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

2. 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?

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

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

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

6. 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

7. 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

8. Initial Application Preliminary Review
Completeness
Company and Site Information
Site Operations
Introduction to applicant
Completeness
Company/Site Info.
Site Operations
Introduction

9. 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

10. 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

11. 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.

12. 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

13. 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.

14. 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.

15. 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!

16. Initial Application Resolving Deficiencies
The permit reviewer will:
Send a list of deficiencies
Review applicant responses
Request additional information if needed

17. 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

18. Overview What are the other application types?

19. Overview
Application types - SOP renewals
SOP Renewals

20. 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)

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

22. Overview Application types – SOP revisions and notifications

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

24. 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?

25. 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

26. SOP Revisions Types
Administrative
Minor
Significant

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

28. Administrative Revision
What changes?
What changes qualify for this revision type?
30 TAC §
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 §
When is it due?
30 days after anniversary
Procedures?
Operate before issuance; No public notice/EPA review

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

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

31. Overview
Is there public input?
Is there public input?

32. 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

33. Public Announcement TCEQ publishes announcement online
TCEQ posts documents online

34. Overview
How is EPA involved?
How is EPA involved?

35. 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

36. 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

37. Guidance TCEQ Memos Additional FOP Guidance
FOP – federal operating permit
TCEQ memos can be found at
Additional FOP guidance can be found at

38. Submitting Applications to TCEQ
TCEQ APIRT, MC 161 P.O. Box Austin, TX Mail a copy of all applications to the appropriate TCEQ regional office.
APIRT - Air Permits Initial Review Team
MC - mail code

39. Submitting Updates to Applications Under Review
[Name of Assigned Permit Reviewer] TCEQ Air Permits Division, MC 163 P.O. Box Austin, TX Mail a copy of all updates to the appropriate TCEQ regional office.

40. Submitting Info. to EPA Region 6
Air Permits Section (6PD-R)
EPA, Region 6
1445 Ross Avenue, Suite 1200
Dallas, Texas
Send all applications on a CD
Send all application updates to:
Identify the permit number
CD – compact disc

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