Title V Site Operating Permit (SOP)

Initial Application Review

Carolyn MausAir Permits Division

Texas Commission on Environmental QualityEnvironmental Trade Fair 2012

SOP Review• Preliminary Procedures• Technical Review• Resolving Deficiencies• Working Draft Permit• Public Notice/EPA Review• Final State Action (Permit

Issuance)

Preliminary Procedures• Review application for

completeness• Review site information• Review process description and

process flow diagram• Inform applicant that application

review has begun

OP-1

OP-CRO1

Technical Review• Review NSR related permit

information• Compare emission units on OP-SUM

to emission units on plot plan• Review application forms for

technical content and completeness OP-REQ1 OP-SUM OP-UA forms OP-REQ2

OP-REQ1

Texas Administrative Code (TAC)

OP-REQ2

Technical Review

• Review permit shield requests• Review PM/CAM requirements• Review OP-ACPS for compliance

issues• Review compliance history

Resolving Deficiencies

• A list of deficiencies is sent by e-mail or letter

• Review response• Goal: sufficient information to

complete review

Working Draft Permit (WDP)• General Terms & Conditions• Special Terms & Conditions• Attachments

Unit Summary Applicable Requirements Summary Additional Monitoring Permit Shield NSR Authorization References Compliance Schedule

• Applicant review of WDP 30-day deadline to submit comments Show changes on forms or WDP pages

as needed Clearly indicate new, revised, or deleted

data

• Certify updates prior to public notice

Working Draft Permit (WDP)

Public Notice• Public notice authorization package

sent containing: Letter with detailed instructions Notice and sign posting templates Publisher’s affidavit forms Draft permit Statement of Basis

Public Notice• Publication required within 30 days of

the letter’s date• Verify public notice was executed

Receipt of newspaper tear sheets Receipt of publisher’s affidavit(s) Receipt of public notice certification

• Respond to comments or hearing requests

• Schedule public hearing if necessary

Affidavit of Publication

• Site’s nearest city: Springlake (Form OP-1)

• Will the Chief Clerk accept this form?

The Office of the Chief Clerk will check whether this line includes the city (municipality) nearest to the site. If it does not, the applicant will be contacted to provide further information.

Public Notice Verification

• Site submitted tear sheet and affidavit for Spanish publication in La Informacion.

• Why is this form incorrect?

The site did find a newspaper, so this should be No.

A newspaper should only be entered here if its publishers refused to publish the notice.

EPA Review• Runs concurrently with public notice

period• 45-day review period• Review period stops if comments

received Another EPA review period begins after

comments are addressed

Final State Action• Permit is issued after EPA review

period• 60-day public petition period extends

after EPA review period EPA may receive valid petition TCEQ will resolve objections Permit may be modified accordingly

Site Operating Permit (SOP) Renewals, Revisions, and

Notifications

Whitney HillAir Permits Division

Texas Commission on Environmental QualityEnvironmental Trade Fair 2012

OverviewSubmittal and Application

Requirements for:

• Renewals• Notifications• Administrative Revisions• Minor Revisions• Significant Revisions

SOP Renewals• 30 TAC Chapter 122, Subchapter C,

Division 4• Timeline

Five-year permit term (unless otherwise noted)

12-month renewal notification Application due 6 - 18 months before

expiration

SOP RenewalsRequired Application

Forms OP-2 OP-CRO1 OP-ACPS OP-1 OP-REQ1

Potentially Required Forms

OP-SUMR OP-UAs OP-MON OP-REQ2 OP-REQ3 Acid Rain/CAIR

OP-AR1OP-SUM (Table 2)

SOP Renewals• General requirements

Incorporate changes claimed under notifications

Include all revisions Evaluate CAM and PM Use updated forms Significant revisions may not be

operated until renewal is issued Public notice, EPA review, public petition

SOP Revisions/Notifications

• 30 TAC Chapter 122, Subchapter C, Division 2

• Review TCEQ EPA The public

• Purpose is to maintain current applicable requirements

SOP Notifications• Qualification criteria

No FCAA Title I modifications No increase in any NSR permit limits Pre-construction authorization obtained

• General requirements No public notice/announcement, EPA

review, or public petition Incorporate into permit at renewal

SOP Notification Types• Off-permit changes

Adding applicable requirements resulting from changes at the site

Adding a unit authorized by new PBR or standard permit

Adding a new PBR or standard permit

• Operational flexibility Removing unit Modifying existing applicable requirements Decreasing NSR permit emission limits

SOP Notification Requirements

• Submit notification before operating the proposed change Off-permit Operational flexibility

• Form OP-Notify• Certification by RO or DAR• Maintain notice with permit

Example Notifications

• Change of tank service covered under 261/262. Notification required?

Yes

• Change of tank service to a lower VP compound, covered under 261/262 with 30 TAC Chapter 115 applicability. Notification required? Yes

Example Notifications• Adding PBR that was

authorized before permit was issued. Notification required? No

• A notification is submitted after the change has occurred. Notification required? No

SOP Revisions• Types of SOP revisions

Administrative Minor Significant

• Application review

Administrative Revision• Qualification criteria

Typographical errors Increase monitoring/reporting Change in identification of permit holder Similar EPA-approved changes

• Application timeline Due no later than 30 days after the

permit anniversary No public notice and EPA review

Administrative Revision• Required application forms

OP-2 OP-CRO1

• Potentially required forms OP-1 OP-REQ1 OP-REQ3 Core Data Form, TCEQ Form Number

20405 (Change of Name/Ownership Form)

Minor Revision• Qualification criteria

No applicable requirements violated No significant changes to monitoring,

recordkeeping, or reporting No case-by-case determination of emission

limitation or standard No FCAA Title I modification (PSD or NA)

Minor Revision• Application timeline

Submit before change is operated Public announcement and EPA review

• Application requirements Submit provisional terms and conditions

to operate change before approval Comply with new requirements

Minor Revision• Required application

forms OP-2 OP-CRO1

• Potentially required forms OP-1 OP-SUMR OP-UA OP-REQ1

OP-REQ2 OP-REQ3 OP-MON

Minor Revision Examples• Addition of newly promulgated

applicable requirements

• Addition or removal of unit and applicable requirements

• Change in minor NSR allowable emissions

• Removal of permit shield

Significant Revision• Qualification criteria

Does not qualify as admin. or minor revision

Significant changes to monitoring Relaxation of reporting or recordkeeping Addition/modification of permit shield

• Application timeline SOP revised before operating change PN, EPA review, and public petition

Significant Revision• Required application forms

OP-2 OP-CRO1

• Potentially required forms OP-1 OP-SUMR OP-UA OP-REQ1

OP-REQ2OP-REQ3OP-MON

Significant Revision Examples

• PSD or NA modification

• Change in compliance plans

• Addition of acid rain permit

• Significant change to monitoring requirement

• 112(j) applications

Example Revisions• An FCCU with PM for NSPS J is

changing opacity monitoring from COMS to Method 9. Revision type? Significant revision

• Company Name ABC is changing its name to ABC, Inc. Revision type? Administrative revision

Example Revisions• A site has a throughput increase in NSR that does not

result in a major modification. A revision is submitted to incorporate the NSR amendment. Revision type? Minor revision

• Adding an NSR authorized tank to an SOP with NSPS Ka requirements and a permit shield for NSPS Kb. Revision type? Significant revision

Example Revisions

• Consolidating one SOP application area into another involving addition of units with no permit shield or case-by-case emission limit. Revision type? Minor revision

• Adding an NSR authorized tank with applicable NSPS Ka requirements to an SOP. Revision type?

Minor revision

SOP Reviewer Procedures

• APD permit revision review policies PBR effective dates Scope of revision Expected timeline of review

SOP Guidance

• TCEQ Memos

• Additional FOP Guidance

Submitting SOP ApplicationsPlease mail all permit initial, revision,

notification, and renewal applications to the following address:

Texas Commission on Environmental QualityAir Permits Initial Review Team (APIRT), MC

161P.O. Box 13087

Austin, TX 78711-3087

Copies of applications and updates must be mailed to the appropriate TCEQ regional

office.

Submitting SOP ApplicationsPlease send updates to permit applications under review to the

following address:

Name of Assigned Permit ReviewerTexas Commission on Environmental Quality

Air Permits Division, MC 163P.O. Box 13087

Austin, TX 78711-3087

Submitting SOP ApplicationsSubmit applications on a readable compact

disk (CD) to the following EPA Region 6 office address:

Air Permits Section (6PD-R)Environmental Protection Agency, Region 6

1445 Ross Avenue, Suite 1200Dallas, Texas 75202-2733

Submit application updates to EPA at R6AirPermits@EPA.gov. Identify the associated permit number when submitting information.

Title V SOPInitial, Renewal, and

Revision Applications and Notifications Questions?

Air Permits Division(512) 239-1250