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Oil and Gas MSS Permitting The NSR Perspective

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

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  1. Oil and Gas MSS PermittingThe NSR Perspective Jeff Greif Air Permits Division Texas Commission on Environmental Quality Oil and Gas Facilities Workshop 2013

  2. 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

  3. O&G MSS Permit Options • Permit by rule (PBR) • Std. Permit • NSR

  4. Multiple Permits, One Site Site-- • Normal • Facility 1 • Facility 2 • MSS • Activities

  5. MSS Activities • Inside the Pipe • Outside the Pipe • Process by Process

  6. 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

  7. Alternate Operating Scenario • Glycol Dehydrator Needs Maintenance • Wet Gas

  8. 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

  9. 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

  10. 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?

  11. 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

  12. 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

  13. 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

  14. MSS Impacts • Toxics • Benzene • Toluene • Ethylbenzene • Xylene • Mercaptans • NAAQS Criteria (All) • State Standards • H2S

  15. Federal Netting • Existing but Not Permitted • Options • Call it new • Retrospective review

  16. Need NSR for O&G MSS? • Really? Really? Let’s Talk! • Let’s Talk!

  17. Actually Just Call or e-mail Jeff Greif TCEQ Air Permits Division Chemical Section jeff.greif@tceq.texas.gov (512) 239-1534

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