title v site operating permits (sops), revisions, and renewals
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Title V Site Operating Permits (SOPs), Revisions,
and Renewals
Carolyn Maus, P.E.Air Permits Division
Texas Commission on Environmental QualityEnvironmental Trade Fair 2014
Overview
• Review of an Initial SOP Application
• Renewals
• Notifications
• Revisions Administrative Minor Significant
Initial SOP Review Process
Preliminary Procedures
Technical Review
Resolving Deficiencies
Working Draft Permit
Public Notice/EPA Review
Final State Action
Preliminary Procedures
The permit reviewer will:
• Check application for completeness
• Review OP-1 information
• Review site operations
• Inform applicant that review has begun
Preliminary Procedures
OP-1
Ralph Furley is entered as the RO
OP-CRO1
Ralph Furley signed this form as the DAR
Technical Review
The permit reviewer will review:
• 30 TAC Chapter 106/116 permits
• Major NSR Summary Table Required for all PSD/NA permits Includes all emission points in the MAERT Identifies monitoring/testing,
recordkeeping, and reporting requirements
Preliminary Procedures
Technical Review
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
Special Condition
Special Condition
TK-1 Tank VOC 2.5 0.24 5, 6 5, 7 5, 7, 8
Contents of current MAERT
Special Condition numbers that contain requirements for the EPN
OP-REQ1
Include the correct issuance dates for NSR authorizations.
OP-REQ1
Not a valid effective date
Texas Administrative Code (TAC)
Source Note: The provisions of this §106.183 adopted to be effective June 18, 1997, 22 Tex Reg 5668; amended to be effective September 4, 2000, 25 Tex Reg 8653
Technical ReviewThe permit reviewer will:
• Compare emission units on OP-SUM to plot plan
• Review forms for technical content and completeness OP-REQ1 OP-SUM OP-UA forms OP-REQ2
Preliminary Procedures
Technical Review
OP-REQ2
Lacks information
Shows that all exemption criteria are met
Technical Review
The permit reviewer will review:
• Permit shield requests
• OP-ACPS
• Compliance history
• PM/CAM requirements
Preliminary Procedures
Technical Review
Technical Review
• Periodic Monitoring Required for rules with insufficient
monitoring Exemptions
Rules with adequate monitoring VOC/HAP fugitive rules Rules proposed by EPA after November 15,
1990 Units conducting monitoring/recordkeeping
to meet an exemption from a rule
Preliminary Procedures
Technical Review
Technical Review• Compliance Assurance Monitoring
Applicability Criteria Subject to an emission limitation or standard; Using a control device; and Pre-control emissions ≥ major source
threshold
Exemptions Rules proposed by EPA after November 15,
1990 Continuous compliance determination
method Acid rain regulationsPreliminar
y Procedures
Technical Review
Resolving Deficiencies
The permit reviewer will:
• Send a list of deficiencies
• Review applicant responses
• Request additional information if needed
Preliminary Procedures
Technical Review
Resolving Deficiencies
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
Preliminary Procedures
Technical Review
Resolving Deficiencies
Working Draft Permit
Public Notice
• The permit reviewer will mail the public notice authorization package (PNAP) to the applicant.
• PNAP contents Letter Templates Forms Links
Preliminary Procedures
Technical Review
Resolving Deficiencies
Working Draft Permit
Public Notice/EPA Review
Public NoticeThe applicant will:
• Publish notice within 30 days of PNAP letter’s date
• Post signs beginning on first day of publication
• Place permit documents in a public facility for viewing
• Submit public notice documents Newspaper tear sheets Publisher’s affidavit(s) Public notice verification
Preliminary Procedures
Technical Review
Resolving Deficiencies
Working Draft Permit
Public Notice/EPA Review
Public Notice
The permit reviewer will:
• Verify that the applicant executed public notice correctly
• Respond to comments or hearing requests
• Schedule public hearings if necessary
Preliminary Procedures
Technical Review
Resolving Deficiencies
Working Draft Permit
Public Notice/EPA Review
Affidavit of Publication
• Site’s nearest city: Springlake (Form OP-1)
• Will the Chief Clerk accept this form?
The Office of the Chief Clerk will check whether this line includes the city (municipality) nearest to the site. If it does not, the applicant will be contacted to provide further information.
EPA Review
• 45-day review period
• Runs concurrently with public notice period
• Review period stops if comments are received EPA review period begins after comments
are addressed
Preliminary Procedures
Technical Review
Resolving Deficiencies
Working Draft Permit
Public Notice/EPA Review
Final State Action
• Permit is issued by TCEQ after EPA review period
• 60-day public petition period extends after EPA review period EPA may receive valid petition TCEQ will resolve objections Permit may be modified accordingly
Preliminary Procedures
Technical Review
Resolving Deficiencies
Working Draft Permit
Public Notice/EPA Review
Final State Action
SOP Renewal Timeline
Permit issued
Permit expiratio
n
Five year permit term (unless otherwise
noted)
TCEQ sendsrenewal notification
Application due(6-18 months before
expiration)
Renewals
General Policies and Procedures:• Incorporate changes under
notifications• Include all revisions• Evaluate PM and CAM• Use updated forms• Public notice, EPA review, public
petition• Significant revisions may not be
operated until renewal is issued
General Policies and Procedures
Incorporate changes
under notificatio
ns
Include all revisions
Evaluate PM and
CAM
Use updated
formsPublic notice, EPA review,
public petition
Significant revisions may
not be operated until
renewal is issued
SOP Revisions/Notifications
•Review TCEQ EPA The public
• Purpose is to maintain current applicable requirements
Notifications
• What is a notification? Applicant notifies TCEQ of changes at
the site No public notice/announcement, EPA
review, or public petition Must be added to the permit at renewal
• When can you use a notification? Changes are not FCAA Title I
modifications Changes do not increase NSR permit
limits Pre-construction authorization was
obtained
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
Notification Requirements
•Submit notification before operating the proposed change Off-permit Operational flexibility
•Form OP-Notify
•Certification by RO or DAR
•Maintain notice with permit
Example Notifications
• Change of tank service covered under §106.261/§106.262. Notification allowed?
Yes
• Change of tank service to a lower VP compound, covered under §106.261/§106.262 with 30 TAC Chapter 115 applicability. Notification allowed?
Yes
Example Notifications
• Adding PBR that was authorized before permit was issued. Notification allowed? No
• A notification is submitted after the change has occurred. Notification allowed? No
SOP Revisions• Revision types
Administrative Minor Significant
• Application contents Describe each change Identify affected emission units Use appropriate TCEQ forms
Administrative Revision
• What changes qualify for this revision type? Correcting typographical errors Increasing monitoring/reporting Change of permit holder Similar EPA-approved changes
• When is it due? No later than 30 days after the permit
anniversary
• No public notice and EPA review
Minor Revision
• Criteria No applicable requirements violated No significant changes to monitoring,
recordkeeping, or reporting No case-by-case determination of
emission limitation or standard No FCAA Title I modification
(PSD or NA)
Minor Revision
• When is it due? Submit before change is operated
• Public announcement and EPA review
• Application requirements Submit provisional terms and conditions
to operate change before approval Comply with new requirements
Minor Revision Examples
• Addition of newly promulgated applicable requirements
• Addition or removal of unit and applicable requirements
• Change in minor NSR allowable emissions
• Removal of permit shield
Significant Revision
• Criteria Does not qualify as admin. or minor
revision Significant changes to monitoring Relaxation of reporting or recordkeeping Addition/modification of permit shield
• When is it due? SOP revised before operating change
• PN, EPA review, and public petition
Significant Revision Examples
• PSD or NA modification
• Change in compliance plans
• Addition of acid rain permit
• Significant change to monitoring requirements
• 112(j) applications
Example Revisions
• An FCCU with PM for NSPS J is changing opacity monitoring from COMS to Method 9. Revision type? Significant revision
• Adding a tank to an SOP with NSPS Ka requirements and a permit shield for NSPS Kb. Revision type? Significant revision
Example Revisions
• Throughput increase in NSR
• Does not result in a major modification
• Revision to incorporate NSR amendment
• Revision type? Minor revision
Revision Review Policies
The permit reviewer will:
• Verify PBR effective dates
• Address errors/omissions unrelated to the requested revision if appropriate
• Combine multiple revision applications into one project if appropriate
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 applications and updates 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
Submitting Updates to EPA Region 6
Air Permits Section (6PD-R)
EPA, Region 6
1445 Ross Avenue, Suite 1200
Dallas, Texas 75202-2733
• Send applications on a CD
• Send application updates to: R6AirPermits@EPA.gov
• Identify the permit number
Questions?
Air Permits Division(512) 239-1250
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