title v site operating permits (sops), revisions, and renewals

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


The permit reviewer will:

• Check application for completeness

• Review OP-1 information

• Review site operations

• Inform applicant that review has begun


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


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


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


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


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



• Send a list of deficiencies

• Review applicant responses

• Request additional information if needed


Technical Review



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


Technical Review



Public Notice

• The permit reviewer will mail the public notice authorization package (PNAP) to the applicant.

• PNAP contents Letter Templates Forms Links


Technical 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


Technical Review




Public Notice


• Verify that the applicant executed public notice correctly

• Respond to comments or hearing requests

• Schedule public hearings if necessary


Technical 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


Technical 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


Technical 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


• 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

http://www.tceq.texas.gov/permitting/air/memos/op_memos.html

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 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: [email protected]

• Identify the permit number

mailto:[email protected]

Questions?

Air Permits Division(512) 239-1250

title v site operating permits (sops), revisions, and renewals

Documents

completeness review

emission units

emission limitation

emission rates

emission points

nsr authorizations

tex reg

exemption criteria