Common Permit by Rule Authorizations in Texas

Joe ShineAir Permits Division

Texas Commission on Environmental QualityEnvironmental 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 ◦airog@tceq.texas.gov

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:

Questions?

airog@tceq.texas.gov

Air Permits main line: (512) 239-1250