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ENV-07-117 Texas MSS Permit - A Bright Light out of a Mess

Grant Smedley and Sue Sung, Trinity Consultants

Format:
Electronic (digital download/no shipping)

Associate Member, International Member, Petrochemical Member, Refining Member, Special/Temporary Member - $0.00
Government, NonMember - $25.00

Description:

In 2006, the Texas Commission on Environmental Quality (TCEQ) promulgated a regulation requiring all petroleum refineries to submit permit applications to authorize maintenance, startup, and shutdown (MSS) activities by January 2007. This new regulatory requirement presented a significant challenge for the Texas refineries, for several reasons. Firstly, no guidance was provided by the TCEQ on available permitting mechanisms to be used to authorize MSS activities, or on how to incorporate MSS activities into existing refinery permits. Secondly, no standardized methodology was available or developed for the quantification of emissions from MSS activities. Finally, no information was provided on how refineries would be expected to demonstrate compliance with issued MSS permits in the future. To address the challenge presented by the uncertain regulatory landscape ahead, a spreadsheet tool was developed to identify, quantify, and track MSS activities and emissions in a way that is simple, flexible, and comprehensive. The inherent flexibility of the tool facilitates future changes in emission calculation methodologies, permitting mechanisms, and compliance strategies. Such changes will inevitably be required as the TCEQ continues to review MSS permit applications. The MSS tracking tool also provides a simple interim method for performing compliance demonstrations for MSS activities and emissions.

Product Details:

Product ID: ENV-07-117
Publication Year: 2007