1. Emission Events: Teaching the Basics
Jon Williams
TCEQ Work leader, El Paso Region

2. Congratulations! Probationary TCEQ Employees
No benefits until 3 months have been reached
Employment terminates upon exit of the room at any time
Learn the most challenging investigation type, FIRST
Also, no salary has been provided in our budget

3. The Investigator Perspective
You will learn how the investigator thinks while reading your provided information.
Hopefully the rules will make a little more sense.
Also, this should prepare you to provide clearer, more comprehensive event reports.

4. Initial Report High points of the report
How was the report received; STEERS, fax, , or by hand? (Form 10360)
24 hour clock started from the time they knew about the upset, did they report in time?
Simple statements of what occurred; does it match with Emission Point Numbers, and pollutants released?

5. Screen Shot of actual STEERS report #1

6. Close-up of top quarter of the Screen Shot of actual STEERS report #1

7. Close-up of second quarter of the Screen Shot of actual STEERS report #1

8. Close-up of third quarter of Screen Shot of actual STEERS report #1

9. Close-up of bottom quarter of Screen Shot of actual STEERS report #1

10. Initial report review Check RQ for everything reported
Start learning about the affected facility and those immediately upstream and downstream.
Learn permit conditions and permit emission limits.
Review compliance history.

11. What was that…? Missed the 24 hour reporting requirement
What chemical produced the opacity?
Not claiming Affirmative Defense
Excess Opacity does not require a Final Report

12. 2 weeks later High points
Again, check the date of receipt. The final is due 2 weeks from the END of the event.
Did they speciate emissions (Benzene vs. VOC)?
Pollutants compared to EPN, what came out of what?
Does the end result make sense based on the initial?
Must answer all 11 determinations to meet Affirmative Defense.
Must be a COMPLETE answer for each of the determinations.
If the final report doesn’t complete the 11 determinations, request additional information with a deadline.

13. Screen Shot of actual STEERS report #2

14. Screen Shot of close-up of third quarter of actual STEERS report #2

15. What was that…? #2 Incorrect authorized emissions limit
Insufficient detail on final report (e.g. not including the best known cause at the time of reporting)
Why did the coupling fail?
How quickly and exactly what actions were taken to minimize emissions?

16. Grouping Emissions
Understand that “VOC” or “PM” is not an acceptable way to report emissions for §101 purposes.
(Even though the permit may very well refer to “VOC” or “PM” on its maximum allowable emission rates table (MAERT).)
Carefully read the definition of RQ to understand which mixtures are acceptable to report (e.g. natural gas excluding methane, ethane, etc.)
30 TAC § (b)(1)(G): They can lump all compounds as “other” for which BOTH of these things are true:
The RQ is 100 lbs or more.
Less than 10 lbs was released in a 24-hour period.

17. Last Chance Drill down on any unknowns or questions
How did that cause this?
How was the operator trained?
Maintenance records for affected units.
No more than five years should be requested.
Operational logs before & after the event.
Ask/compare previous events that may have occurred that were reported to STEERS.
Ask them to provide any additional information that was not specifically asked for that they feel is relevant.

18. Put it all on the scales Affirmative Defense
The event couldn’t have been prevented or avoided.
How was this event handled compared to the last one of the same facility.
They have the technology, Better.. Faster... Stronger
The consequences of the events were minimized as much as possible.
All reporting requirements were met.

19. Screen Shot of actual STEERS report #3

20. Close up screenshot of third quarter of emission event

21. Lost Affirmative Defense
Usually falls into these categories:
Operator error
Poor Training
Sub-standard Maintenance Practices
Record Request
Inadequate design or engineering practices
System keeps failing
Not so Usual
Communication time lag, emitting for 10 hours while waiting for a decision

22. STEERS Expert Contacts
STEERS Questions:
STEERS MC
Physical Address
TCEQ <Place Program Name and Mail Code Here> Park 35 Cir Austin, TX 78753
Petroleum Storage Tank (PST)
PST Registration and Self-Certification MC
Aggregate Production Operations (EPR_APO)
WQ Processing Center MC APOP (2767)
Discharge Monitoring Report (eDMR/NetDMR)
Enforcement Division MC eDMR (3367)
Pollution Prevention Planning (P2PLAN)
Waste Reduction Policy Act Program MC
Air Emissions Maintenance Events (AEME)
Field Operations MC
Industrial and Hazardous Waste (IHW)
Registration and Reporting MC
Public Drinking Water - Labs (PDWLAB)
Public Drinking Water MC
Air New Source Review (EPR_NSR)
Air Permits MC
Municipal Solid Waste (MSW)
Municipal Solid Waste MC
Public Drinking Water - Systems (PDWSYS)
Annual Emissions Inventory Report (AEIR)
Emissions Inventory, MC
Municipal Solid Waste Registrations (EPR_MSW)
Municipal Solid Waste Permits Section MC
Storm Water General Permits (EPR_SW)
Storm Water Processing Center MC
CAFO General Permit (EPR_CAFO)
Applications Review & Processing MC
Occupational Licensing Computer Based Testing (CBT)
Operator Licensing MC
Training Roster Online Submittal (TROLS)
Operator Licensing MC
Central Registry (CR) Questions:
Central Registry Program MC
Pesticide General Permit (EPR_PESTGP)
WQ Processing Center MC BUGS (2847)

23. Time for Your Questions