Texas Title V General Operating Permit (GOP) Holders Subject to TCEQ Proposed Changes

For more information, contact Ed Fiesinger at 713.977.8787.  

The TCEQ has announced plans to revise or eliminate the use of General Operating Permits (GOP) for those sites having case-by-case New Source Review (NSR) authorizations in the portion of the site covered by the GOP. Sites in Texas with a Title V GOP that also have a case-by-case NSR permit will have to submit a new application for a site operating permit (SOP) by September 1, 2004 (for all but oil & gas), unless they can convert their NSR permits to either a Permit by Rule (PBR) or a Standard Permit.

What Facilities are Affected by This Rule?

The TCEQ will revise the current oil and gas PBR and standard permits, thereby enabling some sites to convert their NSR permits to a PBR or Standard Permit and continue to use GOPs. For Bulk Fuel Terminals, Site Wide Facilities, and Municipal Waste Landfills, however, there is no way to develop PBRs or Standard Permits that will allow continued use of a GOP. Therefore, these GOP holders will have to convert their GOPs to SOPs which will most likely mean submitting a more detailed and complicated permit application than was submitted to obtain the GOP. These sites will continue to operate under their current GOP until their new SOP is issued. Once all Gops have been converted, the TCEQ will rescind the GOPs.

The tentative schedule for submitting a new application is as follows:

Oil and Gas (GOPs 511-514) - 90 days after the TCEQ promulgates revisions to the oil & gas GOPs to add compliance assurance monitoring (CAM); periodic monitoring (PM); 30 TAC 101 requirements; new PBR's and Standard Permits; and update all requirements in terms and conditions and GOP tables. This is expected to be early fourth quarter 2005.

Bulk Fuel Terminals (GOP 515) - applications for SOPs must be received by September 1, 2004 since it is felt that these sources will not be able to convert their NSR authorizations to PBRs or Standard Permits.

Site Wide (GOP 516) - applications for SOPs must be received by September 1, 2004 since it is felt that these sources will not be able to convert their NSR authorizations to PBRs or Standard Permits.

Municipal Solid Waste Landfills (GOP 517) - 90 days following after TCEQs promulgates revisions to the landfill GOP to add compliance assurance monitoring (CAM); periodic monitoring (PM); 30 TAC 101 requirements; new PBR's and Standard Permits; and update all requirements in terms and conditions and GOP tables. This is expected to be early fourth quarter 2005.