The Great Emissions Roundup: Strategies for Permitting Maintenance, Startup and Shutdown (MSS) Emissions at Upstream Oil & Gas Facilities

Abstract

Abstract Unconventional development projects follow a general life cycle. Each step in the life cycle has a number of common activities that can have important environmental and social impacts. Managing those activities to reduce/control the impacts can reduce the project’s business risks and improve the overall success of the development program. As the development activities become more production oriented, facilities will be more likely to undergo regular maintenance, and the potential for air emissions will increase accordingly. In recent years, the EPA has been working to reduce air pollution from stationary sources by closely examining the use of affirmative defense as it pertains to emission events. To this end, the Texas Commission on Environmental Quality (TCEQ) issued rules in December 2005 for permitting planned maintenance, start-up and shutdown (MSS) emissions. Upstream oil and gas sites have an MSS permitting deadline of January 5, 2014. For the refining, chemical, and utility industries, the TCEQ processed MSS permit applications for 30 refineries, 400 chemical plants, and scores of utility plants. In the coming year, more than 20,000 oil and gas sites are expected to confront this issue. The vast majority of these oil and gas sites are authorized under permit by rule or standard permit. While TCEQ has published guidance for MSS Best Available Control Technology (BACT) for refineries, the relevance of this guidance to the oil and gas industry is lacking, and additional guidance has yet to be presented. Facilities seeking to utilize existing authorization mechanisms for their identified MSS activities will have to evaluate the equivalent of BACT to meet the emission limits. Based on the implementation schedule, most companies have not yet attempted to tackle the MSS permitting issue. Early experience in this area indicates that, in order to meet current permit requirements, MSS activities at oil and gas production sites will require a combination of revised operating procedures and application of additional controls. Sites that cannot manage to a tighter set of operating parameters during MSS activities may trigger the need to convert to a new source review permit, which would require BACT. This paper will look at the permitting and emission control challenges and strategies for complying with this impending requirement using existing mechanisms.