Emission Events: Teaching the Basics Jon Williams TCEQ Work leader, El Paso Region

Congratulations! Probationary TCEQ Employees No benefits until 3 months have been reached Employment terminates upon exit of the room at any time Learn the most challenging investigation type, FIRST Also, no salary has been provided in our budget

The Investigator Perspective You will learn how the investigator thinks while reading your provided information. Hopefully the rules will make a little more sense. Also, this should prepare you to provide clearer, more comprehensive event reports.

Initial Report High points of the report How was the report received; STEERS, fax, email, or by hand? (Form 10360) 24 hour clock started from the time they knew about the upset, did they report in time? Simple statements of what occurred; does it match with Emission Point Numbers, and pollutants released?

Screen Shot of actual STEERS report #1

Close-up of top quarter of the Screen Shot of actual STEERS report #1

Close-up of second quarter of the Screen Shot of actual STEERS report #1

Close-up of third quarter of Screen Shot of actual STEERS report #1

Close-up of bottom quarter of Screen Shot of actual STEERS report #1

Initial report review Check RQ for everything reported Start learning about the affected facility and those immediately upstream and downstream. Learn permit conditions and permit emission limits. Review compliance history.

What was that…? Missed the 24 hour reporting requirement What chemical produced the opacity? Not claiming Affirmative Defense Excess Opacity does not require a Final Report

2 weeks later High points Again, check the date of receipt. The final is due 2 weeks from the END of the event. Did they speciate emissions (Benzene vs. VOC)? Pollutants compared to EPN, what came out of what? Does the end result make sense based on the initial? Must answer all 11 determinations to meet Affirmative Defense. Must be a COMPLETE answer for each of the determinations. If the final report doesn’t complete the 11 determinations, request additional information with a deadline.

Screen Shot of actual STEERS report #2

Screen Shot of close-up of third quarter of actual STEERS report #2

What was that…? #2 Incorrect authorized emissions limit Insufficient detail on final report (e.g. not including the best known cause at the time of reporting) Why did the coupling fail? How quickly and exactly what actions were taken to minimize emissions?

Grouping Emissions Understand that “VOC” or “PM” is not an acceptable way to report emissions for §101 purposes. (Even though the permit may very well refer to “VOC” or “PM” on its maximum allowable emission rates table (MAERT).) Carefully read the definition of RQ to understand which mixtures are acceptable to report (e.g. natural gas excluding methane, ethane, etc.) 30 TAC §101.201(b)(1)(G): They can lump all compounds as “other” for which BOTH of these things are true: The RQ is 100 lbs or more. Less than 10 lbs was released in a 24-hour period.

Last Chance Drill down on any unknowns or questions How did that cause this? How was the operator trained? Maintenance records for affected units. No more than five years should be requested. Operational logs before & after the event. Ask/compare previous events that may have occurred that were reported to STEERS. Ask them to provide any additional information that was not specifically asked for that they feel is relevant.

Put it all on the scales Affirmative Defense The event couldn’t have been prevented or avoided. How was this event handled compared to the last one of the same facility. They have the technology, Better.. Faster... Stronger The consequences of the events were minimized as much as possible. All reporting requirements were met.

Screen Shot of actual STEERS report #3

Close up screenshot of third quarter of emission event

Lost Affirmative Defense Usually falls into these categories: Operator error Poor Training Sub-standard Maintenance Practices Record Request Inadequate design or engineering practices System keeps failing Not so Usual Communication time lag, emitting for 10 hours while waiting for a decision

STEERS Expert Contacts STEERS Questions: STEERS MC226 512-239-6925 steers@tceq.texas.gov Physical Address TCEQ <Place Program Name and Mail Code Here> 12100 Park 35 Cir Austin, TX 78753 Petroleum Storage Tank (PST) PST Registration and Self-Certification MC138 512-239-2160 Aggregate Production Operations (EPR_APO) WQ Processing Center MC140 512-239-APOP (2767) APO@tceq.texas.gov Discharge Monitoring Report (eDMR/NetDMR) Enforcement Division MC224 512-239-eDMR (3367) netdmr@tceq.texas.gov Pollution Prevention Planning (P2PLAN) Waste Reduction Policy Act Program MC108 512-239-3143 P2@tceq.texas.gov Air Emissions Maintenance Events (AEME) Field Operations MC 174 512-239-0416 Industrial and Hazardous Waste (IHW) Registration and Reporting MC 129 512-239-6413 Public Drinking Water - Labs (PDWLAB) Public Drinking Water MC155 512-239-4691 PDWS@tceq.texas.gov Air New Source Review (EPR_NSR) Air Permits MC 163 512-239-1250 Municipal Solid Waste (MSW) Municipal Solid Waste MC130 512-239-6700 elvi.yzaguirre@tceq.texas.gov Public Drinking Water - Systems (PDWSYS) Annual Emissions Inventory Report (AEIR) Emissions Inventory, MC-164 512-239-1773 psinvent@tceq.texas.gov Municipal Solid Waste Registrations (EPR_MSW) Municipal Solid Waste Permits Section MC124 512-293-2334 Storm Water General Permits (EPR_SW) Storm Water Processing Center MC228 512-239-3700 swpermit@tceq.texas.gov CAFO General Permit (EPR_CAFO) Applications Review & Processing MC 148 512-239-4671 CAFO@tceq.texas.gov Occupational Licensing Computer Based Testing (CBT) Operator Licensing MC178 512-239-0176 Training Roster Online Submittal (TROLS) Operator Licensing MC178 512-239-2262 Central Registry (CR) Questions: Central Registry Program MC 144 512-239-5175 registry@tceq.texas.gov Pesticide General Permit (EPR_PESTGP) WQ Processing Center MC140 512-239-BUGS (2847) PGP@tceq.texas.gov  

Time for Your Questions