Environmental Permitting Updates: Autumn Conference Highlights

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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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  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 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

  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 Special Conditions/ Application Info Air lbs/hour TPY Contaminant CO 36.80 13.80 6, 7, 31 NOx 18.20 6.40

  14. 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

  15. PM and CAM Review 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 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

  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 Lacks Satisfies PM 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 Lacks min. frequency for large CAM Satisfies 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: Email: (512) 239-6204 carolyn.maus@tceq.texas.gov General Phone: Email: (512) 239-1250 airperm@tceq.texas.gov

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