tanks and permits by rule

Tanks and Permits By Rule

Mr. Mark McDonald / Mr. James NolanTCEQ Air Permits DivisionRule Registrations Section

Objectives

• Review of PBRs• Tank Authorizations• Calculations• Case Study

Permit By Rule30 TAC Chapter 106

Emission Limits

Conditions

Claim/Register/Certify

30 TAC §106.4 Emission Limits

Total actual emissions per facility:• 250 tpy NOx and CO• 25 tpy VOCs, SO2, PM• 15 tpy PM10

• 10 tpy PM2.5

Conditions

All conditions of the specific permit by rule must be met.

• Only the facilities and materials specifically identified in the rule can be authorized.

• Only the materials designated in the rule can be authorized.

Claiming a PBR Authorization

Keep records on site to show compliance with applicable rules and regulations

Registration of PBR Authorization

• Submit documentation

through STEERs

• Pay fee

• Maintain records

Certification

Emission limitations for Title V applicability

Federal applicability

Control/destruction efficiency claims

Limiting operating hours

• §106.6(a): Federally enforceable emission limits

• §106.6(b): Representations become conditions

• §106.6(c): Changes require registration

• §106.6(d): Documentation is required

30 TAC §106.6: Registration Of Emissions

30 TAC §106.8 Recordkeeping

Maintain records sufficient to demonstrate compliance with your representations in a reviewable format.

30 TAC §106 Subchapter U

What operations can be authorized under30 TAC §106 Subchapter U

30 TAC §106 Subchapter UGeneral Guidance

• Storage vessels include tanks, totes, drums, bins, reservoirs, or other facilities whose sole purpose is storage.

• Include fugitives directly associated with the facility.

• Note exceptions and control requirements for specific chemicals stored.

• Registration should include all potential services being authorized.

30 TAC §106, Subchapter UTanks, Storage, and Loading

• §106.471: Storage or Holding of Dry Natural Gas

• §106.472: Organic and Inorganic Liquid Loading and Unloading

• §106.473: Organic Liquid Loading and Unloading

• §106.474: Hydrochloric Acid Storage

• §106.475: Pressurized Tanks or Tanks Vented to a Firebox

• §106.476: Pressurized Tanks or Tanks Vented to Control

• §106.477: Anhydrous Ammonia Storage

• §106.478: Storage Tank and Change of Service

30 TAC §106.471: Storage or Holding Of Dry Natural Gas

Equipment used exclusively to store or hold dry natural gas is permitted by rule.

30 TAC §106.474: Hydrochloric Acid Storage

• HCl concentration less than 38% (by weight)

• Concentration >20% (by weight) requires control

30 TAC §106.477: Anhydrous Ammonia Storage

• Capacity limit (30,000-gallons)

• Site approval and registration.

• ¼ mile distance requirement.

30 TAC §106.475: Pressurized Tanks or Tanks Vented to a Firebox

• Carbon, Hydrogen, Oxygen only

• Pressurized tank vented to control

• Exceptions for liquid petroleum gas and odorants

• Does not include control

30 TAC §106.476: Pressurized Tanks or Tanks Vented to Control

• Carbon compounds

• Pressurized or relief valve routed to control

• Does not include control

• Specific Chemicals

• Loading/Unloading

• Rail, Tank Truck, Drums

• Storage

• Change of Service

30 TAC §106.472: Organic and Inorganic Liquid Loading and Unloading

30 TAC §106.472: Organic and Inorganic Liquid Loading and Unloading

• Scrubber requirements for Acetic Acid, Ammonia and Hydrochloric Acid

• 500-ft Distance Requirement for Appendix VIII Chemicals

30 TAC §106.473: Organic Liquid Loading and Unloading

• Loading/Unloading

• Railcars, Tank Trucks, and Drums

• 20,000-gal/day loading rate limit

• Storage

• 25,000-gallon limit

• Except sweet petroleum

(40,000-gallon)

30 TAC §106.473: Organic Liquid Loading and Unloading

• Specific chemicals listed

• Must meet 30 TAC Chapter115

• No Appendix VIII chemicals

• Chemicals Listed in Table 478

• 500 foot distance requirement • Notification required for

>25,000-gal AND located in a designated nonattainment area for ozone

30 TAC §106.478: Storage Tank and Change Of Service

30 TAC §106.478: Storage Tank And Change Of Service

• Requirements closely follow NSPS Kb

• Vapor pressure range

(0.5 psia – 11.0 psia)

• Floating roof OR “equivalent control”

• No Loading

Change Of Service

• Change of material stored

• All requirements of the PBR apply

• Worst-case emissions should be represented for the facility.

What operations can be authorized under30 TAC §106 Subchapter U

Railcar Loading§106.472, §106.473

Truck Loading§106.472, §106.473

Storage Tanks§106.472, §106.473, §106.478

What operations can not be authorized under30 TAC §106 Subchapter U

What is Not Covered Under30 TAC §106 Subchapter U?

• Mechanical mixing

• Marine loading

• Control devices

• Chemicals not specifically listed

Mechanical Mixing

• 30 TAC §§106.261/262

• Be sure to include:

• Loading/unloading

• Fugitives components

• Controls

Marine Loading

• Use 30 TAC §§106.261/262

• 99% Capture Efficiency for Ocean-Going Marine Vessels

Controls

• 30 TAC §§106.261/262 or 30 TAC §106.492

• Must include basis of calculations

PBR Tank Authorization

• 30 TAC §§106.261/262 authorizes handling of chemicals not considered or excluded from 30 TAC §§106.472-106.478

• 30 TAC §§106.472-106.478 authorizes construction of the tank.

• Cannot be used to circumvent control, distance, or registration requirements in §§106.472-106.478.

MSS for Tanks

• Included in the Subchapter U PBR authorization

• Registered or Claimed under 30 TAC §106.263

State/Federal Applicability

• 30 TAC Chapter 115

• 40 CFR Part 60, Subparts

K, Ka, and Kb

• 40 CFR Part 61, Subpart Y

• 40 CFR Part 63, Subpart G

What operations can not be authorized under30 TAC §106 Subchapter U

Marine Loading§§106.261/106.262

Control Devices§106.261, §106.262, §106.492

Mechanical Mixing§§106.261/106.262

Emissions Representations

Sources of Emissions

Fugitives

Fugitive components directly associated with the tank can be authorized with the facility.

Tank Emissions

• Moving Liquids

• Temperature Changes

• Pressure Changes

Loading

• Vapor space displaced

• Calculated using AP-42 Ch. 5

Sources of Emissions

Calculation Methodologies

• AP-42

• Simulators (Based on AP-42)

• TCEQ Guidance

PBRs Authorize ACTUAL Emissions

• Worst case emission should be represented

• Short term emissions

• Annual emissions

• All potential chemical species should be identified

• §106.6(a): Federally enforceable emission limits

• §106.6(b): Representations become conditions

• §106.6(c): Changes require registration

• §106.6(d): Documentation is required

30 TAC §106.6 Registration of Emissions

Tank Example

Site Location and Process Specifics

• Stores Naphtha - Isopropanol - Ethanol

• 6 tanks, largest is 12,000 gallons

• 8 tpy of VOCs (calculated with AP-42)

• Product arrives and leaves via pipeline

• Greater than 500 feet from receptor

• Located in Harris County•

Authorization

• Naphtha and alcohols are listed in Table 478

• True vapor pressure is > 0.5 psia and < 11.0 psia

• Calculations: Sitewide <25 tons per year of VOCs

• PBR §106.478 is the most appropriate

• Harris County

• Chapter 115 applicable / VOCs in nonattainment area

Chapter 115 Requirements

True Vapor Pressure (psia)

Storage Capacity (gal)

Control Requirements

≥ 1.5 psia and < 11 psia> 1,000 gal and ≤ 25,000 gal

Submerged fill pipe or Vapor control system

OK < 1.5 psia = Isopropanol (0.63 psia) / Ethanol (0.83 psia) Naphtha (10.9 psia) = Ch. 115 applicable

• Review of PBRs• Tank Authorizations• Calculations• Case Study

Objectives

Pre-Permit Meetings are Encouraged!

Mr. Mark McDonaldWork Leader512-239-1357

[email protected]

Mr. James NolanTechnical Specialist

[email protected]

TCEQ Air Permits DivisionRule Registration Section

512-239-1250

Tanks and Permits by RuleUsing 30 TAC §106 Subchapter U

tanks and permits by rule

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