The rush is on! Oil and gas operators in Texas have only a few months to comply with newly finalized Maintenance Start-up and Shutdown (MSS) emissions rules.
Under the Federal Clean Air Act, the Texas Commission on Environmental Quality (TCEQ) is required to account for emissions associated with MSS activities.
TCEQ’s latest and highly anticipated MSS emission authorization mechanism– a “Permit by Rule” or PBR- has been finalized and published, establishing a compliance deadline of January 5, 2014.
Due to the large number of potentially affected sources, and a lack of clarity on required compliance actions, many operators in Texas delayed the permitting process, awaiting the final authorization of the PBR.
Now, they must act. And given the US EPA’s recent focus on MSS associated emissions, scrutiny on operators will be rigorous.
The good news is that TCEQ’s new PBR mechanism streamlines the MSS authorization process for the majority of facilities by covering emissions from the most common operational activities. And this PBR is not required to be registered — operators must only document the emissions for record keeping purposes.
However, several important factors must be accounted for by the January 5, 2014 deadline.
Emissions thresholds – Total authorized emissions from all facilities must meet the 25 tpy VOC maximum for PBR authorizations. If exceeded, alternative authorization mechanisms must be used and approved of by TCEQ.
Proper documentation – All facilities must have on site documentation of claimed emissions in formats such as “Notes to file” or a “PBR determination” letter.
Maintenance programs – All facilities must establish programs “consistent with good air pollutions control practices” or with “manufacturer’s specifications and recommendations.” Cleaning and inspection, repair schedules, training and record keeping must all be accounted for.
To learn more about the processes and tools that operators need to demonstrate compliance,download “Authorizing Maintenance, Start-up and Shutdown (MSS) Emissions at Oil and Gas Facilities in Texas.”
With the TCEQ deadline looming, what are your biggest challenges to comply? What best practices do you already have in place? Please share your questions and comments below.