TCEQ Revises Title V Deviation Reporting Forms
Beveridge & Diamond, P.C. - Texas Environmental Update, April 2008
TCEQ is in the final stages of revising its Title V permit compliance certification and deviation reporting forms and hopes to have them completed by the end of April. Most of the changes are intended to fix typographical errors in the current forms and to streamline the “look” of the forms to be more consistent with other permit forms.
The new deviation reporting forms include a “Miscellaneous Monitoring and Credible Evidence” companion form that would be used to support compliance status. The expectation to provide descriptions of credible evidence could in some cases increase the time involved in preparing Title V deviation reports.
The Agency is also revising its deviation guidance to reflect recent guidance on deviation reporting. In particular, the Agency has changed the guidance examples to explain: (1) that any emissions event of any unauthorized pollutant, regardless of its reportability, is a deviation; (2) how to determine or define compliance certification periods; and (3) how to distinguish between the duration and number of deviations for continuous deviations.
The Agency provides some example forms for completing the new forms. The draft forms and guidance are available on the TCEQ website.1
For a printable PDF of this article, please click here.
1 http://www.tceq.state.tx.us/compliance/field_ops/acguide.html
