Emission Events: Teaching the Basics

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

2. 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

3. Why the shift? • 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.

4. Initial Report • High points • 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? • 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.

5. Screen Shot of actual STEERS report #1

6. What was that…? • Missed the 24 hour reporting requirement • What chemical produced the opacity? • Where’s the final? • Not claiming Affirmative Defense

7. 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.

8. Screen Shot of actual STEERS report #2

9. What was that…? #2 • Insufficient detail on final report (e.g. not including the best known cause at the time of reporting) • Incorrect authorized emissions limit

10. Grouping Emissions • Understand that “VOC” or “PM” is generally 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.

11. 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. (You do have other work) • 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.

12. 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.

13. Screen Shot of actual STEERS report #3

14. Screen Shot of actual STEERS report #4

15. Lost Affirmative Defense • Usually fall into these categories: • Operator error • Sub-standard Maintenance Practices • Inadequate design or engineering practices • Not so Usual • Communication time lag- emitting 10 hours while waiting for a decision

16. Time for Your Questions