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Common Permit by Rule Authorizations in Texas

Common Permit by Rule Authorizations in Texas. Joe Shine Air Permits Division Texas Commission on Environmental Quality Environmental Trade Fair 2014. Permit by Rule 106.A3168 Alchemy. Definition - the ability to transform base metals into the noble metals ( gold or silver ). Alchemy.

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Common Permit by Rule Authorizations in Texas

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  1. Common Permit by Rule Authorizations in Texas Joe Shine Air Permits Division Texas Commission on Environmental Quality Environmental Trade Fair 2014
  2. Permit by Rule 106.A3168Alchemy Definition - the ability to transform base metals into the noble metals (gold or silver)
  3. Alchemy
  4. Permit by Rule 106.A3168Alchemy Rule language – Equipment and facilities used for the process of alchemy is permitted by rule.
  5. Today’s Topics General Information About Using PBRs Most Common PBRs What to Include in the Application New Processes
  6. Using a PBR Quicker response time Lower fees Cannot customize – all or nothing Cannot partially permit a process Cannot circumvent permitting
  7. Using a PBR Claiming vs. Registering Claiming – Keep records to show compliance with all rules and regulations Registering – Submitting documentation to TCEQ and paying a fee Certification vs. Registration PI-7 PI-7CERT or APD-CERT
  8. Most Common PBRs §106.433 – Surface Coating §106.452 – Dry Abrasive Cleaning §106.261/262 – Facilities 470 series – Tanks, Loading, Storage 140 Series – Aggregate & Pavement §§106.352, 359, 492, 512 – Oil and Gas
  9. Surface Coating
  10. §106.433 Enclosed vs. non-enclosed surface coating 13 tpy VOC vs. 25 tpy VOC Exempt solvents Process MSS vs. non-process MSS
  11. §106.433 MSDS: technical and air quality data Calculations Surface Coating Facilities Guide Calculation Spreadsheet for Estimating Emissions Chapter 115, Federal Standards, MSS
  12. Dry Abrasive Cleaning
  13. §106.452 Enclosed vs. non-enclosed Blast media Distance limits Usage limits MSS
  14. Facilities
  15. §106.261 and §106.262 Only use when there is nota more specific rule Account for all upstream/downstream impacts MSS Represent all associated NSR Permits Certify major sites
  16. §106.261 and §106.262 Common Issues Can you use current version of TLV? Annual submittal Easier, cheaper when prepared all together We allow “portable” annual notifications if each site < 5 tpy
  17. §106.261 and §106.262Limits 6 lb/hr & 10 tpy 1 lb/hr & 4.38 tpy E=L/K Net increase on new hour Netting Is it okay to exceed permitted allowable?
  18. Tanks, Storage, and Loading
  19. §106.470 - §106.478 Authorizes: New construction New service of existing tank Change of service Is “tank memo” still in effect? Using PBRs §106.261 and §106.262
  20. Aggregate & Pavement
  21. §106.141- §106.150 Calculations: AP-42 and throughput Using engines? §106.4(a)(4) PM10 limit = 15 tpy PM2.5 limit = 10 tpy Include a project description
  22. §106.141- §106.150 MSS: process vs. non-process Include a plot plan RFC (site review) required Distance limitations
  23. Oil and Gas Sites
  24. Oil and Gas §106.352 - Oil and Gas Handling and Production Facilities §106.492 - Flares §106.512 - Stationary Engines and Turbines §106.359 - Planned Maintenance, Startup, and Shutdown (MSS) at Oil and Gas Handling and Production Facilities
  25. PBR Options – Location
  26. Barnett Shale Counties
  27. §106.352(l) §106.352 (l) Sweet: No registration required, meet §106.4 limits, and keep records Sour (> 24 ppm H2S): Registration required ¼ mile distance limit, 4.0 lb/hr limit of sulfur compounds, vent height requirements
  28. §106.352(a-k) §106.352 (a-k) Notification and registration through ePermits system Notification - Prior to construction or implementation of changes Registration Level 1 - Within 180 days from start of operation Level 2 - Within 90 days from start of operation
  29. §106.492 and §106.512 §106.492 May be used in combination with §106.352 (l) May require certification §106.512 May be used in combination with §106.352(l) Requires registration if > 240 hp May require certification
  30. Submitting the Application
  31. Application Admin. Documents Preferred Order Cover letter Core Data Form PI-7, PI-7-CERT, APD-CERT Copy of check or ePay voucher
  32. When Do I Need to Certify? Emission limitations for Title V applicability Federal applicability Control/destruction efficiency claims Operating hours
  33. Application Technical Documents Preferred Order Introduction Table of Contents Process and flow diagram Summary of emissions Emission calculations Impact analysis/NAAQS Applicability Lab analysis Maps Tables
  34. Summary of Emissions
  35. Application Technical Documents Preferred Order Introduction Table of Contents Process and flow diagram Summary of emissions Emission calculations Impact analysis/NAAQS Applicability Lab analysis Maps Tables
  36. Lab AnalysisSite Specific/Representative Guidance at www.TexasOilandGasHelp.org Three criteria Reservoir/formation API gravity Process/treatment
  37. Application Technical Documents Preferred Order Introduction Table of Contents Process and flow diagram Summary of emissions Emission calculations Impact analysis/ NAAQS Applicability Lab analysis Maps Tables
  38. New Processes and Changes New Processes and Changes
  39. Enhanced Application Review (E.A.R.) Purpose E-mail notification airog@tceq.texas.gov Expectations Approval letter will be sent through e-mail unless specified otherwise.
  40. Auto Deficiency Begins 6/1/2014:
  41. Questions? airog@tceq.texas.gov Air Permits main line: (512) 239-1250
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