GOP Background: The MSWL GOP Permit Number 517 was developed for use by Title V major and minor source landfills that collect and dispose of refuse. MSWLs that must obtain a Federal Operating Permit under 30 Texas Administrative Code Chapter 122 that qualify for this GOP may apply to TCEQ for authorization under GOP 517. Compared to an individual SOP, the GOP offers the opportunity for a more streamlined application process because such applications are not required to comply with the public participation procedures in 40 CFR §70.7(h) or 30 TAC Chapter 122, Subchapter D.
GOP Revisions and TCEQ's Response to TxSWANA's Comment:
Electric Generating Facilities: TCEQ requested comments on specific issues, including whether electric generating facilities (e.g., turbines, boilers and engines) located in the Houston/Galveston ozone nonattainment area that generate electricity for compensation should be authorized under the GOP. In agreement with TxSWANA's comment, the TCEQ revised the GOP to authorize co-located generating facilities.
|
|
Renewable Fuels: TCEQ also requested comment on whether facilities capable of using or producing methanol or ethanol fuels from landfill gas should be included under the GOP. According to TCEQ, since there are no facilities capable of producing methanol or ethanol fuels were under consideration for Texas landfills, no requirements were codified in the revision to the GOP that would allow for the production of these fuels. TCEQ did; however, agree with TxSWANA that the use of renewable non-fossil fuels should be encouraged and revised the GOP to allow for the use all liquid or gaseous renewable fuels, including landfill gas and biodiesel fuels.
Diesel Fuel Activities Clarified: TxSWANA also requested that TCEQ clarify their position on "diesel fuel activities" and specifically requested that TCEQ identify where in the GOP requirements for diesel fuel tanks and fueling operations were contained.
-
According to TCEQ, it was not their intent to exclude requirements for diesel fuel from the GOP, because such requirements are necessary for regulating the storage and transfer operations of diesel fuels on landfill sites. TCEQ also clarified what type of activity would constitute a "loading or unloading operation," and noted that the transfer of diesel from or into a transport vessel (i.e, any land-based mode of transportation such as a truck or railcar) that is equipped with a storage tank having a capacity greater than 1,000 gallons constitutes a "loading or unloading operation."
-
Transfer of diesel fuel from stationary storage to a service vehicle with a tank capacity of less than 1,000 gallons does not constitute either a loading or unloading operation. Fueling of stationary combustion sources (diesel engines) or mobile sources (heavy equipment or trucks) does not constitute either a loading or unloading operation.
-
In the existing GOP, requirements for loading operations were contained in the permit tables and requirements for unloading operations were contained in a site-wide term. The site-wide terms addressing unloading, including the unloading of diesel fuels, were removed and those requirements were placed in tables under GOP Number 517(c)(23) or (c)(24), which are dependant on the county in which the site is located. Applicants in nonattainment or covered attainment counties subject to 30 TAC Chapter 115 should identify a GOP Index Number in either (c)(23) or (c)(24), as appropriate, to identify requirements for loading and/or unloading requirements associated with the transfer of diesel fuels.
Path Forward:
TCEQ Staff sent the revised GOP 517 to EPA for official review on June 12, 2006. The EPA comment period is expected to end during the first week of August, and provided that EPA has no significant comments, the revised GOP is expected to be finalized in the Fall of 2007.
|
