Transcript Site Operating Permits (SOPs)

Title V Site Operating Permits
(SOPs)
Carolyn Maus, P.E.
Air Permits Division
Texas Commission on Environmental Quality
Environmental Trade Fair 2015
Why Title V?
How is the initial application reviewed?
What are the other application types?
Is there public input?
How is EPA involved?
Why Title V?
Why Title V?
Major
source
Title V
permit
needed
Affected
source
category
How is the initial application reviewed?
Initial Application
Basic Info.
• Due before site operation begins or 12
months after TCEQ/EPA action
• All site-wide and unit requirements
• Public notice and EPA review
Initial Application
What’s in it?
• Area map, plot plan, process information
• Forms with detailed site information
• PM/CAM
• Compliance status
• Certification
Initial Application
Preliminary Review
Completeness
Company/Site Info.
Site Operations
Introduction
Initial Application
Technical Review
• 30 TAC Chapter 106/116 permits
• Major NSR Summary Table:
 PSD/NA permits
 Emission points in the MAERT
 Monitoring/testing, recordkeeping,
reporting
Initial Application
Major NSR Summary Table
AIR CONTAMINANTS DATA
Emission
Point No.
(1)
TK-1
Source
Name
(2)
Tank
Air
Contaminant
Name (3)
VOC
Contents of
current MAERT
Emission
Rates *
Monitoring
and Testing
Requirements
Recordkeeping
Requirements
Reporting
Requirements
lb/hr
TPY**
Special
Condition
Special
Condition
Special
Condition
2.5
0.24
5, 6
5, 7
5, 7, 8
Special Condition numbers with
requirements for the EPN
Initial Application
Technical Review
Site-wide
requirements
• OP-REQ1
Unit-specific
requirements
• OP-SUM
• OP-UA
Negative
applicability
• OP-REQ2
Initial Application
Negative Applicability
Lacks information
Shows that all exemption
criteria are met
Initial Application
More Technical Review
Compliance
PM/CAM
• OP-ACPS
• Compliance History Review
• OP-MON
Initial Application
Periodic Monitoring
• Does the rule contain sufficient monitoring?
• Does it have sufficient monitoring frequency?
If you answered
No at least once,
you’ll need PM.
Initial Application
Compliance Assurance Monitoring
Emission
Limit
Control
Device
CAM applies!
Pre-control ≥
major
Initial Application
Resolving Deficiencies
The permit reviewer will:
• Send a list of deficiencies
• Review applicant responses
• Request additional information if needed
Initial Application
Working Draft Permit
The applicant will:
• Submit comments within 30 days
• Legibly mark changes on forms or draft
• Clearly indicate new, revised, and deleted data
• Certify updates prior to public notice
What are the other application types?
SOP Renewals
SOP Renewal
Timeline
TCEQ sends
renewal notification
Permit
issued
Application due
(6-18 months before
expiration)
Five year permit term
(unless otherwise noted)
Permit
expiration
SOP Renewal
Application
• Update all requirements
• Evaluate PM/CAM for all units
• Certify compliance status
• Public notice and EPA review
SOP Revisions and Notifications
SOP Revisions
and Notifications
• Reviewed by:
 TCEQ
 EPA
 The public
• Purpose is to maintain current applicable
requirements
Notifications
Can I use a
notification?
When should
I submit my
notification?
What is a
notification?
Notification Types
Off-permit changes:
•
Add applicable requirements from site changes
•
New unit
•
New PBR/standard permit
Off-permit
changes
• Add applicable
requirements from
site changes
• New unit
• New PBR/standard
permit
Operational flexibility:
•
Remove unit
•
Modify applicable requirements
•
Decrease NSR emission limits.
Operational
flexibility
• Remove unit
• Modify applicable
requirements
• Decrease NSR
emission limits
SOP Revisions
Types
• Administrative
• Minor
• Significant
SOP Revisions
Application
• Describe each change
• Identify affected emission units
• Use appropriate TCEQ forms
Administrative Revision
What changes?
30 TAC §122.211
When is it due?
30 days after anniversary
Procedures?
Operate before issuance;
No public notice/EPA review
Minor Revision
What changes?
30 TAC §122.215
When is it due?
Before operation
Procedures?
Operate before issuance;
Public announcement/EPA review
Significant Revision
What changes?
30 TAC §122.219
When is it due?
Before operation
Procedures?
Operate after issuance;
Public notice/EPA review
Is there public input?
Public Notice
Publish
Notice
Post
Signs
Applicant
Tasks
Public
Viewing
Submit
Forms
Public Announcement
How is EPA involved?
EPA Review
• 45-day review period
• Concurrent with public notice/announcement
• Stops if comments are received:
 Begins again after comments are
addressed
Final State Action
After EPA review:
• TCEQ issues permit
• 60-day public petition period:
 EPA may receive valid petition
 TCEQ resolves objections
 Permit may be modified
Guidance
• TCEQ Memos
• Additional FOP Guidance
Submitting Applications to TCEQ
TCEQ
APIRT, MC 161
P.O. Box 13087
Austin, TX 78711-3087
Mail a copy of all applications to the
appropriate TCEQ regional office.
Submitting Updates to
Applications Under Review
[Name of Assigned Permit Reviewer]
TCEQ
Air Permits Division, MC 163
P.O. Box 13087
Austin, TX 78711-3087
Mail a copy of all updates to the appropriate
TCEQ regional office.
Submitting Info. to
EPA Region 6
Air Permits Section (6PD-R)
EPA, Region 6
1445 Ross Avenue, Suite 1200
Dallas, Texas 75202-2733
• Send all applications on a CD
• Send all application updates to:
[email protected]
• Identify the permit number
Questions?
Air Permits Division
(512) 239-1250