The Air Permits Division of the Texas Commission on Environmental Quality (TCEQ) published a revised technical guidance document for Chemical Source Fugitive (APDG 6422) in June of 2018. This guidance is aimed to assist with appropriately permitting fugitive sources including details on:
- When fugitive emissions need to be quantified;
- How to calculate uncontrolled fugitive emissions;
- Fugitive emission control options (e.g., leak detection and repair (LDAR) programs and equipment specification);
- Best Available Control Technology (BACT) and impacts; and
- Overlaps with federal fugitive source regulations.
With the revision published in June of 2018, TCEQ provides clarification on many contentious issues perhaps most notably more transparent guidance on what types of streams must be considered when quantifying fugitive emissions. Previously, there was some confusion over whether or not fugitive emissions had to be calculated for components which were exempt from normal monitoring requirements under various leak detection and repair (LDAR) rules (e.g., unsafe-to-monitor components, equipment only in service during startup and shutdown, heavy liquid components, wastewater line components, natural gas line components etc.). TCEQ plainly indicates that emissions from these components must be quantified and included in the emission estimates for fugitive sources.
This update and more will be discussed in more detail during a complimentary webinar provided by the Trinity Consultant's Chemical Sector Services group on September 12, 2018 from 12PM -1 PM (CDT). To register for this webinar, please click here.
For assistance with your air permitting needs, contact the Trinity office nearest you by calling 800-229-6655 for more information.