1. Commonly Used Permits by Rule
Ivan Rivera
Air Permits Division
Texas Commission on Environmental Quality
Environmental Trade Fair 2018
Commonly Used Permits by Rule
Ivan Rivera
Air Permits Division
Texas Commission on Environmental Quality
Environmental Trade Fair 2018

2. Overview Types of Authorizations General Information About PBRs
Application
Case Study
STEERS
Overview
Today, we will discuss authorization types, general information on permits by rule (PBRs), go over what should be included in an application, do brief case studies on §§ , § , and §§ /262 and discuss the TCEQ State of Texas Environmental Electronic Reporting System (STEERS).

3. Types of Authorizations
De Minimis
PBR & Standard Permit
Case-by-Case Permits
Minor
GOPs
SOPs
Types of Authorizations
These are the types of air permit authorizations. Depending on what type of permit you have, the bigger the permit, the higher the emissions you typically have.
De Minimis facilities do not require registration or authorization prior to construction as long as they meet the specific requirements of Title 30 Texas Administrative Code (30 TAC) § (a)(1)-(3). In addition, specific facilities that have been evaluated and designated as de minimis are identified on the de minimis list, which is posted on the division's Web site. De minimis facilities and sources include very small additions to background concentrations of air contaminants that cause no discernable or unacceptable impact to public health and for which permitting would be an ineffective use of commission resources.  The de minimis list can be found at
These are negligible sources. They are industry and activity specific. Examples: Fireplaces and pits, Laundromats, and swimming pool maintenance.
Permits by rule (PBRs) are new source review (NSR) authorizations. They authorize sources that do not meet the de minimis criteria. PBRs are in the Texas Administrative Code, Title 30, Chapter This chapter identifies certain types of facilities or changes within facilities, which the commission has determined will not make a significant contribution of air contaminants to the atmosphere pursuant to the Texas Health and Safety Code, the Texas Clean Air Act (TCAA), § and § The chapter contains general requirements applicable to all PBRs, including, but not limited to, record keeping and emission limitations.
Standard permits (SPs) are NSR authorizations. They often authorize sources that cannot meet PBRs or are not covered in Chapter Standard permits are industry/activity specific and must be renewed every ten years. A standard permit can never be used to authorize emissions that will trigger major NSR permitting under Chapter 116, and unlike PBRs, all standard permits (with the exception of the Pollution Control Standard Permit) require best available control technology (BACT). Types of SPs currently processed by the Rule Registrations (R&R) Section include: Oil and Gas § , Non-rule Oil & Gas (Adopted 2/27/11), Municipal Solid Waste Landfills, Animal Carcass Incinerator, Boilers, Electric Generating Units, and Pollution Control Project (only some types of these are processed in R&R).
Case-by-Case NSR Permits – If a facility is not de minimis and cannot meet a PBR or standard permit, it must be authorized by a case-by-case NSR permit. These types of authorizations provide more flexibility to applicants because they can authorize more emissions ,and unlike a PBR or standard permit, facility-specific information can be considered during the technical review, which includes a BACT and impacts review.
However, today we will be discussing commonly used PBRs. If you would like to learn more about Case-by-Case NSR permits, there will be presentations throughout the Trade Fair.

4. Permit By Rule 30 TAC Chapter 106
Emission Limits
Conditions
Claim/Register/Certify
Permit by Rule 30 TAC Chapter 106
The full list of PBRs can be found at

5. Emission Limits §106.4 – General Limits §106.261 – PBR Specific Limits
250 tpy CO & NOx
25 tpy VOC, SO2, & PM
15 tpy PM10
10 tpy PM2.5
§ – PBR Specific Limits
6 lb/hr
10 tpy
1 lb/hr
4.38 tpy (additional information can be found in the speaker notes)
Emission Limits
Title 30 Texas Administrative Code (30 TAC), Chapter 106, §106.4 sets emission limits for a site. Ex: An oil and gas site, authorized only under PBR, has an engine and a flare. The entire site, including the flare and the engine, must meet §106.4 limits.
Some PBRs have facility and activity specific emission limits. For example, facilities permitted under §
tpy = tons per year
lb/hr = pounds per hour
CO = carbon monoxide (§106.4 limit = 250 tpy; § limit = 6 lb/hr)
NOx = oxides of nitrogen (§106.4 limit = 250 tpy; § limit = 6 lb/hr)
VOC = volatile organic compound (§106.4 limit = 25 tpy)
SO2 = sulfur dioxide (§106.4 limit = 25 tpy)
PM = particulate matter (§106.4 limit = 25 tpy)
PM10 = particulate matter less than or equal to ten microns in diameter (§106.4 limit = 15 tpy)
PM2.5 = particulate matter less than or equal to 2.5 microns in diameter (§106.4 limit = 10 tpy)

6. Conditions All conditions of the rule must be met, no exceptions.
All facilities on a site must be authorized appropriately. (additional information can be found in the speaker notes)
Conditions
All conditions of §106.4, §106.6, and rule specific requirements must be met – no exceptions.
All facilities on a site must be authorized appropriately whether de minimis, PBR, standard permit etc.

7. §106.146 Conditions (Soil Stabilization Plants)
(1) All bulk storage silos shall be equipped with fabric filter(s) having a maximum filtering velocity of 4.0 feet per minute (ft/min) with mechanical cleaning or 7.0 ft/min with automatic air cleaning.
(2) All conveyor belts transferring dry material to the pugmill shall be top covered. No symbol indicating that this PBR cannot be used if the specific conditions of the PBR cannot be met (additional information can be found in the speaker notes)
§ Conditions (Soil Stabilization Plants)
Let’s say that a company would like to register a pugmill that has mechanical cleaning but the maximum filtering velocity of the fabric filter is 6.0 feet per minute (ft/min). Section (1) states that the maximum filtering velocity for a fabric filter with mechanical cleaning can be no more than 4.0 ft/min. This fabric filter would not meet the PBR authorization.
Alternatively, let’s say that a company would like to register a pugmill using § There are specific requirements within that PBR that must be met. For example § (2) states that “all conveyor belts transferring dry material to the pugmill shall be top covered.” Therefore, the conveyors must be top covered if transferring dry material to the pugmill– there are no exceptions around this requirement.
If the pugmill cannot meet PBR requirements, a higher permitting mechanism must be sought.
Image Attribution:
Dirt created by Shawn Erdely from Noun Project

8. Conditions – Light Bulb Crusher
All conditions of the rule must be met, no exceptions.
All facilities on a site must be authorized appropriately.
What if my facility is not listed in Chapter 106?
§ or § is a possibility. (additional information can be found in the speaker notes)
Conditions – Light Bulb Crusher
All conditions of §106.4, §106.6, and rule specific requirements must be met – no exceptions.
What if my facility is not a listed PBR? Ex: Light bulb crusher? Light bulb crushers are not mentioned in any chapters within Chapter However, light bulb crushers have emissions that require registration. In this case, TAC §§ /262 can be used to authorize the light bulb crusher and its associated emissions. However, keep in mind that §§ /262 cannot be used to bypass control, distance, or other registration requirements of an industry specific PBR. If you can’t meet a section of another applicable PBR, you cannot use PBRs § or § in lieu of.
Image Attribution:
Bulb created by ICONCRAFT from Noun Project

9. Claiming versus Registering
Keep records on site to show compliance with rules and regulations
Registering
Submit documentation to TCEQ with fee
Emission limits must stay within §106.4 or PBR-specific limits
Claiming versus Registering
Claiming vs. Registering
PI-7 = Registration for Permits by Rule (form)
PBRs can either be claimed or registered. Some PBRs will require registration; others can simply be claimed.
Claiming a PBR: Certain rules do not require registration. A company can instead claim this rule and maintain records. Example of a rule that can be claimed: § – Soldering, Brazing, and Welding. No rule compliance demonstration needs to be submitted to the TCEQ if the company is claiming a PBR.
Registering a PBR: If a PBR requires registration, this requirement will be listed as a condition of the rule and will state that “the facility shall be registered with the commission using Form PI-7.” To register a project means that an application is submitted to the TCEQ demonstrating the site’s rule compliance.
Example of a rule that must be registered: § – Surface Coat Facility. It states, “Before construction begins, the facility shall be registered with the commission using Form PI-7”.
If the PBR you are claiming does not require registration, you may begin construction and operation  immediately. If the PBR does require registration, please keep in mind that certain PBRs require that you receive written approval from the commission before construction can begin.
A company may voluntarily register a site that does not require registration using the STEERs system. This will result in a letter from the agency regarding your authorization. If a company voluntarily registers, compliance with all conditions of the rule must be demonstrated.
If the company registers, there is a fee – Small Business: $100, All others: $450
*PBRs can be a part of the expedited program at an additional fee.

10. Certifying §106.6(a): Federally enforceable emission limits
§106.6(b): What the company represents, they are bound to
§106.6(c): Changes of representation, that result in change to emissions, require a revised certification (additional information can be found in the speaker notes)
Certifying
Certify: To certify a project means that the emissions submitted by the company are federally enforceable and cannot be exceeded.
PI-7-CERT = Registration and Certification for Permits by Rule (form)
§106.6(a): An owner or operator may certify and register the maximum emission rates from facilities permitted by rule under this chapter in order to establish federally enforceable allowable emission rates, which are below the emission limitations in §106.4 of this title.
§106.6(b): All representations with regard to construction plans, operating procedures, and maximum emission rates in any certified registration under this section become conditions upon which the facility permitted by rule shall be constructed and operated.
§106.6(c): It shall be unlawful for any person to vary from such representation if the change will cause a change in the method of control of emissions, the character of the emissions, or will result in an increase in the discharge of the various emissions, unless the certified registration is first revised.
The rule can be found at

11. Why Certify? Emission limitations for Title V applicability
Federal applicability
Control/destruction efficiency claims
Limiting operating hours (additional information can be found in the speaker notes)
Why Certify?
The most common reasons companies voluntarily certify or are asked to certify a project by a permit reviewer are:
Set emissions limits so as not to trigger Title V applicability. This has to do with the site’s potential to emit (PTE) which is the maximum capacity of a stationary source to emit a pollutant under its physical and operational design.
Demonstrate compliance with or exemption from federal rule applicability.
The company is representing a control efficiency over what the TCEQ guidance normally allows and may require certification.
Limit the operating hours below 8760 hours/year:
An example of this could be limiting the run time of a compressor to 2000 hours instead of 8760.
The above is only a partial list of the most common reasons companies voluntarily certify or are asked to certify a project by a permit reviewer. Depending on the type of PBR, a company may choose to voluntarily certify the project or may be required to certify the project by the permit reviewer prior to approval. Detailed explanations of the various reasons for certification can be found on the Form PI-7-CERT.
Form PI-7 CERT can be found at

12. PI-7-CERT ≠ APD-CERT
APD-CERT does not replace the need for a PI-7-CERT (or registration). ≠
PI-7-CERT is not equivalent to APD-CERT
APD-CERT = Certification of Emission Limits (form)
In lieu of a PI-7 CERT form, an APD-CERT form could be used in certain cases.
APD-CERT form is usually for sites that do not require registration.
An APD-CERT could be used if, for example, the site is a sweet oil and gas site that does not require registration, but the company would like to certify their maintenance, start-up, and shutdown (MSS) emissions or to certify tank emissions to demonstrate compliance with NSPS OOOOa.
Section (l) requires registration for sour oil and gas sites. An APD-CERT cannot be used to register the site. The site has to submit an application for review.

13. Federal and State Rules
30 TAC Ch. 112
30 TAC Ch. 115
30 TAC Ch. 117
Federal
NSPS
MACT
NESHAPs
Federal and State Rules
Regardless of whether the PBR is being claimed, registered or certified, the company is required to maintain records containing sufficient information to demonstrate compliance with the general requirements in 30 TAC §106.4, all applicable conditions of the PBR being utilized, and all other applicable state and federal rules potentially including, but not limited to:
Title 30 Texas Administrative Code (30 TAC) Chapter 112, Chapter 115, Chapter 117
New Source Performance Standards (NSPS), Maximum Achievable Control Technology (MACT) and National Emission Standards for Hazardous Air Pollutants (NESHAPs)

14. Tanks, Storage, & Loading §106.471 – §106.478
New construction
New service of existing tank
Change of service
Guidance
TANKS Software Program (additional information can be found in the speaker notes)
Tanks, Storage, & Loading
§ – §
Subchapter U – Tanks, Storage, and Loading (aka 470 Series)
New construction
New service of existing tank
Change of service
Guidance
TANKS Software Program
The “Storage Tank Construction Under Permit by Rule” memo can be found at
Per the Memo:
PBRs §§ may be claimed to authorize handling of chemicals not considered or excluded from PBRs §§ while construction of the tank will be authorized under PBRs §§ PBRs §§ cannot be used to circumvent control, distance, or registration requirements in PBRs §§
Guidance for tank emissions calculations can be found at
TANKS Software can be found at
Image Attribution:
Storage tank icon: by Nikita Kozin from the Noun Project

15. Tanks, Storage, & Loading §106.472
Constructing a 500 gallon diesel tank
Will store purchased diesel
Tanks, Storage, & Loading §
Constructing a 500 gallon diesel tank
Will store purchased diesel
This tank shall be authorized under, and meets the conditions, of § (1).

16. Tanks, Storage, & Loading §106.478 & §106.262
Constructing new tanks for the storage of Aromatics and Halogenated Compounds
§ – Construction of Tank
§ – Aromatics and Halogenated Compounds
Tanks, Storage, & Loading
§ & §
Constructing new tanks for the storage of Aromatics and Halogenated Compounds
§ – Construction of tank
§ – Aromatics and Halogenated Compounds

17. Surface Coating Case Study
(Transition Slide)

18. Surface Coating §106.433 Surface Coating §106.433
Enclosed vs. non-enclosed
VOC limits based specified
Exempt solvents (additional information can be found in the speaker notes)
Surface Coating §
Allows for enclosed vs. non-enclosed surface coating
Individual enclosed booth is limited to a five-hour average of 6 lb/hr and 500 lb/week of VOCs, as per § (6)(A)
All non-enclosed (outdoor) work areas, together, are limited to a five-hour average of 6 lb/hr and 500 lb/week of VOCs, as per § (7)(A)
Authorization requires the applicant to account for exempt solvents
This PBR requires registration before construction per § (9)

19. Surface Coating §106.433 – More Info
Why an MSDS?
Surface Coating Calculations:
Authorization Guide
Emissions Calculation Spreadsheet
Did you address applicability with state and federal requirements?
Surface Coating § More Info.
MSDS = Material Safety Data Sheet
The surface coating authorization guide can be found at
The surface coating emissions calculation spreadsheet can be found at

20. Daily Weighted Average
5.0 lb/gal
1.0 lb/gal
3.0 lb/gal
9 lb
3 gal
3.0 lb/gal
Daily Weighted Average
We get a lot of questions related to daily weighted average requirement of 30 TAC Ch. 115, Subchapter E. It is a common misconception that if your VOC daily weighted average is 3.5 pound per gallon (lb/gallon), you cannot use any coatings that are above that. That is not true. What it means is that the combined coatings used to coat a specific item must average out to 3.5 lb/gallon VOC.
Let’s say that in order to paint your miscellaneous metal part you have to use three coatings. The VOC content of each coating is 5 lb/gallon, 1 lb/gallon, and 3 lb/gallon. Each is added together (which equals 9 lb/gal) and then divided by three to get the daily weighted average of 3.0 lb/gal.

21. Dry Abrasive Cleaning §106.452
Enclosed vs. non-enclosed:
Registration
Blasting media
Distance limitations
Usage limitations
MSS may be authorized using § (additional information can be found in the speaker notes)
Dry Abrasive Cleaning §
Section typically goes hand-in-hand with §
Enclosed vs. non-enclosed: registration required for non-enclosed operations
Blasting media requirements
Distance limits do apply for facilities that are unable to meet the requirements of an enclosed facility.
Usage limits do apply for facilities that are unable to meet the requirements of an enclosed facility.
As applicable, MSS may also be authorized under PBR
MSS must be accounted for.

22. §106.261 and §106.262 (additional information can be found in the speaker notes)
Section and
As previously mentioned, PBRs are industry or activity specific. However, there are two PBRs that are not industry or activity-specific: Sections and If there is not a PBR that was written to authorize your specific activity, one of these general PBRs may be registered.
All upstream and downstream impacts must be addressed and accounted for when using §§ /262 to add new equipment to an existing process. Questions to consider are: Is the throughput changing? Will there be new chemicals introduced with this new process that will have to be addressed in facilities downstream?
Image Attribution:
Puzzle created by Sketchepedia - Freepik.com
<a href=" vector created by Sketchepedia - Freepik.com</a>

23. Facilities Limits §106.261 6 lb/hr 10 tpy 1 lb/hr 4.38 tpy §106.262
Emissions table in 262
1997 TLVs and BEIs
E = L/K
Facilities Limits
lb/hr = pound per hour
Emission limits for pollutants will be limited by the following:
PBR § (a)(2) – 6 lb/hr & 10 tpy
PBR § (a)(3) – 1.00 lb/hr & 4.38 tpy
PBR § (a)(2) – E = L/K
L is determined using either the table found in the rule ( or
The 1997 Threshold Limit Values (TLVs) and Biological Exposure Indices (BEIs)
The rule requires the use of the time weighted average (TWA) Threshold Limit Value (TLV) published by the American Conference of Governmental Industrial Hygienists (ACGIH), in its TLVs and BEIs guide (1997 Edition). However, if a newer TLV has a more stringent value OR if a chemical is listed on the current version, but was not in the 1997 version, we highly recommend you use the newer value to ensure protectiveness. You can use the current version of the TLV only when the current version is equal to or more stringent than the 1997 version.

24. §106.261 Annual submittal: Account for upstream/downstream
Prepare it all together
Account for upstream/downstream
Represent associated NSR permits (additional information can be found in the speaker notes) §
NSR = New Source Review
These PBRs are not intended to be substitutes for rules that have technical requirements that cannot be met.
NOTE: Break out each project to make sure Prevention of Significant Deterioration, Nonattainment, etc. were never triggered.

25. §§106.261/262 Case Study §§106.261/262 Case Study
Chemical plant with an NSR permit
Adding 10 flanges to existing piping for maintenance
Emits Butane, Benzene, Emery, Di-n-butyl-ether, and Heptane (additional information can be found in the speaker notes)
§§ / Case Study
If you can’t meet a section of another applicable PBR, you can’t use PBRs § or § instead.
Company A owns and operates a chemical plant under an NSR case-by-case Permit. The company plans to add additional fugitive components (ten [10] flanges) to the existing welded piping. The additional flanges will facilitate piping maintenance activities. This will emit Butane, Benzene, Emery, Di-n-butyl-ether, and Heptane. Fugitive components are located 300 ft. from nearest receptor.

26. §§106.261/262 Table – Butane ? Pollutant Actual lb/hr tpy Rule K Value
L Value
max
Butane
2.33
1.89 ?
Benzene
0.0201
0.003
Emery
0.0211
Di-n-butyl-ether
0.80
1.36
Heptane
0.35
1.53
§§ /262 Table – Butane
§§ / Table – Butane
These are the chemicals we need to speciate. Let’s start with Butane.

27. §§106.261/262 Case Study Order §106.261(2) §106.262 §106.261(3)
When trying to find out the emission limits of a chemical, follow this process,
First check § (2).

28. § (2) Rule Language
(2) Total new or increased emissions, including fugitives shall not exceed 6.0 lb/hr and ten tons per year of the following materials:
Acetylene,
Argon,
Butane,
Crude oil… (additional information can be found in the speaker notes)
§ (2) Rule Language
(2) Total new or increased emissions, including fugitives shall not exceed 6.0 lb/hr and ten tons per year of the following materials:
Acetylene,
Argon,
Butane,
Crude oil…
Butane is a 261(2) Chemical.
Emission limits are 6 lb/hr and 10 tpy.
The rule language does not differentiate between i-butane or n-butane. All isomers of butane together need to meet 6 lb/hr and 10 tpy limits.
The rule can be found at

29. §§106.261/262 Table – Butane ? Pollutant Actual lb/hr tpy Rule K Value
L Value
max
Butane
2.33
1.89
261(a)(2) --
6.00
10.00
Benzene
0.0201
0.003 ?
Emery
0.0211
Di-n-butyl-ether
0.80
1.36
Heptane
0.35
1.53
§§ /262 Table – Butane
§§ /262 Table – Butane
Here we enter 6 lb/hr and 10 tpy into the chart. The K Value and the L value are only needed for § chemicals.

30. §§106.261/262 Table – Benzene ? Pollutant Actual lb/hr tpy Rule
K Value
L Value
max
Butane
2.33
1.89
261(a)(2) --
6.00
10.00
Benzene
0.0201
0.003 ?
Emery
0.0211
Di-n-butyl-ether
0.80
1.36
Heptane
0.35
1.53
§§ /262 Table – Benzene
§§ /262 Table – Benzene
Now let’s look at Benzene.

31. §§106.261/262 Case Study Order §106.261(2) §106.262 §106.261(3)
Benzene isn’t listed.
Let’s look at 262.
§§ /262 Case Study Order
Benzene is not one of the chemicals listed in § (2). So, skip over to §

32. Benzene is in the table at this link.
§ Rule Language
(2) …nor in a quantity greater than E as determined using the equation E=L/K and the following table:
Attached Graphic
Benzene is in the table at this link.
The table at this link shows Benzene’s L-value to be: mg/m3. (additional information can be found in the speaker notes)
§ Rule Language
(2) …nor in a quantity greater than E as determined using the equation E=L/K and the following table:
Attached Graphic
TCEQ accepts the L value from two sources:
§ rule language, which the arrow is pointing to. Or, if the chemical is not listed here, check
1997 TLV
In this case, Benzene is listed in PBR § and has an L value of 3.
The rule can be found at
Limit Values (L Values) can be found at

33. §§106.261/262 Table – Benzene K Value
Pollutant
Actual
lb/hr
tpy
Rule
K Value
L Value
max
Butane
2.33
1.89
261(a)(2) --
6.00
10.00
Benzene
0.0201
0.003
262 ? 3
Emery
0.0211
Di-n-butyl-ether
0.80
1.36
Heptane
0.35
1.53
§§ /262 Table – Benzene K Value ?
§§ /262 Table – Benzene K Value
We must now find the K value.

34. The K value is in the table at this link.
§ Rule Language
(2) …nor in a quantity greater than E as determined using the equation E=L/K and the following table:
Attached Graphic
The K value is in the table at this link.
The table linked here shows the K value at 300 ft to be (additional information can be found in the speaker notes)
§ Rule Language
(2) …nor in a quantity greater than E as determined using the equation E=L/K and the following table:
Attached Graphic
In this case study, the distance to the nearest off property receptor is 300 feet.
K = 139
The rule can be found at
K Values can be found at

35. §§106.261/262 Table – Benzene ? E=L/K E=3/139 Pollutant Actual lb/hr
tpy
Rule
K Value
L Value
max
Butane
2.33
1.89
261(a)(2) --
6.00
10.00
Benzene
0.0201
0.003
262
139 3
0.0216
0.0946
Emery
0.0211 ?
Di-n-butyl-ether
0.80
1.36
Heptane
0.35
1.53
E=L/K E=3/139
§§ /262 Table – Benzene
§§ /262 Table – Benzene
E = 3/139 =
Per the rule, the annual limit is 5.00 tpy. However, it is mathematically impossible to reach this number when the max lb/hr * 8760 hrs/2000 = < 5 tpy.
Now, let’s look at Emery.

36. §§106.261/262 Table – Emery ? Pollutant Actual lb/hr tpy Rule K Value
L Value
max
Butane
2.33
1.89
261(a)(2) --
6.00
10.00
Benzene
0.0201
0.003
262
139 3
0.0216
0.0946
Emery
0.0211 ?
Di-n-butyl-ether
0.80
1.36
Heptane
0.35
1.53
§§ /262 Table – Emery
§§ /262 Table – Emery

37. §§106.261/262 Case Study Order §106.261(2) §106.262 §106.261(3)
Next try the TLVs & BEIs. (additional information can be found in the speaker notes)
§ (2) §
§ (3)
Emery isn’t listed.
Emery isn’t listed.
§§ /262 Case Study Order
Emery is not listed in PBR , so we will have to look at PBR
Emery is not listed in PBR ’s pollutants list, so we will have to look at the 1997 Threshold Limit Values (TLVs) and Biological Exposure Indices (BEIs).

38. 1997 TLVs & BEIs … Divinyl benzene [1321-74-0] (1980)………….. 10 53
[ ] (1980)…………
Emery [ ] (1986)………… (e)
Endosulfan[ ] ---
… Rectangle highlighting the information for emery. Additional information can be found in the speaker notes.
1997 TLVs & BEIs
Emery is listed in the 1997 Threshold Limit Values (TLVs) and Biological Exposure Indices (BEIs) and has an L value of 10.
Important! If a newer TLV has a more stringent value OR if a chemical is listed on the current version, but was not previously, we highly recommend you use the newer value to ensure protectiveness. You can use the current version of the TLV only when the current version is equal to or more stringent than the 1997 version.

39. ? §§106.261/262 Table – Emery E=L/K E=10/139 Pollutant Actual lb/hr
tpy
Rule
K Value
L Value
max
Butane
2.33
1.89
261(a)(2) --
6.00
10.00
Benzene
0.0201
0.003
262
139 3
0.0216
0.0946
Emery
0.0211
262(a)(2) 10
0.0719
0.315
Di-n-butyl-ether
0.80
1.36 ?
Heptane
0.35
1.53
E=L/K E=10/139
§§ /262 Table – Emery
§§ /262 Table – Emery
E = 10/139 = 0.07
Per the rule, the annual limit is 5.00 tpy. However, it is mathematically impossible to reach this number when the max lb/hr * 8760 hrs/2000 = < 5 tpy.
Now let’s look at Di-n-butyl-ether.

40. §§106.261/262 Table – Di-n-butyl-ether
Pollutant
Actual
lb/hr
tpy
Rule
K Value
L Value
max
Butane
2.33
1.89
261(a)(2) --
6.00
10.00
Benzene
0.0201
0.003
262
139 3
0.0216
0.0946
Emery
0.0211
262(a)(2) 10
0.0719
0.315
Di-n-butyl-ether
0.80
1.36 ?
Heptane
0.35
1.53
§§ /262 Table – Di-n-butyl-ether
§§ /262 – Di-n-butyl-ether

41. §§106.261/262 Case Study Order §106.261(2) §106.262 §106.261(3)
Not in the TLVs & BEIs. Let’s check here.
Let’s check here.
§ (2) §
§ (3)
Di-n-butyl-ether isn’t listed.
Isn’t listed.
§§ /262 Case Study Order
It is not listed in § (2), § , or the 1997 TLV. Now what?

42. § (a)(3) Rule Language
(3) …emissions, including fugitives, shall not exceed 1.0 lb/hr of any chemical… (additional information can be found in the speaker notes)
𝟖𝟕𝟔𝟎 𝒍𝒃 𝒚𝒓 ÷ 𝟐𝟎𝟎𝟎 𝒍𝒃 𝒕𝒐𝒏 =𝟒.𝟑𝟖 𝒕𝒑𝒚)
1 𝑙𝑏 ℎ𝑟 × ℎ𝑟 𝑦𝑟 = 𝟖𝟕𝟔𝟎 𝒍𝒃 𝒚𝒓
§ (a)(3) Rule Language
(3) …emissions, including fugitives, shall not exceed 1.0 lb/hr of any chemical…
Because Di-n-butyl-ether is not listed elsewhere, you will use § (a)(3) to authorize the emissions.
1 lb/hr and 4.38 tpy limit
1 lb/hr*8760 hr/year=8760lb/yr
8760lb/yr / 2000 lb/ton= 4.38 tpy
The rule can be found at

43. §§106.261/262 Table – Di-n-butyl-ether – tons per year
Pollutant
Actual
lb/hr
tpy
Rule
K Value
L Value
max
Butane
2.33
1.89
261(a)(2) --
6.00
10.00
Benzene
0.0201
0.003
262
139 3
0.0216
0.0946
Emery
0.0211
262(a)(2) 10
0.0719
0.315
Di-n-butyl-ether
0.80
1.36
261(a)(3)
1.00
4.38
Heptane
0.35
1.53 ?
§§ /262 Table – Di-n-butyl-ether – tons per year
§§ /262 Table – Di-n-butyl-ether – tons per year
Here we enter 1.00 lb/hr and 4.38 tpy into the chart.

44. §§106.261/262 Table – Heptane – tons per year
Pollutant
Actual
lb/hr
tpy
Rule
K Value
L Value
max
Butane
2.33
1.89
261(a)(2) --
6.00
10.00
Benzene
0.0201
0.003
262
139 3
0.0216
0.0946
Emery
0.0211
262(a)(2) 10
0.0719
0.315
Di-n-butyl-ether
0.80
1.36
261(a)(3)
1.00
4.38
Heptane
0.35
1.53 ?
§§ /262 Table – Heptane – tons per year
§§ /262 Table – Heptane – tons per year
Now let’s look at Heptane.

45. §§106.261/262 Case Study Order §106.261(2) §106.262 §106.261(3)
L Value = 350
§ (2) §
§ (3)
Heptane isn’t listed.
Heptane is listed.
§§ /262 Case Study Order
The L value of Heptane is 350.

46. But wait! (additional information can be found in the speaker notes)
§§ /262 Case Study Order
§ (2) §
§ (3)
But wait! (additional information can be found in the speaker notes)
§§ /262 Case Study Order
The L value of Heptane is 350.

47. § (a)(3) Rule Language
(3) …emissions, including fugitives, shall not exceed 1.0 lb/hr of any chemical having a limit value (L) greater than 200 milligrams per cubic meter… (additional information can be found in the speaker notes)
§ (a)(3) Rule Language
(3) …emissions, including fugitives, shall not exceed 1.0 lb/hr of any chemical having a limit value (L) greater than 200 milligrams per cubic meter…
Since Heptane’s L value is greater than 200, § (a)(3) can be used.
The rule can be found at

48. §§106.261/262 Table – Heptane – tons per year
Pollutant
Actual
lb/hr
tpy
Rule
K Value
L Value
max
Butane
2.33
1.89
261(a)(2) --
6.00
10.00
Benzene
0.0201
0.003
262
139 3
0.0216
0.0946
Emery
0.0211
262(a)(2) 10
0.0719
0.315
Di-n-butyl-ether
0.80
1.36
261(a)(3)
1.00
4.38
Heptane
0.35
1.53
§§ /262 Table – Heptane – tons per year
§§ /262 Table – Heptane – tons per year
Heptane has a limit value of In which case, § (a)(3) can be used.
1 lb/hr and 4.38 tpy.

49. The Totals Must Match
§§ /262 Table: VOC= 3.52 lb/hr and 4.79 tpy Emission Summary Table: VOC = 3.52 lb/hr and 4.79 tpy
The Totals Must Match
Total Emissions in §§ /262 speciation table must match the emission summary table.

50. Contact Information
Ivan Rivera
(512)
Air Permits Division
(512)
Commonly Used Permits by Rule
Ivan Rivera and Britany Gilman
Air Permits Division
Texas Commission on Environmental Quality
Environmental Trade Fair 2018

51. ePermitting Getting Started and Beyond
Britany Gilman
Air Permits Division
Texas Commission on Environmental Quality
ePermitting: Getting Started and Beyond
Welcome to the Texas Commission on Environmental Quality’s ePermitting demonstration video.
This presentation will be walking through how to submit an Oil and Gas Permit by Rule application using the State of Texas Environmental Electronic Reporting System (or STEERS).

52. ePermit Steps ePermit Steps
There are four main steps in the ePermit process:
First the customer will fill out the application and upload application documents,
The Responsible Official will sign the application,
Next, the customer will pay the application fee through ePay,
And the final step is to submit the application.
The benefits of using the STEERS system include easier application submitting, a faster review time, and potentially receiving a same day authorization letter if the application being submitted is eligible.
References:
Application Icon - APP File by Arthur Shlain from the Noun Project
Signature Icon - Contract signature by Arthur Shlain from the Noun Project
Payment - Payment by Adrien Coquet from the Noun Project
Submit - Upload by Ananth from the Noun Project

53. TCEQ Home Page TCEQ Home Page
To get to the STEERS Web page, first go to the TCEQ Home page (

54. TCEQ Home Page Link to STEERS
Scroll down to the bottom left of the page, and click on “ePermitting (STEERS).”

55. STEERS Home Page STEERS Home Page
Here is what the STEERS Home page looks like. On the left is a list of the available programs that can be submitted through STEERS
There is a link to program area phone numbers in the top right corner under “Questions or Comments>>”.
Assuming that the customer already has a STEERS account, this is where they will log into STEERS using their ER Account Number and Password.
If the customer does not already have a STEERS account set up, there is another video presentation by the TCEQ instructing them how to create a STEERS account.

56. STEERS Program Area STEERS Program Area
After signing in, the STEERS Program Area page will appear.
Today I will be filling out an Oil and Gas initial Permit by Rule § (l) application.
I have already added my appropriate program area (EPR_NSR) to my account and signed the STEERS Participation Agreement.
Click on “Air New Source Review (EPR NSR).”

57. Activities Page Activities Page
To start a new application, select “Fill Out” on the activities page.
To access an already created application by the application password, select “Access.”
In this example, a new application will be created. Click “Fill Out.”

58. Air New Source Review Application Types
STEERS Application Type page

59. Application Type ApplicationType
The next page will bring up different application types of Air New Source Review projects that can be submitted through STEERS.
Under “Air New Source Review (NSR) Administrative Action(s)”, a company can submit an Air NSR Change of Ownership application.
Under “New Source Performance Standard (NSPS-OOOO)”, a company can submit a Well Completion/Flowback Notification.
Under “General MSS Registrations and Other APD Certifications”, the company can submit an APD Certification or APD Maintenance Startup and Shutdown project for a facility.
Under “Notifications and registrations for Barnett Shale (BSH)”, a company can submit Oil and Gas Site Historical or New Project Notifications, a Barnett Shale Oil and Gas Site PBR registration, or an Oil and Gas Site Non-Rule Standard Permit registration.
Under “Registrations for Permits by Rule,” a company can submit a PBR application for new or existing registrations.
Finally under “Registrations for a Standard Permit”, a company can submit a Standard Permit application for a new or existing registration.
In this example, a PBR New Registration application will be filled out. Select Registrations for Permits by Rule, then PBR New Registration, and then click “Next.”

60. Application Access Application Access
Once the project application is created, a confirmation page will appear with the application reference number and application password.
The application reference number and password may be used by another STEERS account holder to access the project application. Access rights will be assigned at this step by clicking “Set Access Rights.” For example, the Responsible Official (RO) can add the STEERS account number of their consultant to the application so that the consultant can access the project.
After access rights have been set, select “Next.”

61. Site Information Site Information
The next step is to input the site information.

62. STEERS Help Text STEERS Help Text
The Question icon at the top of the page near the title is a link to STEERS help. The customer can click on this icon and a new window will open providing help text to explain what information the STEERS system is requesting.
These icons will appear throughout each step of the application process for the customer’s convenience.

63. STEERS Error Example STEERS Error Example
The red highlighted text at the top of the page is an example of a STEERS error message. STEERS will let the customer know if there is a portion of the application step that needs to be completed before letting the customer move forward in the application process.

64. Regulated Entity Regulated Entity
For this portion of the application, there are three options to generate the Regulated Entity information. If there is no RN number assigned yet, fill out Option 3 with the site information.
For this example, the site has an RN. Type in the RN number into the Option 1 “Regulated Entity Number” box, then click “Next.”

65. Customer Number Customer Number
Please note that the “Task List” for this project is to the left of the screen. Here, the customer can see which steps of the application process have been completed, and which steps are still needing to be filled out.
There are four options to generate the customer information. If there is no CN number assigned yet, fill out Option 4.
In this example, select “Option 1,” and then click “Next.”

66. Customer Information Customer Information
Since we selected “Option 1” to generate the customer information, this page shows that information populated.
For the question, “How is this applicant associated with this site?,” the answer will be “owner operator, operator, or owner.” Let’s say “Owner Operator.”
Next, the applicant must certify that the full legal name of the entity applying for this permit has been provided and is legally authorized to do business in Texas.
Verify that the customer information is correct. If the information is incorrect, please contact the APD Mainline.

67. Customer Information Continued
The next step is to provide the contact information for the Responsible Authority.
After filling out all information for the Responsible Authority, click “Next/Save.”

68. Responsible Official Responsible Official
The user will fill out the Responsible Official contact information. This can be the same information as the Responsible Authority contact.

69. Responsible Official Continued
After filling out all information for the Responsible Official, click “Next/Save.”

70. Technical Contact Technical Contact
Next, the user will fill out the Technical Contact information for the project. This will be the person that TCEQ contacts if there are any technical questions regarding the permit application. The Technical Contact can be the same as the Responsible Official or a consultant.

71. Technical Contact Continued
After filling out the Technical Contact information, click “Next/Save.”

72. PBR General Information
The user will now answer general PBR questions about the site.
Question 4 is where the company will indicate if the permit project and associated emissions will be certified.
After answering all necessary questions on this PBR General Information page, click “Next/Save.”

73. Rule Selection Rule Selection
The next step is to add the rule or rules being registered.
Since this application example is only registering PBR 352(l), I will leave the total number of Rules field as “1.”

74. Unit Type Selection Unit Type Selection
The rules are organized by unit names.
Search for the relevant name, and the rule will populate.
In this example, the site is being authorized under § (l), so we will select “OIL AND GAS PRODUCTION FACILITIES” from the drop down selection column.

75. Selection of Appropriate Rule Version
Select what version of the rule is applicable, then click the right arrow to move the applicable rule to the “Selected” box.

76. Submittal of Appropriate Rule Version
Once the applicable rule is on the right hand side under the “Selected” column, click “Next/Save.”

77. 106.352(l) Questions 106.352(l) Questions
Since § (l) was selected, there are specific questions the system will ask in regards to this specific rule. Please read through each question carefully and select your responses according to the site.

78. 106.352(l) Questions Continued
Once all of the specific questions are answered according to the site, click “Next/Save.”

79. 106.352(l) Emission Rate Input
The user will then input the estimated annual emission rates for the site. Please make sure to input your values to the second decimal place.
Once the emissions have been entered, click “Next/Save.”

80. Upload Application Upload Application
The next step is to upload the required supporting documents, or permit application. The TCEQ’s preferred order of documents can be found at the top of the page.
Click “+ Choose..” and select the document(s).
Once the documents have been selected, there is a confidential indicator button to the right of the uploaded attachment. The default answer will say “No.” If the upload attachment is confidential, make sure to click on the indicator button to designate the file as confidential and secure.
Once all necessary attachments have been uploaded, click “Next/Save.”

81. Activities Page- Ready to Sign
Here is what the customer “Activities” page look like. Under the “Status” column of the table, the STEERS system will show the status of the project.
The status of the project will say “In Progress” while the applicant is filling out the required project information shown in the project task list.
Once the application has been successfully filled out, the status will change to “Ready to Sign.” After the Responsible Official signs the application, the status will change to “Ready to Pay,” and finally after the payment is processed, the status will update to “Ready to Submit.”
This example’s status shows that the application is now ready to be signed by the responsible official.
The customer will select the appropriate project and then click “Sign.”

82. Sign Application Sign Application
The responsible official will agree to the statement and sign using their STEERS ER password. Entering the password will act as the electronic signature for the project.
After the responsible official enters their ER Account Password, click “Apply Electronic Signature.”

83. Sign Confirmation/ Payment Prompt
After signing, the user will be directed to pay for the application.
If the company is wanting to apply a previous payment voucher to pay for an application, please contact the APD Mainline for further assistance. A previous payment voucher may be applied to a STEERS project as long as the payment was processed by ePay within six months of the project submittal, and the status of the project says “Ready to Pay.”
In this example, we will be proceeding with the payment process using a new payment.
Select “Pay reference number 61240” then click “Next.”

84. Application Fee Summary
Confirm that the fee amount is correct, then click “Next.”

85. Prompt to Transfer to ePay
A prompt will appear informing the customer that they will next be transferred to ePay. Click “Go to ePay” and follow the steps to complete and submit the payment for the application.

86. Return to STEERS from ePay
After payment has been successfully processed, an ePay transaction confirmation page will appear, to go back to the application click “Return to STEERS.”

87. Submit Page Submit Page
You will be directed to the page where the application that you have been working on can be submitted. Confirm the application information is correct, then click “Submit.”
After clicking Submit, it may take awhile to process the submittal action. Please do not close out of the current page.

88. Submit Confirmation Submit Confirmation
Once the project has been successfully submitted, a confirmation page will appear.
All project submitted via STEERS will have a link to the project’s Copy of Record (COR). The Copy of Record is a copy of the STEERS application as the customer has submitted it.
STEERS projects that are eligible for same day approval, will receive a copy of the registration approval letter, given the project submitted is applicable.
The customer will receive an from STEERS if the submitted project is not eligible for same day approval authorization. The TCEQ will review the project, and the company will receive a response within 45 days for applications within the EPR_NSR Program Area.
In this example, the information that was submitted with the application qualified the company for a same day approval registration letter. Let’s select “Link to Approval Letter” to see what one looks like.

89. Notice of Authorization
The date at the top of the letter is the date that the registration was issued for the site.
The customer would verify that all the contact and site information represented is correct. If it is not correct, please contact the Rules and Registration Section for further assistance.

90. ePermit Tips Please do not copy and paste, or use special characters.
Regional offices have access to application, no need to mail a copy.
Local (city or county) programs will still need a hard copy of the application. Verify accuracy of all site information and addition of all applicable rules before submitting.
Verify accuracy of all site information and addition of all applicable rules before submitting.
ePermit Tips
A few tips for submitting ePermit applications through STEERS:
Avoid copy and pasting, or using special characters when filling in information fields.
Regional offices have access to application, no need to mail a copy.
Local (city or county) programs will still need a hard copy of the application.
Please verify all site information is accurate, and all applicable rules have been added to the application before submitting.

91. Thank You for Watching STEERS Questions 512-239-6925
ePermits Contacts:
STEERS Questions
APD Mainline
Thank You for Watching
At the bottom of this page are some helpful contact numbers if you should come across any problems during your application submittal process.
Thank you for watching!