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Updating Title V Post Permit Forms

Updating Title V Post Permit Forms. Joseph A. Janecka, P.E., Air Program Liaison Field Operations Support Division TCEQ. What Forms? You ask. Permit Compliance Certification – “PCC”: also sometimes referred to as “Annual Compliance Certification.” Supports Chapter 122, §122.146.

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Updating Title V Post Permit Forms

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  1. Updating Title V Post Permit Forms Joseph A. Janecka, P.E., Air Program Liaison Field Operations Support Division TCEQ

  2. What Forms? You ask • Permit Compliance Certification – “PCC”: also sometimes referred to as “Annual Compliance Certification.” Supports Chapter 122, §122.146. • Semiannual Deviation Report – “DevRpt”: Supports Chapter 122, §122.145.

  3. Plan for Update • Current needs identified - complete • Management approval - complete • Schedule for completion: Goal – 2008 Trade Fair • Public Participation: Stakeholder meetings Austin March 13, Houston March 19, Midland April 1

  4. Update Needs Currently Identified • Typos, Reference to “TNRCC”, “DRAFT” watermark, etc. • Incorporate Central Registry Requirements • Restructure to mimic Air Permits Division (APD) application forms • Relocate web site links and information from APD to Office of Compliance and Enforcement (OCE) Field Operations web page

  5. Current Update Needs (cont’d) • Ensure compliance with the Agency’s forms procedures • Ability to refer to reportable emissions events quickly and efficiently • Provide for credible evidence • Explore the need for CAIR and CAMR certifications • Request copy of DevRep to US EPA

  6. New Look – But Familiar Look • Restructure the forms to that similar to Air Operating Permits applications: • Form • Instructions • Guidance • Forms and Instructions are managed and subject to Agency forms policy and procedure. Guidance is not.

  7. Other Updates Needs • Expand the breadth and depth of examples in guidance: • Make sure what we have is current • Include more examples that best explain questions that have arisen since the older forms versions

  8. And Finally… • Discuss and develop a process to minimize time between form updates, if needed • Promote a better understanding between regulated entities, Field Operations, and other stakeholders on how these forms are used.

  9. Emission Events • Definition: Emissions event--Any upset event or unscheduled maintenance, startup, or shutdown activity, from a common cause that results in unauthorized emissions of air contaminants from one or more emissions points at a regulated entity. • Therefore: All emissions events ARE deviations.

  10. How Compliance Certification Periods May Vary • Compliance Certifications at least every 12 months • Certifications must be continuous. • Compliance period start date defined by one of three events: • Initial Permit issuance date • End of previous compliance period • Change of Ownership: Purchaser

  11. How Compliance Certification Periods May Vary • Compliance period end date defined by earliest of three events: • 12 months since last compliance certification • Change of ownership: Seller • Void Permit • Or, the permit holder may define a shorter period voluntarily

  12. How Compliance Certification Periods May Vary • The Compliance Certification submission deadline is based on the end date of the reporting period. Not 12 months.

  13. Recent Guidance: Deviations • How to document the following examples of “continuous” non-compliance: • Exceedance of permit emission allowables • Construction and/or operation without authorization • Enter one line, include start date/time and end date/time. • Enter Number of deviations = 1

  14. Recent Guidance: Deviations • Question: What would be considered “reasonable inquiry” for discovery or use of credible evidence (by the permit holder)? • Please note we are merely providing examples of reasonable inquiry, but not completely defining the term.

  15. Credible Evidence through Reasonable Inquiry • Answer 1 - Multiple rules for same unit and pollutant/requirement: • A deviation for the same unit and pollutant, where the measured exceedance, lack of required work practice, or unauthorized or prohibited activities or operations in one rule that would constitute a deviation of another rule.

  16. Credible Evidence through Reasonable Inquiry • Answer 2 - Emission events at same unit and pollutant, including cause: • Any emission event resulting in a measured exceedance, or indicative of a lack of required work practice, or unauthorized or prohibited activities or operations would constitute a deviation of rule for the same unit and pollutant.

  17. Questions on any of the information so far presented?-----------

  18. And now, let me show you a few more prepared/common issues before we move into open discussion(Referring to prepared documents)

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