Planned Maintenance, Startup, and Shutdown – Other Industries

1. Planned Maintenance, Startup, and Shutdown – Other Industries Mike Coldiron , P.E. Air Permits Division Texas Commission on Environmental Quality Advanced Air Permitting Seminar 2012

2. What Are Planned MSS Emissions? • Planned MSS emissions include air emissions resulting from the maintenance, startup, or shutdown of equipment or facilities at a site

3. What Are Planned MSS Emissions? • Part of normal or routine facility operations other than production operations • Predictable to timing • Do not have to be scheduled for a specific date or time

4. What Are Planned MSS Emissions? • Do not include unplanned MSS, upsets, or emission events • TCEQ does not permit unplanned MSS, upsets, or emission events • Emission events are covered under 30 TAC §101.201

5. MSS Permitting – Other Industries • Diversity very different from previous industry groups • Different industry demographics - small businesses and minor sources (sites)

6. MSS Permitting Goals – Other Industries • Reduce the amount of effort for staff and regulated community • Reduce processing times • Efficiently review MSS from the large number of permitted sources anticipated for the 2013 submittal

7. MSS Permitting – Previously Permitted Industries

8. MSS Permitting – Coatings Industry

9. MSS Permitting – Mech/Ag/Construction Industry Total number of Mechanical Section applications is expected to exceed 3000

10. MSS Permitting – Chemical Process Industry

11. MSS Permitting – Planned MSS Groupings • Evaluated possible MSS activities for each industry type • Created groupings of similar industry types with similar MSS activities • Discussed options for authorizing those activities

12. Activity Categories for MSS • Process MSS • General facility MSS • Included in other industry submissions • Impacts issues are difficult to deal with

13. Approach for Process MSS Activities • Identified specific facility types • Identified for each facility type • What is MSS • What is not MSS (normal process) • MSS activities may be common to different facilities • Authorization options

14. Process MSS Authorization Options • Already authorized in current permit explicitly or implicitly • PBR – 30 TAC Chapter 106 • No registration in most cases • Simple (or no) recordkeeping • No BACT review or public notice • Limited (or no) impacts review

15. Process MSS Authorization Options • De minimis – 30 TAC §116.119 • No registration • Simple (or no) recordkeeping • No BACT review or public notice • Limited impacts review

16. Examples of Process MSS Using PBR §106.263 • Temporary control devices for degassing • Thermal control device startup and shutdown • Process piping replacement or repair

17. Approach for General Facility MSS • Identify common activities • Approach to authorization • De minimis under 30 TAC §116.119 • PBR

18. General Facility MSS Authorization Options • De minimis – 30 TAC §116.119 • No registration • Simple (or no) recordkeeping • No BACT review or public notice • Limited impacts review

19. General Facility MSS Authorization Options • PBR – 30 TAC Chapter 106 • No registration in most cases • Simple (or no) recordkeeping • No BACT review or public notice • Limited (or no) impacts review

20. Examples of General Facility MSSDe Minimis - §116.119 • Glove box blasting cabinets • Aerosol cans (< 64 ounces/day) • Vehicle/equipment washing

21. Examples of General Facility MSSDe Minimis - §116.119 • Instrument calibration/leak checking • Non-aerosol lubricants • Aqueous detergents

22. Examples of General Facility MSS Using PBRs • Facility painting/blasting: §106.263 • Parts cleaners: §106.454 • Welding: §106.227 • Hand-held equipment: §106.265

23. MSS Authorization Requirements - Amendments • Identify planned MSS activities • Quantify emissions • BACT required • May include restrictions on activities • May be work practices

24. MSS Authorization Requirements - Amendments • Impacts analysis required • Use MERA • Air dispersion modeling may be required • Public notice may be required • New air contaminants • Increased emissions > PN Triggers

25. Implementation Tools – Coatings Sources • Form PI-MSS for surface coating sources • Example application based on Form PI-MSS • Updated MSS BACT Tables • Frequently Asked Questions

26. Implementation Tools – Mech/Ag/ConstructionIndustry • Survey to gather information • Outreach to industry • Early MSS review

27. Implementation Tools – Chemical Sources • Chemical Section Toolbox on Air Permits page of TCEQ Web site will include the following: • Guidance documents • Instructions • Calculation spreadsheets • BACT tables • FAQs

28. Summary • Applications for “other sources” are due by 01/05/13 • Timely applications will preserve the affirmative defense • BACT and an impacts analysis will be required for permit amendments

29. Summary • Use PBR or de minimis for general facility MSS activities • Use the implementation tools developed by APD • Work with APD during application development

30. Phone Numbers APIRT: (512) 239-3075 APD: (512) 239-1240 or 1250

31. Contact Information Contact information for the Coatings MSS Team is located on the announcements page of the TCEQ Web site. CoatingsMSS@tceq.texas.gov

32. Contact Information Mike Coldiron, P.E. (512) 239-5027 mike.coldiron@tceq.texas.gov