Transcript Oil and Gas MSS PermittingThe 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
• Clarify Expectations for an NSR O&G MSS Permit
– Approach
– Federal issues
– BACT
– Impacts
O&G MSS Permit Options
PBR
Std. Permit
NSR
Multiple Permits, One Site
Site
Normal
Facility 1
Facility 2
MSS
Activities
MSS Activities
• Inside the Pipe
• Outside the Pipe
• Process by Process
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
Alternate Operating Scenario
• Glycol Dehydrator Needs Maintenance
• Wet Gas
Sales Gas
Dehydrator
Emission
Wet Gas
Flare
Emission
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
•
•
•
•
May be Controlled or Uncontrolled
Often Involve Shutdown and Startup
Report or Record Under Chapter 101
Should Not be Permitted
• Predictable Recurring Problems - Controlled
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
• 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
• 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
• 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
• Toxics
– Benzene
– Toluene
– Ethylbenzene
– Xylene
– Mercaptans
• NAAQS Criteria (All)
• State Standards
– H2S
Federal Netting
• Existing but Not Permitted
• Options
– Call it new
– Retrospective review
Need NSR for O&G MSS?
Actually Just Call or e-mail
Jeff Greif
TCEQ Air Permits Division
Chemical Section
[email protected]
(512) 239-1534