Title V Site Operating Permits (SOPs) Carolyn Maus, P.E. Air Permits Division Texas Commission on Environmental Quality Environmental Trade Fair 2015

Overview Why Title V? Why Title V? How is the initial application reviewed? What are the other application types? Is there public input? How is EPA involved? How is the initial application reviewed? What are the other application types? Is there public input? EPA – Environmental Protection Agency How is EPA involved?

Overview Why Title V? Why Title V? EPA – Environmental Protection Agency

Affected source category Why Title V? Major source Affected source category Title V permit needed Major source Affected source category

Overview How is the initial application reviewed? EPA – Environmental Protection Agency

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 TCEQ – Texas Commission on Environmental Quality

Initial Application What’s in it? Area map, plot plan, process information Forms with detailed site information PM/CAM Compliance status Certification PM – periodic monitoring CAM – compliance assurance monitoring

Initial Application Preliminary Review Completeness Company and Site Information Site Operations Introduction to applicant 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 30 TAC – Title 30 Texas Administrative Code NSR – New Source Review PSD – Prevention of Significant Deterioration NA – nonattainment MAERT – Maximum Allowable Emission Rates Table

Initial Application Major NSR Summary Table AIR CONTAMINANTS DATA Emission Point No. (1) Source Name (2) Air Contaminant Name (3) Emission Rates * Monitoring and Testing Requirements Recordkeeping Requirements Reporting Requirements lb/hr TPY** Special Condition TK-1 Tank VOC 2.5 0.24 5, 6 5, 7 5, 7, 8 Special Condition numbers with requirements for the EPN VOC – volatile organic compounds lb/hr – pound(s) per hour TPY – tons per year EPN – emission point number Contents of current MAERT

Initial Application Technical Review Site-wide requirements OP-REQ1 Unit-specific requirements OP-SUM OP-UA Negative applicability OP-REQ2 OP-REQ1 is the Application Area-Wide Applicability Determinations and General Information form. OP-SUM is the Individual Unit Summary form. OP-UA forms are Unit Attribute forms. OP-REQ2 is the Negative Applicable Requirement Determinations form.

Initial Application Negative Applicability Lacks information Shows that all exemption criteria are met 40 CFR – Title 40 of the Code of Federal Regulations 2SLB – two-stroke lean-burn RICE – reciprocating internal combustion engine hp - horsepower

Initial Application More Technical Review Compliance OP-ACPS Compliance History Review PM/CAM OP-MON OP-ACPS is the Application Compliance Plan and Schedule form.

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. If you answered No at least once, you’ll need PM.

Initial Application Compliance Assurance Monitoring Subject to an emission limitation or standard; Using a control device; and Pre-control emissions ≥ major source threshold Emission Limit Control Device Pre-control ≥ major CAM applies!

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

Overview What are the other application types?

Overview Application types - SOP renewals SOP Renewals

SOP Renewal Timeline TCEQ sends renewal notification Permit issued Permit expiration Five year permit term (unless otherwise noted) Application due (6-18 months before expiration)

SOP Renewal Application Update all requirements Evaluate PM/CAM for all units Certify compliance status Public notice and EPA review

Overview Application types – SOP revisions and notifications

SOP Revisions and Notifications Reviewed by: TCEQ EPA The public Purpose is to maintain current applicable requirements

Notifications What is a notification? What is a notification? Can I use a notification? When should I submit my notification? Can I use a notification? When should I submit my notification?

Operational flexibility Notification Types 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 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. PBR – permit by rule

SOP Revisions Types Administrative Minor Significant

SOP Revisions Application Describe each change Identify affected emission units Use appropriate TCEQ forms

Administrative Revision What changes? What changes qualify for this revision type? 30 TAC §122.211 When is it due? No later than 30 days after the permit anniversary Procedures? Can operate the change before revision issuance No public notice or EPA review 30 TAC §122.211 When is it due? 30 days after anniversary Procedures? Operate before issuance; No public notice/EPA review

Operate before issuance; Public announcement/EPA review Minor Revision What changes? What changes qualify for this revision type? 30 TAC §122.215 When is it due? Before operating the change Procedures? Can operate the change before revision issuance Public announcement/EPA review 30 TAC §122.215 When is it due? Before operation Procedures? Operate before issuance; Public announcement/EPA review

Operate after issuance; Public notice/EPA review Significant Revision What changes? What changes qualify for this revision type? 30 TAC §122.219 When is it due? Before operating the change Procedures? Cannot operate change until revision is issued Public notice/EPA review 30 TAC §122.219 When is it due? Before operation Procedures? Operate after issuance; Public notice/EPA review

Overview Is there public input? Is there public input?

Public Notice Publish Post Applicant must: Notice Signs Publish notice Post signs Make permit documents available for viewing Submit public notice documents to TCEQ Applicant Tasks Submit Forms Public Viewing

Public Announcement TCEQ publishes announcement online TCEQ posts documents online

Overview How is EPA involved? How is EPA involved?

EPA Review Concurrent with public notice/announcement 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 FOP – federal operating permit TCEQ memos can be found at http://www.tceq.texas.gov/permitting/air/memos/op_memos.html. Additional FOP guidance can be found at http://www.tceq.texas.gov/permitting/air/titlev/apps_timelines.html.

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. APIRT - Air Permits Initial Review Team MC - mail code

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: R6AirPermits@EPA.gov Identify the permit number CD – compact disc

Air Permits Division (512) 239-1250 Questions? Air Permits Division (512) 239-1250