op

    • Note volume, temp., press., composition (ranges)

    • How is it cleared?

    • Where does the material go in each step?


Approach continued
Approach Continued

  • Temporary Facility Accounting

    • Frac tanks, totes containers

    • Vacuum trucks

    • Piping

    • Engines

  • Control Device Accounting

    • Existing control, expand EPN if unique

    • Temporary control, a representation for each device


Permitting tools
Permitting Tools

  • PBR & SP Guidance Best Start

    • Includes calculation tools

  • NSR

    • Begin with the end in mind

      • Study the Draft MSS Model Permit

      • Study the MERA guidance


Bact for mss
BACT For MSS

  • Empty to Process

  • Depressurize and Clear to Control

    • 0.5 psia

    • 95oF

    • 10,000 ppmv

    • 10% LEL

  • Cover & Enclose

  • Control Efficiencies the Same as Normal


Mss impacts
MSS Impacts

  • Toxics

    • Benzene

    • Toluene

    • Ethylbenzene

    • Xylene

    • Mercaptans

  • NAAQS Criteria (All)

  • State Standards

    • H2S


Federal netting
Federal Netting

  • Existing but Not Permitted

  • Options

    • Call it new

    • Retrospective review


Need nsr for o g mss
Need NSR for O&G MSS?

  • Really?

Really?

Let’s Talk!

  • Let’s Talk!


Actually just call or e mail
Actually Just Call or e-mail

Jeff Greif

TCEQ Air Permits Division

Chemical Section

[email protected]

(512) 239-1534


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