1 / 18

Updating Title V Post Permit Forms

Updating Title V Post Permit Forms. Joseph A. Janecka, P.E., Air Program Liaison Field Operations Support Division TCEQ. What Forms? You ask. Permit Compliance Certification – “PCC”: also sometimes referred to as “Annual Compliance Certification.” Supports Chapter 122, §122.146.

kynton
Télécharger la présentation

Updating Title V Post Permit Forms

An Image/Link below is provided (as is) to download presentation Download Policy: Content on the Website is provided to you AS IS for your information and personal use and may not be sold / licensed / shared on other websites without getting consent from its author. Content is provided to you AS IS for your information and personal use only. Download presentation by click this link. While downloading, if for some reason you are not able to download a presentation, the publisher may have deleted the file from their server. During download, if you can't get a presentation, the file might be deleted by the publisher.

E N D

Presentation Transcript

  1. Updating Title V Post Permit Forms Joseph A. Janecka, P.E., Air Program Liaison Field Operations Support Division TCEQ

  2. What Forms? You ask • Permit Compliance Certification – “PCC”: also sometimes referred to as “Annual Compliance Certification.” Supports Chapter 122, §122.146. • Semiannual Deviation Report – “DevRpt”: Supports Chapter 122, §122.145.

  3. Plan for Update • Current needs identified - complete • Management approval - complete • Schedule for completion: Goal – 2008 Trade Fair • Public Participation: Stakeholder meetings Austin March 13, Houston March 19, Midland April 1

  4. Update Needs Currently Identified • Typos, Reference to “TNRCC”, “DRAFT” watermark, etc. • Incorporate Central Registry Requirements • Restructure to mimic Air Permits Division (APD) application forms • Relocate web site links and information from APD to Office of Compliance and Enforcement (OCE) Field Operations web page

  5. Current Update Needs (cont’d) • Ensure compliance with the Agency’s forms procedures • Ability to refer to reportable emissions events quickly and efficiently • Provide for credible evidence • Explore the need for CAIR and CAMR certifications • Request copy of DevRep to US EPA

  6. New Look – But Familiar Look • Restructure the forms to that similar to Air Operating Permits applications: • Form • Instructions • Guidance • Forms and Instructions are managed and subject to Agency forms policy and procedure. Guidance is not.

  7. Other Updates Needs • Expand the breadth and depth of examples in guidance: • Make sure what we have is current • Include more examples that best explain questions that have arisen since the older forms versions

  8. And Finally… • Discuss and develop a process to minimize time between form updates, if needed • Promote a better understanding between regulated entities, Field Operations, and other stakeholders on how these forms are used.

  9. Emission Events • Definition: Emissions event--Any upset event or unscheduled maintenance, startup, or shutdown activity, from a common cause that results in unauthorized emissions of air contaminants from one or more emissions points at a regulated entity. • Therefore: All emissions events ARE deviations.

  10. How Compliance Certification Periods May Vary • Compliance Certifications at least every 12 months • Certifications must be continuous. • Compliance period start date defined by one of three events: • Initial Permit issuance date • End of previous compliance period • Change of Ownership: Purchaser

  11. How Compliance Certification Periods May Vary • Compliance period end date defined by earliest of three events: • 12 months since last compliance certification • Change of ownership: Seller • Void Permit • Or, the permit holder may define a shorter period voluntarily

  12. How Compliance Certification Periods May Vary • The Compliance Certification submission deadline is based on the end date of the reporting period. Not 12 months.

  13. Recent Guidance: Deviations • How to document the following examples of “continuous” non-compliance: • Exceedance of permit emission allowables • Construction and/or operation without authorization • Enter one line, include start date/time and end date/time. • Enter Number of deviations = 1

  14. Recent Guidance: Deviations • Question: What would be considered “reasonable inquiry” for discovery or use of credible evidence (by the permit holder)? • Please note we are merely providing examples of reasonable inquiry, but not completely defining the term.

  15. Credible Evidence through Reasonable Inquiry • Answer 1 - Multiple rules for same unit and pollutant/requirement: • A deviation for the same unit and pollutant, where the measured exceedance, lack of required work practice, or unauthorized or prohibited activities or operations in one rule that would constitute a deviation of another rule.

  16. Credible Evidence through Reasonable Inquiry • Answer 2 - Emission events at same unit and pollutant, including cause: • Any emission event resulting in a measured exceedance, or indicative of a lack of required work practice, or unauthorized or prohibited activities or operations would constitute a deviation of rule for the same unit and pollutant.

  17. Questions on any of the information so far presented?-----------

  18. And now, let me show you a few more prepared/common issues before we move into open discussion(Referring to prepared documents)

More Related