Subject: Texas Air Issues
From: [email-masked]
To: [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked]
Cc: [email-masked]
Date: Fri, 3 Nov 2000 01:39:00 -0800 (PST)

Notes from TXOGA and TCC committee meetings:

Operating Permits - TNRCC is attempting to obtain EPA approval of their Title 
V operating permit program by including Minor New Source Review (NSR) (e.g., 
permits by rule) in the operating permit program. The TNRCC idea is that you 
would make changes or install equipment under a permit by rule as you do now 
under current rules. When your Title V permit is renewed, all Minor NSR 
approvals would be rolled into the permit and included in the renewed permit. 
They are also putting together a General Operating Permit (GOP) that would 
include Minor NSR. It is unknown if EPA will buy this concept.

Upset and Maintenance - A general note: The TNRCC field offices are giving 
different answers to questions that have been asked by industry about the new 
upset and maintenance rules. 

When reporting upset emissions, TNRCC wants you to report all pollutants, not 
just the ones that exceeded the RQs;
It is important to give as much detail as possible on the cause of an upset. 
"Operator error" is not acceptable to TNRCC and may make it more likely you 
will be investigated by TNRCC if you repeatedly give this as a cause since it 
may appear to the agency that this is a repeat problem that a company is not 
correcting;
TNRCC's Region 12 (Houston Area) is conducting inspections at 20 facilities 
specifically directed at upset notifications. The inspections take about two 
days. Companies are inspected if they make too many upset notifications or 
too few.
When reporting a release of natural gas (unspeciated), you should exclude 
methane and ethane from the reporting and calculation of determining the 
5,000 pound threshold, but according to TNRCC you cannot exclude CO2 or N2;
If you do speciate a release, remember that heptane and nonane are not listed 
pollutants so they default to a 100 pound RQ.

New Source Review - TNRCC has lifted their hold on NSR permits in the Houston 
non-attainment area, but if there are too many permit applications between 
now and December 6 (to beat the new non-attainment regulations that should 
pass on December 6) there is a chance that they will put another hold on 
permits.

EPA Enforcement Priorities - EPA has proposed their enforcement priorities 
for Fiscal Year 2002-3 and they include "fuels management". Fuels management 
is broadly defined to include many industries and includes pipelines. It is 
not believed that this directive is aimed at gas pipelines, but it is broad 
enough to include them.