Compliance and Enforcement: Investigation Overview

Today’s Topics Advanced Air Permitting Seminar – October 2014 Investigation Overview Investigation Overview Hot Issues by Investigation Type Hot Issues by Investigation Type Guidance Documents and Resources Guidance Documents and Resources Contact Information Contact Information

Investigation Overview Advanced Air Permitting Seminar – October 2014 Announced* Routine compliance onsite investigations Routine compliance onsite investigations In-house investigations In-house investigations Emissions events Emissions events Stack testing Stack testing *Facilities with a unsatisfactory compliance history rating may compliance history rating may not receive notice not receive notice Unannounced Complaints Complaints Fence line observations Fence line observations Reference: RG-457 and TCEQ Webpage RG-457TCEQ WebpageRG-457TCEQ Webpage

What to Expect Advanced Air Permitting Seminar – October 2014 Initial contact: records request Initial contact: records request Onsite investigation Onsite investigation Initial exit interview Initial exit interview Follow-up questions Follow-up questions Final exit interview Final exit interview Letter Letter

Advanced Air Permitting Seminar – October 2014 Contact: 1-14 days Investigation: 1-14 days Findings and Letter: days Typical Investigation Timeframe

Records Advanced Air Permitting Seminar – October 2014

Top 10 Violations: Previous 5 Years Advanced Air Permitting Seminar – October 2014 Number IssuedCitationDescription 12,113THSC (b) Cited in conjunction with applicable state/federal rules 6,94730 TAC (4) ST&C of Federal Operating Permit 4,59630 TAC (c) SC of NSR permit TAC (3) Compliance w/ EPA standards TAC (a) Compliance w/ NSR flexible permit TAC (a) Pre-construction authorization TAC ODB General Prohibition TAC (2)(A) Deviation reporting TAC (b)(2)(F) MAERT TAC (2) PCC 1) THSC (b) was cited 12,113 times in conjunction with applicable state and federal rules. 2) 30 TAC (4) was cited 6,947 times for failing to comply with the standard terms and conditions of a Federal Operating Permit. 3) 30 TAC (c) was cited 4,596 times for failing to comply with a special condition on an NSR permit. 4) 30 TAC (3) was cited 819 times for failing to comply with an EPA standard. 5) 30 TAC (a) was cited 803 times for failing to comply with an NSR flexible permit. 6) 30 TAC (a) was cited 742 times for failing to obtain authorization prior to construction. 7) 30 TAC was cited 591 times for outdoor burning. 8) 30 TAC (2)(A) was cited 584 times for deviation reporting issues 9) 30 TAC (b)(2)(F) was cited 550 times for failing to comply with a Maximum Allowable Emission Rates Table. 10) 30 TAC (2) was cited 388 times for Permit Compliance Certification issues.

Hot Issues for Permit Investigations Advanced Air Permitting Seminar – October 2014 Permit applications Permit applications Reporting errors Reporting errors

Application Errors Advanced Air Permitting Seminar – October 2014 Omissions: Omissions: Units Units Rules: Rules: Decision Decision Decision Support System

Reporting Errors Advanced Air Permitting Seminar – October 2014 OP-CRO1 Form OP-CRO1 Form OP-CRO1 Form OP-CRO1 Form Deviation report parts: Deviation report parts: Deviation report parts Deviation report parts Dates Dates Misuse of Part 2 on DR Misuse of Part 2 on DR

Reporting Errors Advanced Air Permitting Seminar – October 2014

Title V Resources Advanced Air Permitting Seminar – October 2014 Title V Guidance Title V Guidance Title V Guidance Title V Guidance DR Guidance DR Guidance DR Guidance DR Guidance

Hot Issues for EE Advanced Air Permitting Seminar – October 2014 EE vs. MSS boundaries Upset Shutdown Maintenance Start-up STEERS vs. DR

Hot Issues for Stack Testing Advanced Air Permitting Seminar – October 2014

Hot Issues for Stack Testing Advanced Air Permitting Seminar – October 2014 REMINDER: Listing a sampling deviation in a test plan does not constitute approval. Approval is required.

Regional Office Contact Information Advanced Air Permitting Seminar – October 2014 NORTH CENTRAL AND WEST TEXAS AREA COASTAL AND EAST TEXAS AREA CENTRAL TEXAS AREA BORDER AND PERMIAN BASIN AREA