1. § Planned Maintenance, Startup, and Shutdown (MSS) at Oil and Gas Handling and Production Facilities.

2. Overview MSS Schedule in 30 TAC § 101.222(h) January 5, 2012
SB 1134 moved the deadline for Oil and Gas to January 5, 2014
Must meet 30 TAC § 106.4
The deadline for oil and gas sites under certain Standard Industrial Codes (SIC) was extended to January 5, 2014 by the legislature.
Historically, the rules of the commission and its predecessor agencies have not specifically required authorization of MSS activities. However, in December 2005, the commission established deadlines for different facility types to submit an application to authorize planned MSS emissions. Senate Bill (SB) 1134, 82nd Legislature, 2011, created Texas Health and Safety Code (THSC), § , which extended the deadline for certain oil and gas facilities to submit an application to authorize planned MSS from January 5, 2012 to January 5, This rulemaking will provide applicants a streamlined authorization mechanism for planned MSS to meet the statutory deadline.
One thing to remember is that this rule is still a PBR so you must still meet and the underlying PBR.
The main philosophy is to maintain the site and keep records.
The link to the rule for

3. PBR
(1) engine, compressor, turbine, and other combustion facilities maintenance;
(2) repair, adjustment, calibration, lubrication, and cleaning of site process equipment;
(3) replacement of piping components, pneumatic controllers, boiler refractories, wet and dry seals, meters, instruments, analyzers, screens, and filters;
(4) turbine or engine component swaps;
(5) piping used to bypass a facility during maintenance;
(6) planned MSS activities with the same character and quantity of emissions as those listed in paragraphs(1-5) of this subsection;
tried to capture all emissions associated with MSS at an oil and gas site. 1-6 will have very low emissions so a default VOC tpy number was created to help companies capture the emissions. We will go over the default number later in the presentation. It does not have to be used but was created as a useful tool for the public to use.

4. PBR 106.359 (7) pigging and purging of piping; (8) blowdowns;
(9) emptying, purging, degassing, or refilling of process equipment, storage tanks and vessels (except landing floating roof tanks for convenience purposes), if subparagraphs (A) - (C) of this paragraph are met.
(10) abrasive blasting, surface preparation, and surface coating of facilities and structures used at the site in oil and gas handling and production.
Items 7-10 are activities that could have higher emissions associated with them. So these activities will have to be accounted for.
9. (A) all contents from process equipment or tanks must be removed to the maximum extent practicable prior to opening facilities to commence degassing and maintenance.
(B) facilities must be degassed using best management practices to ensure air contaminants are removed from the system to the extent allowed by facility design.
(C) tanks may be emptied or degassed by forced ventilation if:
(i) only one vacuum truck is in use at any time;
(ii) emissions are directed out the top of the tank; or
(iii) emissions are routed through a closed system to a control device.

5. March 15-April 15 Comment Period O&G Authorizes Planned MSS
MSS PBR Timeline
March 15-April 15 Comment Period
July 26
Adoption
This slide shows a timeline that started in March and ends in January 2014.
The first marked area of the timeline is March 15-April 15 and it indicates the comment period. The MSS rule team worked feverously to respond to all the comments. The commission received comments from: Devon Energy Corporation (Devon), Eagle Rock Energy (Eagle Rock), an individual, the Lone Star Chapter of the Sierra Club (Sierra Club), Marathon Oil Company (Marathon), Plains All American (Plains), Pioneer Natural Resources (Pioneer), the Texas Oil and Gas Association (TXOGA), and the Texas Pipeline Association (TPA). One commenter was unsupportive, and the other commenters were generally supportive, but many suggested revisions to the proposed rule language.
Rule language was changed in response to comments.
The overall feedback we got form Industry was positive.
Several staff involved in this rule package when on trips to different facilities around Texas.
On July 3 the final rule language was published in the Texas Register. On July 23, The agency submitted revised back-up material and on July was adopted.
The third marked time is September 10 the effective date.
The final marked time is January 5, It indicates the deadline for oil and gas to authorize planned maintenance, startup, and shutdown.
The deadline for oil and gas sites under certain Standard Industrial Codes (SIC) was extended to January 5, 2014 by the legislature.
September 10
Effective Date
January 5, 2014
O&G Authorizes Planned MSS

6. MSS Authorization Options

7. 106.352 (i)-Planned Maintenance, Startups and Shutdowns
Options:
Counties required to be registered under (a-k) must use (i)
Counties voluntarily registered under (a-k) have an option to revise to (l).
Registering/Representing MSS-January 5, 2012
Counties authorized under a-k must authorize MSS activities and emissions under (i).
Counties voluntarily registered under a-k may choose to revise authorization to (l) and then claim § to authorize planned MSS authorizations.
Prior to January 5, 2012, representations and registration of planned MSS was voluntary, but if represented must meet the applicable limits of this section. After January 5, 2012, all emissions from planned MSS activities and facilities must be considered for compliance with applicable limits of this section.

8. 106.359-Planned MSS at O&G Handling & Production Facilities
Applicability
No superseding of existing authorization
Planned MSS Activities
Does not apply to facilities or sites authorized under (a)-(k) or non-rule subsections (a)-(k), , or Subchapter U
is used to authorize pipelines between sites. However, if you are blowing down a section of pipe between sites and the emissions end up at one of the sites then you can claim
Not used to supersede existing authorization for planned MSS under Ch. 106 or §
Planned MSS Activities:
Engine, compressor, turbine maintenance
Repair, adjustment, calibration, lubrication, cleaning of site process equipment
replacement of piping components, pneumatic controllers, boiler refractories, wet and dry seals, meters, instruments, analyzers, screens, and filters
turbine or engine component swaps
piping used to bypass a facility during maintenance
planned MSS activities with the same character and quantity of emissions as those listed in paragraphs (1) - (5) of this subsection
pigging and purging of piping
blowdowns
abrasive blasting, surface preparation, and surface coating of facilities and structures used at the site in oil and gas handling and production
emptying, purging, degassing, or refilling of process equipment, storage tanks and vessels (except landing floating roof tanks for convenience purposes)

9. 106.359-Planned MSS at O&G Handling & Production Facilities
PBR does not require registration
Best management practices
Keep records
A permit holder must claim the rule, develop and implement a maintenance program, and keep records.
The commission recommends that the permit holder print out a copy of the PBR and sign and date it to document the date of the initial claim
The application for ePermits is available if someone wishes to register or certify.
Please keep in mind that and must fall under the 25 VOC tpy limit.

10. 106.359 Construction Authorizations (Title V, NSR, Standard Permit)

11. Title V 106.359 required for permit Minor revision OP-NOTIFY
Upon the effective date of this rulemaking, permit holders subject to the Federal Operating Permit Program that choose to claim this PBR to authorize planned MSS activities at their sites will be subject to the requirements of this section.
359 will become an applicable requirement under a Title V permit.  Technically, when a facility claims 359 they will have to do a minor revision to the Title V permit.  The site would have to submit a form OP-NOTIFY.

12. NSR (New Source Review)
used to increase specific activities
Activities must be in compliance with rules
may not be used to remove existing special conditions
Section may also be used to authorize additional planned MSS activities that were not previously accounted for in the special conditions and the MAERT. If a new facility is constructed at an existing site that has a case-by-case permit then § may be used to authorize planned MSS from that new facility.
If a case-by-case permit authorized a specific number of activities for a facility, § may be used to increase the number of those activities, as long as the additional number of activities is conducted in compliance with all applicable rules and permit special conditions, including emission controls, monitoring, and recordkeeping, in the case-by-case permit for that activity. For example, if an engine and ten blowdowns associated with that engine are included in the case-by-case permit, § may be used to authorize additional blowdowns for that engine if the blowdowns are conducted in compliance with all applicable rules and special conditions of the New Source Review permit.
Section may not be used to remove existing special conditions and the associated (MAERT) limits related to planned MSS from an existing case-by-case permit. If a planned MSS activity is authorized in a case-by-case permit, companies may not alter the case-by case permit to delete the activities and claim them under §

13. Standard Permits 106.359 not incorporated §116.620
Referenced at renewal
No hourly emission requirements
Emissions from planned MSS activities authorized under § are not subject to the hourly emission requirements in the standard permit in §
A site would retain both authorizations.  359 will have to be referenced in the standard permit at renewal but it would still be a separate authorization.  359 will not have to be incorporated into the standard permit.
Remember for a standard permit you get 25tpy of VOC for

14. Scheduled Planned Upsets

15. Scheduled Maintenance
• Scheduled maintenance, startup, or shutdown activities are routine and predictable and are scheduled using time constraints.
• These activities should be included in the company’s maintenance program.
Scheduled maintenance, startup, or shutdown activities are routine and predictable and are scheduled using time constraints.
These activities should be included in the company’s maintenance program.

16. Example: Scheduled Maintenance
Engine oil will be changed every three months.
An example of scheduled maintenance would be to change the oil on an engine every three months.
You should have an expected day scheduled in advance for when this scheduled maintenance will take place.

17. Planned Maintenance
• Planned activities are routine and predictable, similar to scheduled maintenance, but planned maintenance is not necessarily scheduled for a specific date in the future.
For example: The brake pads on the car will be changed when the thickness is less than 1/8 inch.
Planned activities are routine and predictable, similar to scheduled maintenance, but planned maintenance is not necessarily scheduled for a specific date in the future. Instead you plan on doing it.
The good real world example is changing the brakes on your car. You’ll do so when the thickness passed a certain threshold.
You don’t necessarily have an exact date, but you know you’ll need to do it as some point. You will systematically have your brakes checked and then change them when necessary.
The same can be said for pieces of equipment at your site. You may not have an exact date or time you will replace something, but you will periodically check it, be it weekly, monthly, quarterly, and replace it when necessary.

18. Planned Maintenance
• Planned maintenance can be performed on an accelerated timeframe when a facility is shut down due to an emissions event.
Planned or scheduled maintenance can be performed on an accelerated timeframe when a facility is shut down due to an emissions event.

19. Example: Planned Maintenance After Emission Event
For example:
Emission event causes the engine shut down.
While engine is down, planned maintenance is performed.
Emissions during maintenance and the subsequent startup of the facility may be claimed as planned maintenance.
Emissions from the initial emission event that caused the engine shutdown cannot be claimed as planned maintenance

20. Upset Event Unplanned and unavoidable
This PBR does not authorize emissions associated with emissions events, malfunctions, upsets, unplanned startup, unplanned shutdown, or unplanned maintenance activities that require immediate corrective action.
An upset event is the unplanned and unavoidable breakdown of a process that releases unauthorized emissions of air contaminants
This PBR does not authorize emissions associated with emissions events, malfunctions, upsets, unplanned startup, unplanned shutdown, or unplanned maintenance activities that require immediate corrective action.
For additional information, see §101.1 and § , Emissions Event Reporting and Recordkeeping Requirements.

21. MSS Examples

22. Lily Site Separator Compressor VRU Flare Tank 1 Tank 2 Sales Gas Crude
Incoming Product
Crude Pipeline
This is the simplified process flow of the Lily oil and gas site. Incoming product enters the site and flows into a separator. From the separator, gas is routed to a compressor and then into the sales line, and crude oil is routed to two oil tanks. Crude oil in the tanks is sent offsite via pipeline. Working, breathing and flash emissions are captured by a Vapor Recovery Unit (VRU) and sent into the sales line.
There is also a flare at this site but it is not part of normal operations.
2. MSS will usually occur when a facility is taken down for planned or scheduled maintenance and product that is normally sent to that facility is instead rerouted to a different facility. MSS take place so as to avoid ceasing the flow of incoming product into a site and allows the site to continue to accept and process incoming product while maintenance is being performed on certain facilities.

23. MSS Example 1 Separator Compressor VRU Flare Tank 1 Tank 2
Gas to atmosphere
Compressor
Sales
Crude
Tank 1
Tank 2
VRU
Flare
Separator
Incoming Product
Crude Pipeline
Gas
Closed
for
Repairs
Gas
In this MSS scenario, the compressor is taken down for scheduled maintenance. During this time, gas that is regularly routed to the compressor and on to the sales pipeline is instead released to atmosphere. (I don’t know if we want to go into previously, the emissions coming from the separator would have been AOS….??)
Since the root cause of the emissions being released to atmosphere from the separator are due to scheduled Maintenance of the compressor, the emissions from the separator are considered MSS.
Any maintenance performed on the compressor, or subsequent blowdowns associated with it’s shutdown or startup would be considered MSS as well.

24. MSS Example 2 Separator Compressor VRU Flare Tank 1 Tank 2 Sales Gas
Crude
Tank 1
Tank 2
Flare
Separator
Incoming Product
Crude Pipeline
Gas
Closed
for
Repairs
VRU
In this MSS scenario, the VRU is taken down for scheduled maintenance. During this time, gas that is regularly controlled by the VRU and routed to the sales pipeline is instead routed to a flare for destruction.
The gas from the tanks that is routed to the flare, and the emissions associated with the combustion of this gas can be quantified and represented as MSS. Again, the root cause of gas from the tanks being re-routed to the flare is due to the scheduled maintenance of the VRU. Therefor, the flared gas can be considered MSS.
Any maintenance performed on the VRU, or subsequent blowdowns associated with it’s shutdown or startup would be considered MSS as well.
Gas

25. MSS Example 3 Separator Compressor VRU Flare Tank 1 Tank 2 Sales Gas
Crude
Tank 1
Tank 2
VRU
Flare
Separator
Incoming Product
Crude Pipeline
Closed
for
Repairs
In this MSS scenario, Tank 2 is taken down to be degassed and cleaned. During this time, liquids usually sent to Tank 2 and onto the liquids pipeline are sent to Tank 1.
As liquids originally sent to Tank 2 are now flowing into Tank 1, and not interrupting the incoming flow of product into the site, this is considered MSS.
Emissions associated with the Tank 2 degassing and cleaning are routed to the flare. These degassing and cleaning emissions being combusted in the flare are considered MSS.
Degassing

26. Summary Separator Compressor VRU Flare Tank 1 Tank 2 Sales Gas Crude
Incoming Product
Crude Pipeline
If a facility has been shutdown for a planned or scheduled MSS activity, and new product is still flowing into the site, being processed in some way, and then continuing downstream while this maintenance is being performed on that facility then the site is in MSS.

27. Calculation of Emissions from MSS Activities at Oil & Gas Production Facilities

28. Calculation Programs
We are aware of two programs that can do MSS emissions calculations.
TCEQ Oil and Gas Emissions Calculations Spreadsheets & Tanks ESP
We are aware of two packages that can do MSS emissions calculations. Our spreadsheets and TanksESP. There are a few others out there that have been vetted by the TCEQ and if you are interested in doing this, please feel free to contact us.
TanksESP will only calculate for Tank Degassing MSS.

29. MSS Default Values for Miscellaneous Activities
Spreadsheet contains the default value of a total of 0.25 tons per year for all activities authorized by (b)(1) (b)(6).
No calculations necessary!
The spreadsheet also allows more customized estimates of emissions for applicants choosing not to accept default values.
TCEQ has also developed default emission rates for the miscellaneous activities authorized by (b)(1) through (b)(6). These default values are conservative and can be used by all Oil & Gas Production Facilities. No calculations are required for facilities choosing to accept the default values.
This spreadsheet can also be used to make a more customized estimate of emissions for sites choosing not to accept the default values.
We have done all of the calculations for you based on extremely conservative values.
We will cover each bullet point in the following slides.
Go to spreadsheet

30. MSS Default Values for Miscellaneous Activities
The emissions in activities (b)(1)-(b)(6) may seem small, but they do add up over time. All default values are conservative.
Ex: (b)(1) Engine Oil changes / Filter changes Number of activities per year is 10 (Number of oil changes per engine per year) -Number of Engines is set at Allows for 100 oil changes per year
Go to spreadsheet – Default page.
The activities listed in (b)(1) – (b)(6) may seem small but they do add up over time. The main purpose in us creating these default values was to make it easier for you.
When we are discussing an oil change, we are referring to the actual VOC emissions from draining the oil into a pan.
100 oil changes per year does not necessarily mean that you have to change your oil 100 times.
We tried to account for the maximum number of oil changes per engine, per year.

31. MSS Default Values for Miscellaneous Activities
Customization of the default spreadsheet is possible.
Ex: A Glycol Dehydration and Amine unit are not present Emissions not used for these Units can be used for other activities.

32. MSS Default Values for Miscellaneous Activities
Best option? Use the default values.
It is as easy as selecting “Yes” at the top of the Spreadsheet page.
Can help with record keeping
Equations located at bottom of spreadsheet page.
Use the default values. Its easy and the best part is you do not have to do the calculations. Accounts for all (b)(1)-(b)(6) emissions sufficiently and conservatively.
For emission purposes the default values can be a part of your record keeping. However, the default values alone will not suffice for all record keeping. Ex: When you change your oil in the engine 3 times this year instead of the allotted 10 (per engine), there should be receipts showing that oil was purchased and those would suffice.
All equations used to calculated emissions are located at the bottom of the spreadsheet.
Again, you can customize the spreadsheet if you chose to do so.

33. TCEQ Oil and Gas Emissions Calculations Spreadsheet
Blowdowns
MSS pigging
MSS Floating Roof Tank Landing Losses
MSS Tank Non Forced Ventilation Degassing
MSS Tank Forced Ventilation Degassing
g/air/NewSourceReview/oilgas/spreadsheet- revisions.pdf
TCEQ has developed spreadsheets that can be used to estimate emissions from MSS activities at a Oil and Gas production facilities. Using the spreadsheet can help with streamlining your own permits. It was designed to make doing MSS calculations straightforward, easy and user friendly.
We encourage applicants to use the TCEQ spreadsheets. By using the TCEQ spreadsheet the technical reviewer can speed up their review time and in turn, you can receive your permit at an earlier time?
TCEQ Oil and Gas Emissions Calculations Spreadsheet can be used to estimate emissions from blowdowns, pigging operations, Floating Roof Tank Landing Losses,
Tank Non Forced Ventilation Degassing and MSS Tank Forced Ventilation Degassing.
TCEQ’s spreadsheets are based on well established emissions estimating equations and procedures. These are the methodologies and procedures that should be used by applicants choosing no to use the TCEQ spreadsheets.

34. Equations: Located on bottom of each Spreadsheet
Blowdowns and MSS Pigging and Piping Components: -Emission estimates based on Ideal Gas Law PV=nRT. -VOC result = ((Pressure of Gas Inside the Unit Before Venting) * (Actual Volume of the Vented Unit)) / (Frequency of events) * (Molecular Weight) * VOC wt%
Engine Oil change/Filter change Two components to Emissions: -Losses from emptying of oil into an open pan can be estimated using AP- 42 Loading Equation: LL= SPM T -Evaporation Losses from open pan: 𝐿 𝐸 =4.14 ∗ 10 −5 𝑈𝑆 PV MW0.67 Ap0.94 t
Changing Solution in Glycol Dehydration Units and Amine Units -AP-42 Loading Equation:LL= SPM T -AP-42 Clingage Loss Equation: LSL max = 0.60 (PVv / RT) Mv
Blowdown and MSS pigging emissions can be estimated using the Ideal Gas Law. The estimates will depend on the volume, pressure and temperature of the unit or segment of pipe and the molecular weight and VOC fraction of the liquid or gas. Emissions from piping components are calculated the same way as blowdowns.
The emissions associated with the changing of solutions in glycol dehydration units and amine units can be estimated by using the AP-42 Loading Equation to account for emptying the contactor and regenerator vessels.
Emissions from volatilization/evaporation of any can solution left in the container can be estimating the AP-42 Loading Equation and Clingage equation. The clingage equation will account for all of the liquid sticking to the walls the unit.

35. Equations: Located on bottom of each Spreadsheet
Changing Engine Rod Packings and Wet/Dry Seals and Heater Treaters: -Emissions result from the evaporation of the lubricant adhered to the rod packing and seal casings. -AP-42 clingage equation: LSL max = 0.60 (PVv / RT) Mv
Aerosol Lubricants: Emissions from the use of aerosol lubricants such as WD-40 can be estimated by assuming that 50% of the contents of a 16 oz can are volatile hydrocarbons that will volatilize.
Calibration: Emissions resulting from the use of calibration gases can be estimated by weighing the calibration gas cylinder every time it is used.
Emissions associated with changing engine rod packings and engine wet and dry seals are the result of evaporation of the lubricant adhered to the rod packing casing. These emissions are very low and can be estimating by assuming the casing is a small cylinder and using the AP-42 Clingage Equation.
The emissions calculations from MSS activities for heater-treater units assumes that the vessel has been emptied of process fluids.
The emissions consist of the evaporation of crude oil or condensate left in the heater-treater walls.

36. Painting and Sandblasting
Air Permit Technical Guidance for Coatings Sources: Surface Coating Operations.
Small Business and Local Government Assistance
Surface Coating Facilities: Emissions Calculation Spreadsheet
TCEQ Technical Guidance : Abrasive Blast Cleaning
Emissions from Aerosol Cans (paints, paint removers, rust inhibitors, etc.) Assume that 90% of the can contents evaporate.
Facilities choosing not to use the MSS Emissions for Paint and Blasting Operations Spreadsheet can estimate emissions from painting operations using the methodologies and procedures found in the Air Permit Technical Guidance for Coatings Sources: Surface Coating Operations.
TCEQ’s Small Business and Local Government Assistance Division has also developed a spreadsheet for estimating emissions from painting activities. The link to this spreadsheet is found on this slide.
VOC emissions from manual applications of paints at Oil & Gas Production facilities.
VOC emissions from spray cans (paints, rust removers etc.).
VOC and PM emissions from painting tanks and other large structures.
PM emissions from sandblasting
Emissions from Abrasive Blasting Operations can be estimated using the methodologies and procedures found in the TCEQ Technical Guidance: Abrasive Blast Cleaning.
Emissions from Aerosol Cans (paints, paint removers, rust inhibitors, etc.) can be estimated by assume that 90% of the can contents will evaporate.

37. Where to Find More Information
Kristyn Bower: (512) David Reyna: (512) Air Permits Main Line : (512)