Common Permit by Rule Authorizations in Texas Joe Shine Air Permits Division Texas Commission on Environmental Quality Environmental Trade Fair 2014
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Common Permit by Rule Authorizations in Texas
Joe Shine
Air Permits Division
Texas Commission on Environmental Quality
Environmental Trade Fair 2014
Permit by Rule 106.A3168Alchemy
Definition - the ability to transform base metals into the noble metals (gold or silver)
Alchemy
Permit by Rule 106.A3168Alchemy
Rule language –
Equipment and facilities used for the process of alchemy is permitted by rule.
Today’s Topics
General Information About Using PBRs
Most Common PBRs
What to Include in the Application
New Processes
Using a PBR
Pros Other Considerations
No circumvention
No partial permitting
No customization
Lower fees
Faster response time
Quicker response time
Lower fees
Cannot customize – all or nothing
Cannot partially permit a process
Cannot circumvent permitting
Using a PBR
Claiming vs. Registering◦Claiming – Keep records to show compliance
with all rules and regulations
◦Registering – Submitting documentation to TCEQ and paying a fee
Certification vs. Registration◦PI-7
◦PI-7CERT or APD-CERT
Most Common PBRs
§106.433 – Surface Coating
§106.452 – Dry Abrasive Cleaning
§106.261/262 – Facilities
470 series – Tanks, Loading, Storage
140 Series – Aggregate & Pavement
§§106.352, 359, 492, 512 – Oil and Gas
Surface Coating
§106.433
Enclosed vs. non-enclosed surface coating
13 tpy VOC vs. 25 tpy VOC
Exempt solvents
Process MSS vs. non-process MSS
§106.433
MSDS: technical and air quality data
Calculations
◦Surface Coating Facilities Guide
◦Calculation Spreadsheet for Estimating Emissions
Chapter 115, Federal Standards, MSS
Dry Abrasive Cleaning
§106.452
Enclosed vs. non-enclosed
Blast media
Distance limits
Usage limits
MSS
Facilities
§106.261 and §106.262
Only use when there is not a more specific rule
Account for all upstream/downstream impacts
MSS
Represent all associated NSR Permits
Certify major sites
§106.261 and §106.262 Common Issues
Can you use current version of TLV?
Annual submittal ◦Easier, cheaper when prepared all together
◦We allow “portable” annual notifications if each site < 5 tpy
§106.261 and §106.262Limits
6 lb/hr & 10 tpy
1 lb/hr & 4.38 tpy
E=L/K
Net increase on new hour
Netting
Is it okay to exceed permitted allowable?
Tanks, Storage, and Loading
§106.470 - §106.478
Authorizes:
◦New construction
◦New service of existing tank
◦Change of service
Is “tank memo” still in effect?◦Using PBRs §106.261 and §106.262
Aggregate & Pavement
§106.141- §106.150
Calculations: AP-42 and throughput
Using engines?
§106.4(a)(4)
◦PM10 limit = 15 tpy
◦PM2.5 limit = 10 tpy
Include a project description
§106.141- §106.150
MSS: process vs. non-process
Include a plot plan
RFC (site review) required
Distance limitations
Oil and Gas Sites
Oil and Gas §106.352 - Oil and Gas Handling and
Production Facilities
§106.492 - Flares
§106.512 - Stationary Engines and Turbines
§106.359 - Planned Maintenance, Startup, and Shutdown (MSS) at Oil and Gas Handling and Production Facilities
PBR Options – Location
In Barnett Shale counties
• New – 30 TAC §106.352(a)-(k)
• Existing – 30 TAC §106.352(l)
Not in Barnett Shale counties
• New & existing – 30 TAC §106.352(l)
• May voluntarily register under §106.352 (a)-(k)
Barnett Shale Counties
§106.352(l)
§106.352 (l)◦Sweet:
No registration required, meet §106.4 limits, and keep records
◦Sour (> 24 ppm H2S): Registration required ¼ mile distance limit, 4.0 lb/hr limit of sulfur
compounds, vent height requirements
§106.352(a-k)
§106.352 (a-k)◦Notification and registration through ePermits
system
◦Notification - Prior to construction or implementation of changes
◦Registration Level 1 - Within 180 days from start of operation Level 2 - Within 90 days from start of operation
§106.492 and §106.512
§106.492◦May be used in combination with §106.352 (l)
◦May require certification
§106.512◦May be used in combination with §106.352(l)
◦Requires registration if > 240 hp
◦May require certification
Submitting
the
Application
Application Admin. Documents Preferred Order
Cover letter
Core Data Form
PI-7, PI-7-CERT, APD-CERT
Copy of check or ePay voucher
When Do I Need to Certify?
Emission limitations for Title V applicability
Federal applicability
Control/destruction efficiency claims
Operating hours
Application Technical Documents Preferred Order
Introduction Table of Contents Process and flow diagram Summary of emissions Emission calculations Impact analysis/NAAQS Applicability Lab analysis Maps Tables
Summary of Emissions
Application Technical Documents Preferred Order
Introduction Table of Contents Process and flow diagram Summary of emissions Emission calculations Impact analysis/NAAQS Applicability Lab analysis Maps Tables
Lab AnalysisSite Specific/Representative
Guidance at www.TexasOilandGasHelp.org
Three criteria◦Reservoir/formation
◦API gravity
◦Process/treatment
Application Technical Documents Preferred Order
Introduction Table of Contents Process and flow diagram Summary of emissions Emission calculations Impact analysis/ NAAQS Applicability Lab analysis Maps Tables
New Processes
and Changes
New Processesand
Changes
Enhanced Application Review (E.A.R.)
Purpose
E-mail notification ◦[email protected]
Expectations
Approval letter will be sent through e-mail unless specified otherwise.
Auto Deficiency
All Applications Oil & Gas Specific
Emissions Summary Table Gas and liquid analysis
Emission calculations/ documentation
Sour site < ¼ mile (for §106.352 (l) only)
RO signature matches (certifications only)
Flash calculations
Response to a VOID and not all issues addressed
NOX NAAQS compliance(§106.512 only)
Justification for DRE above default allowables
Begins 6/1/2014:
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