Unfortunately for MMEX (retail investors), MMEX already applied for, and received the Type O AQP from the TCEQ.
This is a permit by regulation (PBR), an administrative permit for minor source emitters (similar to dry cleaners, rock crushers, and other small emission sources).
The issued Type O permit can't be amended - there is no amendment process for this kind of administrative permit.
Without a new application to TCEQ, MMEX is already limited to operating the flawed VFuels design, exactly as it was permitted.
Any remaining engineering work that might alter this is largely irrelevant. Things that might be used to improve operations, like dual stream heat exchange, sub-unit redundancy, de-salting and related pre-treating, alterations from a reboiler based AGO recovery flow, and so on would push the Phase I unit outside of the emissions envelope that could be met by the Type O/PBR process.
All of this was knowable months ago - the misdirect on claimed EPC completion is a two-fold disaster - MMEX made a fatal move by selecting VFuels (death-blow one), and progressing to the subsequent steps on the basis of that flawed design.
The truth is, for something as simple as a 10,000 bpd unit like MMEX's proposed Phase I, the entire design could have been completed in less than two weeks, including simulations, spool layout and fab drawings.
For those without in-depth sector knowledge, "investing" in something like MMEX has worse odds than the lottery, or roulette.
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