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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 Quality Environmental Trade Fair 2014. Overview. Review of an Initial SOP Application Renewals Notifications Revisions Administrative Minor

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Title V Site Operating Permits (SOPs), Revisions, and Renewals

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  1. Title V Site Operating Permits (SOPs), Revisions, and Renewals Carolyn Maus, P.E. Air Permits Division Texas Commission on Environmental Quality Environmental Trade Fair 2014

  2. Overview • Review of an Initial SOP Application • Renewals • Notifications • Revisions • Administrative • Minor • Significant

  3. Initial SOP Review Process Final State Action Public Notice/EPA Review Working Draft Permit Resolving Deficiencies Technical Review Preliminary Procedures

  4. Preliminary Procedures The permit reviewer will: • Check application for completeness • Review OP-1 information • Review site operations • Inform applicant that review has begun • Preliminary Procedures

  5. OP-1 Ralph Furley is entered as the RO OP-CRO1 Ralph Furley signed this form as the DAR

  6. 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 • Preliminary Procedures

  7. Major NSR Summary Table Special Condition numbers that contain requirements for the EPN Contents of current MAERT

  8. OP-REQ1 Include the correct issuance dates for NSR authorizations.

  9. 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

  10. Technical Review The 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 • Preliminary Procedures

  11. OP-REQ2 Lacks information Shows that all exemption criteria are met

  12. Technical Review The permit reviewer will review: • Permit shield requests • OP-ACPS • Compliance history • PM/CAM requirements • Technical Review • Preliminary Procedures

  13. 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 • Preliminary Procedures

  14. 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 regulations • Technical Review • Preliminary Procedures

  15. Resolving Deficiencies The permit reviewer will: • Send a list of deficiencies • Review applicant responses • Request additional information if needed • Resolving Deficiencies • Technical Review • Preliminary Procedures

  16. Working Draft Permit • Working Draft Permit • Resolving Deficiencies • 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 • Preliminary Procedures

  17. Public Notice • Public Notice/EPA Review • Working Draft Permit • Resolving Deficiencies • Technical Review • The permit reviewer will mail the public notice authorization package (PNAP) to the applicant. • PNAP contents • Letter • Templates • Forms • Links • Preliminary Procedures

  18. Public Notice • Public Notice/EPA Review • Working Draft Permit • Resolving Deficiencies • Technical Review The 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 • Preliminary Procedures

  19. Public Notice • Public Notice/EPA Review • Working Draft Permit • Resolving Deficiencies • Technical Review The permit reviewer will: • Verify that the applicant executed public notice correctly • Respond to comments or hearing requests • Schedule public hearings if necessary • Preliminary Procedures

  20. Affidavit of Publication 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. • Site’s nearest city: Springlake (Form OP-1) • Will the Chief Clerk accept this form?

  21. EPA Review • Public Notice/EPA Review • Working Draft Permit • Resolving Deficiencies • Technical 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 • Preliminary Procedures

  22. Final State Action Final State Action • Public Notice/EPA Review • Working Draft Permit • Resolving Deficiencies • Technical Review • 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 • Preliminary Procedures

  23. SOP Renewal Timeline TCEQ sends renewal notification Permit issued Permit expiration Application due (6-18 months before expiration) Five year permit term (unless otherwise noted)

  24. Renewals Significant revisions may not be operated until renewal is issued 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 Incorporate changes under notifications Include all revisions General Policies and Procedures Use updated forms Evaluate PM and CAM Public notice, EPA review, public petition

  25. SOP Revisions/Notifications • Review • TCEQ • EPA • The public • Purpose is to maintain current applicable requirements

  26. 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 authorizationwas obtained

  27. 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.

  28. 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

  29. 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

  30. 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

  31. SOP Revisions • Revision types • Administrative • Minor • Significant • Application contents • Describe each change • Identify affected emission units • Use appropriate TCEQ forms

  32. 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

  33. 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)

  34. 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

  35. 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

  36. 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

  37. Significant Revision Examples • PSD or NA modification • Change in compliance plans • Addition of acid rain permit • Significant change to monitoring requirements • 112(j) applications

  38. 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

  39. Example Revisions • Throughput increase in NSR • Does not result in a major modification • Revision to incorporate NSR amendment • Revision type? • Minor revision

  40. Revision Review Policies The permit reviewer will: • Verify PBR effective dates • Address errors/omissions unrelated to the requested revision if appropriate • Combine multiple revision applications into one project if appropriate

  41. Guidance • TCEQ Memos • Additional FOP Guidance

  42. 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.

  43. 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

  44. 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: R6AirPermits@EPA.gov • Identify the permit number

  45. Questions? Air Permits Division (512) 239-1250

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