Environmental Permitting Updates: Autumn Conference Highlights
Title V Update
Carolyn Maus, P.E.
Technical Specialist, Air Permits Division
Autumn Environmental Conference and Expo
October 9, 2019
Presentation Outline
•
Regulatory news
•
PBRs in Title V permits (FOPs)
•
Major NSR Summary Table format and review
•
PM and CAM review tips
Regulatory News
•
HGB and DFW areas reclassified as serious
nonattainment for 2008 ozone NAAQS:
–
Effective 9/23/19
–
Title V major source threshold for NO
x
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
PBRs in FOPs
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
PBR Supplemental Table
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)
…
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].
FOP Display of Registration Numbers
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.
Major NSR
Summary
Tables
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
Change to Format for Special Conditions
References to NSR Applications
•
If MRRT in NSR application:
–
Project number,
–
Issuance date, and
–
Application page number
•
Include copy of application
page
PM and CAM
Review Tips
Monitoring Applicability Criteria
Monitoring
Frequency
•
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
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
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
PM/CAM Example Pt. 1
•
Continuous process vent with direct flame incinerator
•
Is PM needed?
PM/CAM Example Pt. 2
•
Continuous process vent with absorber
•
Is PM needed?
PM/CAM Example Pt. 3
•
Continuous process vent with direct flame incinerator
•
Meets criteria for large CAM unit – add CAM?
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
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
Carolyn Maus, a Technical Specialist in the Air Permits Division, presented key updates at the Autumn Environmental Conference and Expo on October 9, 2019. The presentation covered regulatory news, PBRs in Title V permits, major NSR summaries, and tips for PM and CAM reviews. Important changes in the classification of HGB and DFW areas as serious nonattainment for 2008 ozone NAAQS were discussed, along with updates on NOx and VOC thresholds. The talk also emphasized providing additional PBR information and compliance requirements related to PBR Supplemental Tables.
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Presentation Transcript
Title V Update Carolyn Maus, P.E. Technical Specialist, Air Permits Division Autumn Environmental Conference and Expo October 9, 2019
Presentation Outline Regulatory news PBRs in Title V permits (FOPs) Major NSR Summary Table format and review PM and CAM review tips
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
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
PBR Supplemental Table Registered PBRs Registration No. PBR Number Registration Date Claimed (not registered) PBRs from OP-REQ1 PBR Number Version No./Date Claimed (not registered) PBRs not listed on OP-REQ1 PBR Number Version No./Date
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)
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].
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
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.
Major NSR Summary Tables
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
Change to Format for Special Conditions Special Conditions/ Application Info Air lbs/hour TPY Contaminant CO 36.80 13.80 6, 7, 31 NOx 18.20 6.40
References to NSR Applications If MRRT in NSR application: Special Conditions/ Application Info. Project number, Issuance date, and Proj: XXXX, mm/dd/year, page QQQ Application page number Include copy of application page
PM and CAM Review Tips
Monitoring Applicability Criteria PM CAM Emission limit/standard Emission limit/standard Control device Major pre-control
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
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
Monitoring for Multiple Emission Limits CAM for VOC 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 Rule A Rule B Rule C
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
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 Lacks Satisfies PM frequency needs PM
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 Lacks min. frequency for large CAM Satisfies CAM
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
Contact Information Carolyn Maus, P.E. Phone: Email: (512) 239-6204 carolyn.maus@tceq.texas.gov General Phone: Email: (512) 239-1250 airperm@tceq.texas.gov
