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Enron Mail |
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.
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