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Incorporation by Reference and Title V Permits

Dana Poppa Vermillion, P.E. Air Permits Division Texas Commission on Environmental Quality Advanced Air Permitting Seminar 2012. Incorporation by Reference and Title V Permits. Overview. EPA/TCEQ agreement Timeline New procedure. Incorporation by Reference (IBR).

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Incorporation by Reference and Title V Permits

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  1. Dana Poppa Vermillion, P.E. Air Permits Division Texas Commission on Environmental Quality Advanced Air Permitting Seminar 2012 Incorporation by Reference and Title V Permits

  2. Overview • EPA/TCEQ agreement • Timeline • New procedure

  3. Incorporation by Reference(IBR) • EPA wants Title V permits to include: • NSR emission limit • Monitoring, recordkeeping, and reporting • Major NSR Summary Table

  4. Current MAERT Table Headings Major NSR Summary Table

  5. Major NSR Summary Table • Three additional columns added to NSR permit MAERT • Monitoring/testing, recordkeeping, and reporting • Applicant will fill in table

  6. Major NSR Summary Table (cont.) • All EPNs from MAERT must be included • Include permit issuance date in header • Include all footnotes from MAERT • Include all PSD and NNSR permit numbers

  7. Major NSR Summary Table (cont.) • Submitted tables will be reviewed by APD staff • Table will be added to Appendix B of the Title V permit with a copy of the PSD/NNSR permit conditions and MAERT

  8. Timeline • 14 pending applications with IBR objections • Proposal - all initial, renewal, and significant revision applications received after October 1, 2012

  9. Timeline (cont.) • Pending applications if no PN by October 1 • All permits updated within five years • Applicants notified in renewal notice

  10. How Do You Fill Out the Table? • Sources • Thermal oxidizer • Fugitives • 3 storage tanks – internal floating roof • Conditions • SC 2 - NSPS Kb • SC 3 – Storage Tanks (boilerplate) • SC 4 - Stack test (boilerplate) • SC 5 - Temperature monitoring – continuous • SC 6 - CEM • SC 7 - 28 VHP

  11. Current MAERT Table Headings Major NSR Summary Table

  12. Major NSR Summary Table (cont.)

  13. Major NSR Summary Table (cont.)

  14. Major NSR Summary Table (cont.)

  15. Common Errors • Include federal applicability conditions (NSPS, NESHAP, MACT) • Don’t need to include paragraph designations or text with condition number • Include stack testing condition in all three columns, not just in Monitoring/Testing • Include stack test condition, even if testing is complete

  16. Common Errors(cont.) • Watch for implied recordkeeping – if you have to report or notify regarding data, you have to record the data, even if records aren’t mentioned • Watch for indirect monitoring or recordkeeping for a source

  17. Example • Condition requires annual leak checking of tank cars • Basis for collection efficiency • Affects emission rate for loading rack and loading fugitives

  18. Example(cont.) • Indirect testing of loading rack • Include in the Monitoring/Testing and Recordkeeping columns for the loading rack

  19. Correspondence A copy of the TCEQ letter to EPA may be found at: http://www.tceq.texas.gov/assets/public/permitting/air/Announcements/toepa-07-27-12.pdf

  20. Contact Contact Information— • Dana Poppa Vermillion • (512) 239-1280 • dana.poppa-vermillion@tceq.texas.gov

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