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Title V Update

This presentation covers regulatory news, PBRs in Title V permits, major NSR summary, and PM and CAM review tips.

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Title V Update

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  1. Title V Update Carolyn Maus, P.E. Technical Specialist, Air Permits Division Autumn Environmental Conference and Expo October 9, 2019

  2. Presentation Outline • Regulatory news • PBRs in Title V permits (FOPs) • Major NSR Summary Table format and review • PM and CAM review tips

  3. Regulatory News • HGB and DFW areas reclassified as serious nonattainment for 2008 ozone NAAQS: • Effective 9/23/19 • Title V major source threshold for NOx and VOC now 50 tpy • Initial FOP applications due 9/23/20 • Proposed revisions to state rules as a result: • 30 TAC Chapter 115 for Wise County • 30 TAC Chapter 117 for Wise County

  4. PBRs in FOPs

  5. Providing Additional PBR Information • Applicants may opt to submit: • Registration numbers for registered PBRs • PBRs claimed that were not required to be listed on Form OP-REQ1 • Data can be provided on PBR Supplemental Table • Reference to that table is added to FOP and SOB • PBR registration numbers are added to permit

  6. PBR Supplemental Table

  7. FOP Reference to PBR Supplemental Table Permit holder shall comply with the requirements of New Source Review authorizations issued or claimed by the permit holder for the permitted area, including permits, permits by rule (including the permits by rule identified in the PBR Supplemental Tables in the application)…

  8. SOB Reference to PBR Supplemental Table The application for this project contains a list of PBRs, that are not listed on the OP-REQ1 form, that are also claimed for this permit area. This list is found on the table titled PBR Supplemental Table. These PBRs are enforceable through permit condition number [FOP-specific condition number].

  9. FOP Display of Registration Numbers PBR Unit Name Unit ID T100 VOC TANK 100 106.472/09/04/2000 PBR registration number is added to this cell

  10. Footnote for NSR References Table in FOP **This column may include Permit by Rule (PBR) numbers and version dates, PBR or Standard Permit Registration numbers in brackets, Minor NSR permit numbers, and Major NSR permit numbers.

  11. Major NSR Summary Tables

  12. Submittal and Review Procedures • Indicate in application cover letter that Major NSR Summary Table is being added or revised • Permit reviewer will email table to applicant • Applicant will complete MRRT columns and email back to reviewer • Refer to instructions on TCEQ website

  13. Change to Format for Special Conditions

  14. References to NSR Applications • If MRRT in NSR application: • Project number, • Issuance date, and • Application page number • Include copy of application page

  15. PM and CAMReview Tips

  16. Monitoring Applicability Criteria PM CAM Emission limit/standard Emission limit/standard Control device Major pre-control

  17. MonitoringFrequency • PM – at least annual • CAM – once per day for small CAM units, four times per hour for large CAM units • “Continuous” may not be specific enough for CAM • May monitor multiple parameters if one is not frequent enough

  18. Providing Justification • Deviation limits and case-by-case monitoring must have supporting information, such as: • Performance test data, • Manufacturer’s recommendations, • Engineering calculations, or • Historical data • See OP-MON instructions and CAM/PM guidance documents

  19. Monitoring for Multiple Emission Limits • Rule-by-rule • Pollutant-by-pollutant • May use same PM/CAM for multiple rules • May use language from rule with sufficient monitoring in PM/CAM proposal CAM for VOC Rule A Rule B Rule C

  20. PM/CAM Example Pt. 1 • Continuous process vent with direct flame incinerator • Is PM needed? MACT FFFF Chap. 115 Proposed after 11/15/90 Continuous temperature monitoring Satisfies PM Satisfies PM

  21. PM/CAM Example Pt. 2 • Continuous process vent with absorber • Is PM needed? MACT FFFF Chap. 115 Proposed after 11/15/90 • Records of parameters Satisfies PM • Lacks frequency – needs PM

  22. PM/CAM Example Pt. 3 • Continuous process vent with direct flame incinerator • Meets criteria for large CAM unit – add CAM? MACT FFFF Chap. 115 Proposed after 11/15/90 Continuous temperature monitoring Satisfies CAM Lacks min. frequency for large CAM

  23. Summary • PBRs in Title V permits • Applicants may opt to submit PBR registration numbers and PBRs not listed on Form OP-REQ1 • FOP and SOB will be modified accordingly • Major NSR Summary Tables • Application should mention need to add/revise table • Review latest guidance on TCEQ website • PM/CAM • Check rule for frequency as well as monitoring • Justify case-by-case and deviation limits

  24. Contact Information Carolyn Maus, P.E. Phone: (512) 239-6204 Email: carolyn.maus@tceq.texas.gov General Phone: (512) 239-1250 Email: airperm@tceq.texas.gov

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