ENV-15-6 Permitting Startup, Shutdown, and Maintenance Emissions: It’s Coming … Be Prepared!

Description:

This paper draws from the lessons learned in Texas from the implementation of these rules and provides detailed discussions on key permitting strategies used to address the complex issues that may be associated with permitting emissions from planned MSS activities. Key topics presented in this paper include Prevention of Significant Deterioration (PSD) and Nonattainment New Source Review (NNSR) evaluations for existing MSS emissions, Best Available Control Technology (BACT) negotiations and the use of best management practices rather than expensive controls, and the challenges of demonstrating compliance with the U.S.EPA’s stringent short-term National Ambient Air Quality Standards (NAAQS) for certain criteria pollutants emitted during MSS related activities. Additionally, this paper will include Texas’ approach to making MSS activity emission limits enforceable, while providing industry operational flexibility via the categorization of activity types and the use of planned MSS emission sub-caps. Finally, this paper will include a discussion on the implementation and ongoing challenges of an MSS permit compliance program.