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Compliance and Enforcement: Investigation Overview. Cynthia Gandee Air Program Liaison Field Operations Program Support Team Office of Compliance and Enforcement Texas Commission on Environmental Quality. Today’s Topics. Investigation Overview Hot Issues by Investigation Type

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compliance and enforcement investigation overview

Compliance and Enforcement: Investigation Overview

Cynthia Gandee

Air Program Liaison

Field Operations Program Support Team

Office of Compliance and Enforcement

Texas Commission on Environmental Quality

today s topics
Today’s Topics
  • Investigation Overview
  • Hot Issues by Investigation Type
  • Guidance Documents and Resources
  • Contact Information

Advanced Air Permitting Seminar – October 2014

investigation overview
Investigation Overview

Announced*

Unannounced

Complaints

Fence line observations

  • Routine compliance onsite investigations
  • In-house investigations
  • Emissions events
  • Stack testing
  • *Facilities with a unsatisfactory
  • compliance history rating may
  • not receive notice

Reference: RG-457 and TCEQ Webpage

Advanced Air Permitting Seminar – October 2014

what to expect
What to Expect
  • Initial contact: records request
  • Onsite investigation
  • Initial exit interview
  • Follow-up questions
  • Final exit interview
  • Letter

Advanced Air Permitting Seminar – October 2014

typical investigation timeframe
Typical Investigation Timeframe

Advanced Air Permitting Seminar – October 2014

records
Records
  • All permits have a general recordkeeping requirement:
    • 30 TAC 106.8(c)(2)
    • 30 TAC 116.115(b)(E)
    • 30 TAC 122.144
  • Be prepared to demonstrate compliance

Advanced Air Permitting Seminar – October 2014

top 10 violations previous 5 years
Top 10 Violations: Previous 5 Years

1) THSC 382.085(b) was cited 12,113 times in conjunction with applicable state and federal rules. 2) 30 TAC 122.143(4) was cited 6,947 times for failing to comply with the standard terms and conditions of a Federal Operating Permit. 3) 30 TAC 116.115(c) was cited 4,596 times for failing to comply with a special condition on an NSR permit. 4) 30 TAC 101.20(3) was cited 819 times for failing to comply with an EPA standard. 5) 30 TAC 116.715(a) was cited 803 times for failing to comply with an NSR flexible permit. 6) 30 TAC 116.110(a) was cited 742 times for failing to obtain authorization prior to construction. 7) 30 TAC 111.201 was cited 591 times for outdoor burning. 8) 30 TAC 122.145(2)(A) was cited 584 times for deviation reporting issues 9) 30 TAC 116.115(b)(2)(F) was cited 550 times for failing to comply with a Maximum Allowable Emission Rates Table. 10) 30 TAC 122.146(2) was cited 388 times for Permit Compliance Certification issues.

Advanced Air Permitting Seminar – October 2014

hot issues for permit investigations
Hot Issues forPermit Investigations
  • Permit applications
  • Reporting errors

Advanced Air Permitting Seminar – October 2014

application errors
Application Errors
  • Omissions:
    • Units
    • Rules:
      • Decision

Support

System

Advanced Air Permitting Seminar – October 2014

reporting errors
Reporting Errors
  • OP-CRO1 Form
  • Deviation report parts:
    • Dates
    • Misuse of Part 2 on DR

Advanced Air Permitting Seminar – October 2014

reporting errors1
Reporting Errors

Advanced Air Permitting Seminar – October 2014

title v resources
Title V Resources
  • Title V Guidance
  • DR Guidance

Advanced Air Permitting Seminar – October 2014

hot issues for ee
Hot Issues for EE
  • EE vs. MSS boundaries
  • STEERS vs. DR

Advanced Air Permitting Seminar – October 2014

hot issues for stack testing
Hot Issues for Stack Testing
  • Common violations:
    • Notification
    • Reports submittal
  • Review stack test conditions in draft permits:
    • Methods, procedures, pollutants to be tested, timeframes

Advanced Air Permitting Seminar – October 2014

hot issues for stack testing1
Hot Issues for Stack Testing

REMINDER:

Listing a sampling deviation in a test plan does not constitute approval.

Approval is required.

Advanced Air Permitting Seminar – October 2014

regional office contact information
Regional Office Contact Information

NORTH CENTRAL AND WEST TEXAS AREA

CENTRAL

TEXAS

AREA

BORDER AND

PERMIAN BASIN

  • AREA

COASTAL AND

EAST TEXAS

  • AREA

Advanced Air Permitting Seminar – October 2014