Texas Commission on Environmental Quality



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Form OP-REQ1 - Instructions

Application Area-Wide Applicability Determinations and General Information

General:

Title 30 Texas Administrative Code Chapter 122 (30 TAC Chapter 122) requires the owners or operators of major source sites to submit a federal operating permit (FOP) application to the Texas Commission on Environmental Quality (TCEQ). However, owners or operators may request the use of multiple permit applications at the site and applications are then submitted for areas of the site (application areas). A site may, therefore, have a single permit application submitted for the entire site or multiple permit applications for areas that constitute the site. The entire site is also considered the application area when a single permit application is submitted for the site.

The TCEQ Air Permits Division (APD) has designated certain applicable requirements as site-wide requirements (please go to the TCEQ web site at www.tceq.texas.gov/assets/public/permitting/air/Guidance/Title_V/additional_fop_guidance.pdf for a list of site-wide requirements). A site-wide requirement is a requirement that applies uniformly to emission units or activities at the site. As an example, the APD has designated specific requirements of 30 TAC Chapter 111 (Control of Air Pollution from Visible Emissions and Particulate Matter), such as the opacity limits for stationary vents, as site-wide requirements. These requirements were designated as site-wide since many sites have numerous stationary vents and each must comply with the appropriate opacity limit.

Since multiple permit applications may be submitted for a site, these site-wide requirements and their applicability then become specific to the application area. Applicability of these site-wide requirements is then done on an area-wide basis. When a single permit application is submitted for the entire site, these site-wide requirements and their applicability again become specific to the application area that is the entire site.

The primary purpose of this form is to determine applicability of site-wide requirements for emission units or activities in the application area through a series of questions. Applicability, both positive and negative, of the site-wide requirements is determined by reviewing the answers to the questions that describe the site, or application area. Please read the entire question before indicating “YES”, “NO”, or “N/A” (not applicable) with an “X” in the appropriate box next to each question (please refer to the instructions for each question to determine if “N/A” is an appropriate response. If “N/A” is not an available response, there is no corresponding box on the form. Once these questions have been answered, repeating the site-wide requirements on Form OPREQ2 (Negative Applicable Requirements Determinations) or Form OP-REQ3 (Applicable Requirements Summary) in the permit application on a unit-by-unit basis is not necessary. Additionally, attribute information relating to these site-wide requirements on any unit attribute form need not appear in the permit application, unless specified in these instructions.

Where possible, directions are given on the form itself enabling the applicant to skip certain questions based on answers to previous questions. Applicants are advised to take advantage of this opportunity as appropriate, not all questions require answers.

High-level applicability determinations for potentially applicable requirements are also indicated on this form without having to demonstrate the applicability for individual units on other forms in the permit application. For example, “The application area includes units specified in 30 TAC § 117.1000, 117.1200, or 117.1300” is a question on the form. If the response to this question is “YES,” additional attribute information and

applicability determinations are necessary for these units in the permit application. If the response to this question is “NO,” applicability determinations for 30 TAC Chapter 117, Subchapter C: Combustion Control at Major Utility Electric Generation Sources in Ozone Nonattainment Areas are not necessary in the permit application.

Since questions on this form serve several functions, the instructions provide information relating to the need for additional attribute information or applicability determinations in the permit application. Please note that questions on this form relate to the specific regulation of the section in which they are located. Attribute information and applicability determinations for other regulations may also be necessary. For example, questions pertaining to steam generators under 30 TAC Chapter 111 appear in Section I.C. of this form. The questions relates only to the applicability of 30 TAC § 111.153(a) and 111.153(c) and are designed to determine whether additional information is necessary on OP-UA forms for 30 TAC § 111.153(a) and 111.153(c) or if only site-wide requirements apply. Additional attribute questions relating to steam generation for potentially applicable requirements [i.e., Title 40 Code of Federal Regulations Part 60,

Subparts D - Dc; 30 TAC Chapter 117, etc.] should be completed on the appropriate OP-UA forms in the permit application. Applicability determinations for the potentially applicable requirements should also be made in the permit application. Please refer to the “Unit Attribute Series Forms” and “Potentially Applicable Requirements Series Forms” if additional attribute information or applicability determinations are necessary.

The TCEQ regulated entity reference number (RNXXXXXXXXX), if assigned, and the application area name from Form OP-1 (Site Information Summary) must appear on the header of each page for purposes of identification for the initial submittal. The date of the initial submittal must also be included and should be consistent throughout the application (MM/DD/YYYY). Leave the permit number blank for the initial form submittal. If this form is included as part of the permit revision process, enter the permit number assigned by the TCEQ, the area name from Form OP-1, the date of the revision submittal, and the regulated entity reference number. When applying for a revision or renewal, all “YES/NO/N/A” questions must be answered as directed by the form instructions. For the New Source Review (NSR) authorization section, you only need to include information for the new or changed NSR authorization numbers.

The TCEQ requires that a Core Data Form be submitted on all incoming registrations unless a regulated entity reference number and customer reference number has been issued by the TCEQ and no core data information has changed. If a regulated entity reference number or customer reference number has been issued, then the number must be noted on the request or applicable form. For more information regarding the Core Data Form, call (512) 239-5175 or go to the TCEQ Web site at: www.tceq.texas.gov/permitting/central_registry/guidance.html.





Specific:

For site operating permit (SOP) applications, answer ALL questions unless otherwise directed.

  • For general operating permit (GOP) applications, answer ONLY these questions unless otherwise directed.



Form OP-REQ1 (Page 1)

I. Title 30 TAC Chapter 111 - Control of Air Pollution from Visible Emissions and Particulate Matter

A. Visible Emissions



  • 1. The application area includes stationary vents constructed on or before January 31, 1972.

Indicate “YES” if stationary vents in the application were constructed on or before January 31, 1972. Otherwise, indicate “NO.”

Question I.A.1 relates to stationary vents in the application area having a flow rate less than 100,000 actual cubic feet per minute (acfm) constructed on or before January 31, 1972. The following stationary vents should be addressed in the permit application on Form OPUA15, Tables 1a and 1b:

a. stationary vents having a flow rate greater than or equal to 100,000 acfm;

b. stationary vents for steam generators fired by solid fossil fuel, oil, or a mixture of oil and gas; or

c. stationary vents for catalyst regenerators for fluid bed catalytic cracking units.


  • 2. The application area includes stationary vents constructed after January 31, 1972.

Indicate “YES” if stationary vents in the application area were constructed after January 31, 1972. Otherwise, indicate “NO.”

Question I.A.2 relates to stationary vents in the application area having a flow rate less than 100,000 actual cubic feet per minute (acfm) constructed after January 31, 1972. The following stationary vents should be addressed in the permit application on Form OP-UA15, Tables 1a and 1b:

a. stationary vents having a flow rate greater than or equal to 100,000 acfm;

b. stationary vents for steam generators fired by solid fossil fuel, oil, or a mixture of oil and gas; or

c. stationary vents for catalyst regenerators for fluid bed catalytic cracking units.

Note: If the response to both Question I.A.1. and I.A.2. is “NO,” go to Question I.A.6. If the response to Question I.A.1. is “NO” and the response to Question I.A.2. is “YES,” go to Question I.A.4.


  • 3. The application area is opting to comply with the requirements for stationary vents constructed after January 31, 1972 for vents in the application area constructed on or before January 31, 1972.

Indicate “YES,” or “NO.”

Question I.A.3. relates to stationary vents in the application having a flow rate less than 100,000 acfm constructed on or before January 31, 1972. Applicants have the option to comply with the requirements of 30 TAC § 111.111(a)(1)(B) as contained in the Special Terms and Conditions of the permit in lieu of providing information on those stationary vents on Form OPUA15, Tables 1a and 1b. If the response to Question I.A.3. is “NO,” please provide unit specific information on all stationary vents constructed on or before January 31, 1972 on Form OP-UA15, Tables 1a and 1b.



  • 4. All stationary vents are addressed on a unit specific basis.

Indicate “YES” if all stationary vents are listed individually on Form OP-SUM and addressed on Form OP-UA15, Tables 1a and 1b. Otherwise, indicate “NO.”

Question I.A.4. relates to all stationary vents in the application area having a flow rate less than 100,000 acfm. Questions I.A.1. and I.A.2. are designed to determine if the application area has vents for which requirements may be addressed in a Special Term and Condition in the permit.

The applicant may opt to address all such stationary vents in the application on Forms OP-SUM and OPUA15, Tables 1a and 1b, in lieu of the Special Term and Condition. By answering Question I.A.3. “YES,” the applicant indicates that all stationary vents with a flow rate less than 100,000 acfm are addressed on Form OP-UA15 and the Special Term and Condition should not be included in the permit.

Note: If the response to Question I.A.4. is “YES,” go to Question I.A.6.


  • 5. Stationary vents are subject to compliance assurance monitoring requirements.

Indicate “YES” if there are stationary vents with a flow rate less than 100,000 acfm that are major sources and subject to CAM requirements and are listed individually on Form OP-SUM and addressed on Form OP-UA15, Tables 1a and 1b. Otherwise, indicate “NO.”

Question I.A.5. relates to stationary vents in the application area having a flow rate less than 100,000 acfm that are major sources. These vents should be addressed in the application on Forms OP-SUM and OPUA15, Tables 1a and 1b. By answering Question I.A.5. “YES,” the applicant indicates that stationary vents with a flow rate less than 100,000 acfm subject to CAM are addressed on Form OP-UA15. These vents will have applicable requirements addressed in the Applicable Requirements Summary of the permit and will not be subject to the requirements of the Special Terms and Conditions.



  • 6. Test Method 9 (40 CFR Part 60, Appendix A, Method 9 - Visual Determination of the Opacity of Emissions from Stationary Sources) is used to determine opacity of emissions in the application area.

Indicate “YES” if 40 CFR Part 60, Appendix A, Method 9 (Visual Determination of the Opacity of Emissions from Stationary Sources) is used to determine the opacity of emissions in the application area. Otherwise, indicate “NO.”

  • 7. The application area includes structures subject to 30 TAC § 111.111(a)(7)(A).

Indicate “YES” if structures in the application area are subject to the opacity requirements of 30 TAC § 111.111(a)(7)(A). Otherwise, indicate “NO.”

Additional questions relating the applicability of 30 TAC § 111.111(a)(7)(A) for structures in the application area do not appear on UA forms. Applicability determinations for this requirement need not be addressed on any other form in the permit application.



  • 8. The application area includes sources other than those specified in 30 TAC § 111.111(a)(1), (4), or (7) subject to 30 TAC § 111.111(a)(8)(A).

Indicate “YES” if sources other than stationary vents, flares, or structures in the application area are subject to the opacity requirements of 30 TAC § 111.111(a)(8)(A). Otherwise, indicate “NO.”

Additional questions relating the applicability of 30 TAC § 111.111(a)(8)(A) for sources other than those specified in 30 TAC § 111.111(a)(1), (4), or (7) in the application area do not appear on a UA forms. Applicability determinations for this requirement need not be addressed on any other form in the permit application.



  • 9. Emissions from units in the application area include contributions from uncombined water.

Indicate “YES” or “NO.”

  • 10. The application area is located in the City of El Paso, including Fort Bliss Military Reservation, and includes solid fuel heating devices subject to 30 TAC § 111.111(c).

For SOP applications and Municipal Solid Waste Landfill GOP (GOP 517) applications, indicate “YES” or “NO.” Otherwise, indicate “N/A.”

Additional questions relating the applicability of 30 TAC § 111.111(c) for solid fuel heating devices in the city of El Paso, including the Fort Bliss Military Reservation, do not appear on UA forms. Applicability determinations for this requirement need not be addressed on any other form in the permit application.





Form OP-REQ1 (Page 2)

I. Title 30 TAC Chapter 111 - Control of Air Pollution from Visible Emissions and Particulate Matter (continued)

B. Materials Handling, Construction, Roads, Streets, Alleys, and Parking Lots

All questions relating the applicability of 30 TAC Chapter 111 requirements for materials handling, construction, roads, streets, alleys, and parking lots are contained in this section. Applicability determinations for these requirements need not be addressed on any other form in the permit application.

1. Items a - d determine applicability of any of these requirements based on geographical location.


  • a. The application area is located within the city of El Paso.

Indicate “YES” or “NO.”

  • b. The application area is located within the Fort Bliss Military Reservation, except areas specified in 30 TAC § 111.141.

Indicate “YES” or “NO.”

  • c. The application area is located in the portion of Harris County inside the loop formed by Beltway 8.

Indicate “YES” or “NO.”

  • d. The application area is located in the area of Nueces County outlined in Group II state implementation plan (SIP) for inhalable particulate matter adopted by the TCEQ on May 13, 1988.

Boundary description for the Nueces county Group II area: A portion of the city of Corpus Christi, delimited as follows: Nueces Bay on the north, Ocean Drive on the east, Highway 44 on the south, and due north from Highway-44 at the intersection of Highway 358 to Nueces Bay on the west.

Indicate “YES” or “NO.”



Note: If there is any “YES” response to Questions I.B.1.a through d, answer Questions I.B.2.a - d.

If all responses to Questions I.B.1.a - d are “NO,” go to Section I.C.


2. Items a - d determine the specific applicability of these requirements.

  • a. The application area is subject to 30 TAC § 111.143.

Indicate “YES” if the application area is subject to the material handling requirements of 30 TAC § 111.143. Otherwise, indicate “NO.”

  • b. The application area is subject to 30 TAC § 111.145.

Indicate “YES” if the application area is subject to the construction and demolition requirements of 30 TAC § 111.145. Otherwise, indicate “NO.”

  • c. The application area is subject to 30 TAC § 111.147.

Indicate “YES” if the application area is subject to the road, street, and alley requirements of 30 TAC § 111.147. Otherwise, indicate “NO.”

  • d. The application area is subject to 30 TAC § 111.149.

Indicate “YES” if the application area is subject to the parking lot requirements of 30 TAC § 111.149. Otherwise, indicate “NO.”

C. Emissions Limits on Nonagricultural Processes

  • 1. The application area includes nonagricultural processes subject to 30 TAC § 111.151.

Indicate “YES” or “NO.”

2. The application area includes vents from nonagricultural process that are subject additional monitoring requirements.


Indicate “YES” or “NO.”

Question I.C.2. relates to stationary vents (stacks) from nonagricultural processes in the application area that are major sources of particulate matter and are, therefore, subject to compliance assurance monitoring (CAM) or have actual emissions of particulate matter that exceed 50 tons per year and are, therefore, subject to periodic monitoring requirements. These vents should be addressed in the application on Forms OP-SUM and OP-UA15, Table 15. By answering Question I.C.2. “YES,” the applicant indicates that these stationary vents subject to CAM or periodic monitoring requirements are addressed on Form OP-UA15. These vents will have applicable requirements addressed in the Applicable Requirements Summary of the permit and will not be subject to the requirements of the Special Terms and Conditions.

If the response to Question I.C.2. is “NO,” applicability determinations for this requirement need not be addressed on any other form in the permit application.

Note: If the response to Question I.C.2. is “NO,” go to Question I.C.4.

3. All vents from nonagricultural process in the application area are subject to additional monitoring requirements.


Indicate “YES” or “NO.”

Question I.C.3. relates to all stationary vents from nonagricultural processes in the application area. Question I.C.1.is designed to determine if the application area has vents for which requirements may be addressed in a Special Term and Condition in the permit. By answering Question I.C.3. “YES,” the applicant indicates that all stationary vents from nonagricultural processes are addressed on Form OP-UA15 and the Special Term and Condition should not be included in the permit.





Form OP-REQ1 (Page 3)

I. Title 30 TAC Chapter 111 - Control of Air Pollution from Visible Emissions and Particulate Matter (continued)

C. Emissions Limits on Nonagricultural Processes

4. The application area includes oil or gas fuel-fired steam generators subject to 30 TAC §§ 111.153(a) and 111.153(c).

Indicate “YES” if the application area includes oil or gas fuel-fired steam generators with a heat input greater than 2500 MMBtu, averaged over a two-hour period, and subject to 30 TAC §§ 111.153(a) and 111.153(c). Otherwise, indicate “NO.”

5. The application area includes oil or gas fuel-fired steam generators that are subject to additional monitoring requirements.


Indicate “YES” or “NO.”

Question I.C.5. relates to oil or gas fuel-fired steam generators in the application area that are major sources of particulate matter and are, therefore, subject to compliance assurance monitoring (CAM) or have actual emissions of particulate matter that exceed 50 tons per year and are, therefore, subject to periodic monitoring requirements. These steam generators should be addressed in the application on Forms OPSUM and OP-UA06, Table 12. By answering Question I.C.5. “YES,” the applicant indicates that these steam generators subject to CAM or periodic monitoring are addressed on Form OP-UA06. These vents will have applicable requirements addressed in the Applicable Requirements Summary of the permit and will not be subject to the requirements of the Special Terms and Conditions.

If the response to Question I.C.5. is “NO,” applicability determinations for this requirement need not be addressed on any other form in the permit application.

Note: If the response to Question I.C.5. is “NO,” go to Question I.C.7

6. All oil or gas fuel-fired steam generators in the application area are subject to additional monitoring requirements.


Indicate “YES” or “NO.”

Question I.C.6. relates to all oil or gas fuel-fired steam generators in the application area. Question I.C.4.is designed to determine if the application area has oil or gas fuel-fired steam generators for which requirements may be addressed in a Special Term and Condition in the permit. By answering Question I.C.6. “YES,” the applicant indicates that all oil or gas fuel-fired steam generators are addressed on Form OP-UA06 and the Special Term and Condition should not be included in the permit.

7. The application area includes solid fossil fuel-fired steam generators subject to 30 TAC §§ 111.153(a) and 111.153(b).

Indicate “YES” if the application area includes solid fossil fuel-fired steam generators with a heat input greater than 2500 MMBtu, averaged over a two-hour period, and subject to 30 TAC §§ 111.153(a) and 111.153(b). Otherwise, indicate “NO.”


8. The application area includes solid fossil fuel-fired steam generators that are subject to additional monitoring requirements.
Indicate “YES” or “NO.”

Question I.C.8. relates to solid fossil fuel-fired steam generators in the application area that are major sources of particulate matter and are, therefore, subject to compliance assurance monitoring (CAM) or have actual emissions of particulate matter that exceed 50 tons per year and are, therefore, subject to periodic monitoring requirements. These steam generators should be addressed in the application on Forms OPSUM and OPUA06, Table 12. By answering Question I.C.8. “YES,” the applicant indicates that these steam generators subject to CAM or periodic monitoring requirements are addressed on Form OP-UA06. These vents will have applicable requirements addressed in the Applicable Requirements Summary of the permit and will not be subject to the requirements of the Special Terms and Conditions.

If the response to Question I.C.8. is “NO,” applicability determinations for this requirement need not be addressed on any other form in the permit application.

Note: If the response to Question I.C.8. is “NO,” go to Section I.D.

9. All solid fossil fuel-fired steam generators in the application area are subject to additional monitoring requirements.


Indicate “YES” or “NO.”

Question I.C.9. relates to all oil or gas fuel-fired steam generators in the application area. Question I.C.7.is designed to determine if the application area has solid fossil fuel-fired steam generators for which requirements may be addressed in a Special Term and Condition in the permit. By answering Question I.C.9. “YES,” the applicant indicates that all solid fossil fuel-fired steam generators are addressed on Form OP-UA06 and the Special Term and Condition should not be included in the permit.



D. Emissions Limits on Agricultural Processes

1. The application area includes agricultural processes subject to 30 TAC § 111.171.

Indicate “YES” or “NO.”

Additional questions relating to the applicability of 30 TAC § 111.171 for agricultural processes do not appear on UA forms. Applicability determinations for this requirement need not be addressed on any other form in the permit application.



E. Outdoor Burning

All questions relating to the applicability of 30 TAC Chapter 111 requirements for outdoor burning are contained in this section. Applicability determinations for these requirements need not be addressed on any other form in the permit application.



  • 1. Outdoor burning is conducted in the application area.

Indicate “YES” or “NO.”

Note: If the response to Question I.E.1 is “NO,” go to Section II.

  • 2. Fire training is conducted in the application area and subject to the exception provided in 30 TAC § 111.205.

Indicate “YES” or “NO.”

  • 3. Fires for recreation, ceremony, cooking, and warmth are used in the application area and subject to the exception provided in 30 TAC § 111.207.

Indicate “YES” or “NO.”

  • 4. Disposal fires are used in the application area and subject to the exception provided in 30 TAC § 111.209.

Indicate “YES” or “NO.”



Form OP-REQ1 (Page 4)

I. Title 30 TAC Chapter 111 - Control of Air Pollution from Visible Emissions and Particulate Matter (continued)

E. Outdoor Burning (continued)

  • 5. Prescribed burning is used in the application area and subject to the exception provided in 30 TAC § 111.211.

Indicate “YES” or “NO.”

  • 6. Hydrocarbon burning is used in the application area and subject to the exception provided in 30 TAC § 111.213.

Indicate “YES” or “NO.”

  • 7. The application area has received the TCEQ Executive Director approval of otherwise prohibited outdoor burning according to 30 TAC § 111.215.

Indicate “YES” or “NO.”

II. Title 30 TAC Chapter 112 - Control of Air Pollution from Sulfur Compounds

A. Temporary Fuel Shortage Requirements

1. The application area includes units that are potentially subject to the temporary fuel shortage plan requirements of 30 TAC §§ 112.15 - 112.18.

Indicate “YES” or “NO.”

Additional questions relating the applicability of 30 TAC §§ 112.15 - 112.18 requirements for temporary fuel shortage plans do not appear on UA forms. Applicability determinations for this requirement need not be addressed on any other form in the permit application. However, additional questions for 30 TAC Chapter 112 requirements may appear in UA forms for other regulations. Applicability determinations may then be necessary for these regulations.

The geographic location of the application area will often determine the applicability of potentially applicable requirements based on the SIP. The applicant is cautioned that in some instances the counties cited in the TCEQ regulation may cover more than the designated “nonattainment” counties for the pollutant.

III. Title 30 TAC Chapter 115 – Control of Air Pollution from Volatile Organic Compounds

A. Applicability


  • 1. The application area is located in the Houston/Galveston/Brazoria area, Beaumont/Port Arthur area, Dallas/Fort Worth area, El Paso area, or a covered attainment county as defined by 30 TAC § 115.10.

Indicate “YES” or “NO.”

The counties affected by Chapter 115 include: Anderson, Angelina, Aransas, Atascosa, Austin, Bastrop, Bee, Bell, Bexar, Bosque, Bowie, Brazos, Brazoria, Burleson, Caldwell, Calhoun, Camp, Cass, Chambers, Cherokee, Collin, Colorado, Comal, Cooke, Coryell, Dallas, Denton, De Witt, Delta, Ellis, El Paso, Falls, Fannin, Fayette, Fort Bend, Franklin, Freestone, Galveston, Goliad, Gonzales, Grayson, Gregg, Grimes, Guadalupe, Hardin, Harris, Harrison, Hays, Henderson, Hill, Hood, Hopkins, Houston, Hunt, Jackson, Jasper, Jefferson, Johnson, Karnes, Kaufman, Lamar, Lavaca, Lee, Leon, Liberty, Limestone, Live Oak, Madison, Marion, Matagorda, McLennan, Milam, Montgomery, Morris, Nacogdoches, Navarro, Newton, Nueces, Orange, Panola, Parker, Polk, Rains, Red River, Refugio, Robertson, Rockwall, Rusk, Sabine,

San Augustine, San Jacinto, San Patricio, Shelby, Smith, Somervell, Tarrant, Titus, Travis, Trinity, Tyler, Upshur, Van Zandt, Victoria, Walker, Waller, Washington, Wharton, Williamson, Wilson, Wise, or Wood County.

If the response to Question III.A.1 is “NO,” negative applicability determinations for 30 TAC Chapter 115 are not necessary in the permit application.



Note: If the response to Question III.A.1 is “NO,” go to Section IV.

B. Storage of Volatile Organic Compounds

  • 1. The application area includes storage tanks, reservoirs, or other containers capable of maintaining working pressure sufficient at all times to prevent any VOC vapor or gas loss to the atmosphere.

Indicate “YES” or “NO.”



Form OP-REQ1 (Page 5)

III. Title 30 TAC Chapter 115 – Control of Air Pollution from Volatile Organic Compounds (continued)

C. Industrial Wastewater

1. The application area includes affected VOC wastewater streams of an affected source category, as defined in 30 TAC § 115.140.

For an application area located in the following counties, indicate “YES” or “NO”: Brazoria, Chambers, Collin, Dallas, Denton, Ellis, El Paso, Fort Bend, Galveston, Hardin, Harris, Jefferson, Johnson, Kaufman, Liberty, Montgomery, Orange, Parker, Rockwall, Tarrant, or Waller. Otherwise, indicate “N/A.”

If the response to Question III.C.1 is “NO” or “N/A”, additional attribute information and applicability determinations are not necessary in the permit application for 30 TAC Chapter 115, Industrial Wastewater. However, attribute information and applicability determinations may be necessary for other regulations.



Note: If the response to Question III.C.1 is “NO” or “N/A,” go to Section III.D.

2. The application area is located at a petroleum refinery in the Beaumont/Port Arthur or Houston/Galveston/Brazoria area.

Indicate “YES” or “NO.”

If the response to Question III.C.2 is “YES”, and the refinery is located in the Beaumont/Port Arthur area additional attribute information and applicability determinations are not necessary in the permit application for 30 TAC Chapter 115, Industrial Wastewater. However, attribute information and applicability determinations may be necessary for other regulations.

If the response to Question III.C.2 is “YES”, and the refinery is located in the Houston/Galveston/Brazoria area additional attribute information and applicability determinations are not necessary in the permit application for 30 TAC Chapter 115, Industrial Wastewater. Attribute information and applicability determinations may also be necessary for other regulations.

Note: If the response to Question III.C.2 is “YES” and the refinery is located in the Beaumont/Port Arthur area, go to Section III.D.
3. The application area is complying with the provisions of 40 CFR Part 63, Subpart G, as an alternative to complying with this division (relating to Industrial Wastewater).

Indicate “YES” or “NO.”

If the response to Question III.C.3 is “YES”, additional attribute information and applicability determinations are not necessary in the permit application for 30 TAC Chapter 115, Industrial Wastewater. However, attribute information and applicability determinations may be necessary for 40 CFR Part 63, Subpart G and/or other regulations.

Note: If the response to Question III.C.3 is “YES,” go to Section III.D.

4. The application area is located at a plant with an annual VOC loading in wastewater, as determined in accordance with 30 TAC § 115.148, less than or equal to 10 Mg (11.03 tons).

Indicate “YES” or “NO.”

If the response to Question III.C.4 is “YES”, additional unit attribute information and applicability determinations are not necessary in the permit application for 30 TAC Chapter 115, Industrial Wastewater. However, attribute information and applicability determinations will be necessary in the permit application if the response to this question is “NO.” Additional attribute information and applicability determinations may also be necessary for other regulations.



Note: If the response to Question III.C.4 is “YES,” go to Section III.D.

5. The application area includes wastewater drains, junction boxes, lift stations, or weirs that are subject to the control requirements of 30 TAC § 115.142(1).

Indicate “YES” or “NO.”

If the application area includes any wastewater drains, junction boxes, lift stations, or weirs with vented covers equipped with a vapor control system in accordance with 30 TAC

§ 115.142(1)(D)(i) - (ii), complete Form OP-UA52 (Closed Vent System and Control Device Attributes).

6. The application area includes wastewater drains, junction boxes, lift stations, or weirs that handle streams chosen for exemption under 30 TAC § 115.147(2).

Indicate “YES” or “NO.”

7. The application area includes wastewater drains, junction boxes, lift stations, or weirs that have executive director approved exemption under 30 TAC § 115.147(4).

Indicate “YES” or “NO.”

D. Loading and Unloading of VOCs


  • 1. The application area includes VOC loading operations.

Indicate “YES” if land-based loading of VOC into transport vessels or tank-truck tanks occurs in the application area or if loading of VOC into marine vessels occurs in the application area. Otherwise, indicate “NO.”



  • 2. The application area includes VOC transport vessel unloading operations.

Indicate “YES” or “NO.”

Under 30 TAC Chapter 115, a transport vessel is defined as “any land-based mode of transportation (truck or rail) that is equipped with a storage tank having a capacity greater than 1,000 gallons which is used primarily to transport oil, gasoline, or other volatile organic liquid bulk cargo. Vacuum trucks used exclusively for maintenance and spill response are not considered to be transport vessels.”



Note: If the responses to Questions III.D.1 - D.2, are “NO,” go to Section III.E.

If the responses to Questions III.D.1 - D.2 are “NO,” additional attribute information and applicability determinations are not necessary in the permit application. If the response to either of these questions is “YES,” complete Question III.D.3. If the response to Question III.D.1. is “YES”, provide either negative applicability determinations on Form OP-REQ2 or unit attribute information on Form OP-UA04, Tables 1a and 1b and applicability determinations on Form OPREQ3.





Form OP-REQ1 (Page 6)

III. Title 30 TAC Chapter 115 – Control of Air Pollution from Volatile Organic Compounds (continued)

D. Loading and Unloading of VOCs (continued)

  • 3. Transfer operations at motor vehicle fuel dispensing facilities are the only VOC transfer operations conducted in the application area.

Indicate “YES” or “NO.”

If the response to Question III.D.3. is “NO” and the response to Question III.D.2. is “YES”, provide either negative applicability determinations on Form OP-REQ2 or unit attribute information on Form OP-UA04, Tables 1a and 1b and applicability determinations on Form OPREQ3.



E. Filling of Gasoline Storage Vessels (Stage I) for Motor Vehicle Fuel Dispensing Facilities

All questions relating to the applicability of 30 TAC Chapter 115 requirements for the filling of gasoline storage vessels (Stage I) for motor vehicle fuel dispensing facilities are contained in this section. Applicability determinations for these requirements need not be addressed on any other form in the permit application.



  • 1. The application area includes one or more motor vehicle fuel dispensing facilities and gasoline transferred from a tank-truck tank into a stationary storage container.

Indicate “YES” or “NO.”

Note: If the response to Question III.E.1 is “NO,” go to Section III.F.

  • 2. Transfers to stationary storage containers used exclusively for the fueling of agricultural implements are the only transfer operations conducted at facilities in the application area.

Indicate “YES” or “NO.”

  • 3. All transfers at facilities in the application area are made into stationary storage containers with internal floating roofs, external floating roofs, or their equivalent.

Indicate “YES” or “NO.”

Note: If the response to Question III.E.2 and/or E.3 is “YES,” go to Section III.F.


  • 4. The application area is located in a covered attainment county as defined in 30 TAC § 115.10.

Indicate “YES” or “NO.”

Note: If the response to Question III.E.4 is “NO,” go to Question III.E.9.

Covered attainment counties for Filling of Gasoline Storage Vessels (Stage I) for Motor Vehicle Fuel Dispensing Facilities: Anderson, Angelina, Aransas, Atascosa, Austin, Bastrop, Bee, Bell, Bexar, Bosque, Bowie, Brazos, Burleson, Caldwell, Calhoun, Camp, Cass, Cherokee, Colorado, Comal, Cooke, Coryell, De Witt, Delta, Falls, Fannin, Fayette, Franklin, Freestone, Goliad, Gonzales, Grayson, Gregg, Grimes, Guadalupe, Harrison, Hays, Henderson, Hill, Hood, Hopkins, Houston, Hunt, Jackson, Jasper, Karnes, Lamar, Lavaca, Lee, Leon, Limestone, Live Oak, Madison, Marion, Matagorda, McLennan, Milam, Morris, Nacogdoches, Navarro, Newton, Nueces, Panola, Polk, Rains, Red River, Refugio, Robertson, Rusk, Sabine, San Augustine, San Jacinto, San Patricio, Shelby, Smith, Somervell, Titus, Travis, Trinity, Tyler, Upshur, Van Zandt, Victoria, Walker, Washington, Wharton, Williamson, Wilson, Wise, or Wood County.



  • 5. Stationary gasoline storage containers with a nominal capacity less than or equal to 1,000 gallons are located at the facility.

Indicate “YES” or “NO.”

  • 6. Stationary gasoline storage containers with a nominal capacity greater than 1,000 gallons are located at the facility.

Indicate “YES” or “NO.”

  • 7. At facilities located in a covered attainment county other than Bastrop, Bexar, Caldwell, Comal, Guadalupe, Hays, Travis, Williamson, or Wilson County, transfers are made to stationary storage tanks greater than 1000 gallons located at a facility which has dispensed less than 100,000 gallons of gasoline in a calendar month after October 31, 2014.

Indicate “YES” or “NO.”

Note: If the response to Question III.E.7 is “YES,” go to Section III.F.



Form OP-REQ1 (Page 7)

III. Title 30 TAC Chapter 115 – Control of Air Pollution from Volatile Organic Compounds (continued)

E. Filling of Gasoline Storage Vessels (Stage I) for Motor Vehicle Fuel Dispensing Facilities (continued)

  • 8. At facilities located in Bastrop, Bexar, Caldwell, Comal, Guadalupe, Hays, Travis, Williamson, or Wilson County, transfers are made to stationary storage tanks greater than 1000 gallons located at a facility which has dispensed no more than 25,000 gallons of gasoline in a calendar month after December 31, 2004.

Indicate “YES” or “NO.”

Note: If the response to Question III.E.8 is “YES,” go to Section III.F.

  • 9. Transfers are made to stationary storage tanks located at a motor vehicle fuel dispensing facility which has dispensed no more than 10,000 gallons of gasoline in any calendar month after January 1, 1991 and for which construction began prior to November 15, 1992.

Indicate “YES” or “NO.”

  • 10. Transfers are made to stationary storage tanks located at a motor vehicle fuel dispensing facility which has dispensed more than 10,000 gallons of gasoline in any calendar month after January 1, 1991 and for which construction began prior to November 15, 1992.

Indicate “YES” or “NO.”

  • 11. Transfers are made to stationary storage tanks located at a motor vehicle fuel dispensing facility which commenced construction on or after November 15, 1992.

Indicate “YES” or “NO.”

  • 12. At facilities located in Ellis, Johnson, Kaufman, Parker, or Rockwall County, transfers are made to stationary storage tanks located at a facility which has dispensed at least 10,000 gallons of gasoline but less than 125,000 gallons of gasoline in a calendar month after April 30, 2005.

Indicate “YES” or “NO.”

F. Control of Leaks from Transport Vessels (Complete this section for GOP applications for GOPs 511, 512, 513 or 514 only.)

All questions relating the applicability of 30 TAC Chapter 115 requirements for the control of VOC leaks from transport vessels are contained in this section. Applicability determinations for these requirements need not be addressed on any other form in the permit application.



  • 1. Tank-truck tanks are filled with or emptied of gasoline at a facility that is subject to 30 TAC § 115.214(a)(1)(C) or 115.224(2) within the application area.

For an application area located in one of the following counties, indicate “YES” or “NO”: Brazoria, Chambers, Collin, Dallas, Denton, Ellis, El Paso, Fort Bend, Galveston, Hardin, Harris, Jefferson, Johnson, Kaufman, Liberty, Montgomery, Orange, Parker, Rockwall, Tarrant, or Waller. Otherwise, indicate “N/A.”



Form OP-REQ1 (Page 8)

III. Title 30 TAC Chapter 115 – Control of Air Pollution from Volatile Organic Compounds (continued)

F. Control of Leaks from Transport Vessels (Complete this section for GOP applications for GOPs 511, 512, 513 or 514 only.) (continued)

  • 2. Tank-truck tanks are filled with non-gasoline VOCs having a TVP greater than or equal to 0.5 psia under actual storage conditions at a facility subject to 30 TAC § 115.214(a)(1)(C) within the application area.

For an application area located in one of the following counties, indicate “YES” or “NO”: Brazoria, Chambers, Collin, Dallas, Denton, Ellis, El Paso, Fort Bend, Galveston, Hardin, Harris, Jefferson, Johnson, Kaufman, Liberty, Montgomery, Orange, Parker, Rockwall, Tarrant, or Waller. Otherwise, indicate “N/A.”

  • 3. Tank-truck tanks are filled with, or emptied of, gasoline at a facility that is subject to 30 TAC § 115.214(b)(1)(C) or 115.224(2) within the application area.

For an application area located in one of the covered attainment counties, as defined in 30 TAC § 115.10, indicate “YES” or “NO.” For counties other than the covered attainment counties, indicate “N/A.”

G. Control of Vehicle Refueling Emissions (Stage II) at Motor Vehicle Fuel Dispensing Facilities

All questions relating the applicability of 30 TAC Chapter 115 requirements for the control of vehicle refueling emissions (Stage II) at motor vehicle fuel dispensing facilities are contained in this section. Applicability determinations for these requirements need not be addressed on any other form in the permit application.



  • 1. The application area includes one or more motor vehicle fuel dispensing facilities and gasoline is transferred from a stationary storage container into motor vehicle fuel tanks.

For an application area located in one of the following counties, indicate “YES” or “NO”: Brazoria, Chambers, Collin, Dallas, Denton, El Paso, Fort Bend, Galveston, Hardin, Harris, Jefferson, Liberty, Montgomery, Orange, Tarrant, or Waller. Otherwise, indicate “N/A.”

Note: If the response to Question III.G.1 is “NO” or “N/A,” go to Section III.H.

  • 2. The application area includes facilities that began construction on or after November 15, 1992 and prior to May 16, 2012.

Indicate “YES” or “NO.”

  • 3. The application area includes facilities that began construction prior to November 15, 1992.

Indicate “YES” or “NO.”

Note: If the response to Questions III.G.2. and III.G.3. are both “NO,” go to Section III.H.

  • 4. The application area includes only facilities that have a monthly throughput of less than 10,000 gallons of gasoline.

Indicate “YES” or “NO.”

5. The decommissioning of all Stage II vapor recovery control equipment located in the application area has been completed and the decommissioning notice has been submitted.


Indicate “YES” if decommissioning activities have been completed and the decommissioning completion notice required under 30 TAC § 115.241(b)(4) has been submitted. Otherwise, indicate “NO.”

Decommissioning activities may not commence prior to 30 days after the effective date of the United States Environmental Protection Agency’s approval of the repeal of the Stage II vapor recovery requirements and adoption of decommissioning requirements and must be completed no later than August 31, 2018.





Form OP-REQ1 (Page 9)

III. Title 30 TAC Chapter 115 – Control of Air Pollution from Volatile Organic Compounds (continued)

H. Control of Reid Vapor Pressure (RVP) of Gasoline

All questions relating the applicability of 30 TAC Chapter 115 requirements for the control of RVP of gasoline in El Paso County are contained in this section. Applicability determinations for these requirements need not be addressed on any other form in the permit application.



  • 1. The application area includes stationary tanks, reservoirs, or other containers holding gasoline that may ultimately be used in a motor vehicle in El Paso County.

For an application area located in El Paso County indicate “YES” or “NO.”

For an application area located in a county other than El Paso County, indicate “N/A.”



Note: For SOP applications, if the response to Question III.H.1 is “NO” or “N/A,” go to Section III.I.

For GOP applications, if the response to Question III.H.1 is “NO” or “N/A,” go to Section III.J.

  • 2. The application area includes stationary tanks, reservoirs, or other containers holding gasoline that will be used exclusively for the fueling of agricultural implements.

Indicate “YES” or “NO.”

  • 3. The application area includes a motor vehicle fuel dispensing facility.

Indicate “YES” or “NO.”

  • 4. The application area includes stationary tanks, reservoirs, or other containers holding gasoline and having a nominal capacity of 500 gallons or less.

Indicate “YES” or “NO.”

I. Process Unit Turnaround and Vacuum-Producing Systems in Petroleum Refineries

1. The application area is located at a petroleum refinery.

Indicate “YES” or “NO.”

J. Surface Coating Processes (Complete this section for GOP applications only.)


  • 1. Surface coating operations (other than those performed on equipment located on-site and in place) that meet the exemption specified in 30 TAC § 115.427(a)(3)(A) or 115.427(b)(1) are performed in the application area.

For GOP applications with an application area located in one of the following counties, indicate “YES” or “NO”: Brazoria, Chambers, Collin, Dallas, Denton, Ellis, El Paso, Fort Bend, Galveston, Gregg, Hardin, Harris, Jefferson, Johnson, Kaufman, Liberty, Montgomery, Nueces, Orange, Parker, Rockwall, Tarrant, Victoria, or Waller. Otherwise, indicate “N/A.”

Note: GOP applicants go to Section III.L.



Form OP-REQ1 (Page 10)

III. Title 30 TAC Chapter 115 – Control of Air Pollution from Volatile Organic Compounds (continued)

K. Cutback Asphalt

All questions relating to the applicability of 30 TAC Chapter 115, Subchapter F, Division 1: Cutback Asphalt are contained in this section. Applicability determinations for these requirements need not be addressed on any other form in the permit application.

1. Conventional cutback asphalt containing VOC solvents for the paving of roadways, driveways, or parking lots, is used or specified for use in the application area by a state, municipal, or county agency.

For an application area located in one of the following counties, indicate “YES” or “NO”: Bastrop, Brazoria, Caldwell, Chambers, Collin, Dallas, Denton, Ellis, El Paso, Fort Bend, Galveston, Hardin, Harris, Hays, Jefferson, Johnson, Kaufman, Liberty, Montgomery, Nueces, Orange, Parker, Rockwall, Tarrant, Travis, Waller, or Williamson County. Otherwise, indicate “N/A.”



Note: If the response to Question III.K.1 is “N/A,” go to Section III.L.

2. The use, application, sale, or offering for sale of conventional cutback asphalt containing VOC solvents for the paving of roadways, driveways, or parking lots occurs in the application area.

For an application area located in one of the following counties, indicate “YES” or “NO”: Bastrop, Brazoria, Caldwell, Chambers, Collin, Dallas, Denton, Ellis, El Paso, Fort Bend, Galveston, Hardin, Harris, Hays, Jefferson, Johnson, Kaufman, Liberty, Montgomery, Orange, Parker, Rockwall, Tarrant, Travis, Waller, or Williamson County. For an application area located in Nueces County, indicate “N/A.”
3. Asphalt emulsion is used or produced within the application area.

Indicate “YES” or “NO.”

4. The application area is using an alternate control requirement as specified in 30 TAC § 115.513.

Indicate “YES” if alternative methods of demonstrating and documenting continuous compliance with the applicable control requirements or exemption criteria in 30 TAC §§ 115.512 - 115.519 have been approved by the TCEQ executive director in accordance with 30 TAC § 115.910. Otherwise, enter “NO.”



Note: If the response to Question III.K.4. is “NO,” go to Section III.L.

5. The application area uses, applies, sells, or offers for sale asphalt concrete, made with cutback asphalt, that meets the exemption specified in 30 TAC § 115.517(1).

Indicate “YES” or “NO.”

6. The application area uses, applies, sells, or offers for sale cutback asphalt that is used solely as a penetrating prime coat.

Indicate “YES” or “NO.”

7. The applicant using cutback asphalt is a state, municipal, or county agency.

Indicate “YES” or “NO.”

L. Degassing of Storage Tanks, Transport Vessels, and Marine Vessels

All questions relating to the applicability of 30 TAC Chapter 115 requirements for the degassing during, or in preparation of, cleaning any stationary, marine, and transport vessels are contained in this section. Applicability determinations for these requirements need not be addressed on any other form in the permit application.



  • 1. The application area includes degassing during, or in preparation of, cleaning operations for stationary, marine, and/or transport vessels.

For an application area located in one of the following counties, indicate “YES” or “NO”: Brazoria, Chambers, Collin, Dallas, Denton, El Paso, Fort Bend, Galveston, Hardin, Harris, Jefferson, Liberty, Montgomery, Orange, Tarrant, or Waller. Otherwise, indicate “N/A.”

Note: If the response to Question III.L.1 is “NO” or “N/A,” go to Section III.M.

  • 2. Degassing of only ocean-going, self-propelled VOC marine vessels is performed in the application area.

For SOP applications and GOP applications for GOPs 511, 512, 513, and 514, indicate “YES” or “NO.” For GOP 517 applications, indicate “N/A.”

Note: If the response to Question III.L.2 is “YES,” go to Section III.M.


Form OP-REQ1 (Page 11)

III. Title 30 TAC Chapter 115 – Control of Air Pollution from Volatile Organic Compounds (continued)

L. Degassing of Storage Tanks, Transport Vessels, and Marine Vessels (continued)

  • 3. Degassing of stationary VOC storage vessels with a nominal storage capacity of 1,000,000 gallons or more and a vapor space partial pressure greater than or equal to 0.5 psia of VOC is performed in the application area.

For SOP applications and GOP applications for GOPs 511, 512, 513, and 514, indicate “YES” or “NO.” For GOP 517 applications, indicate “N/A.”

  • 4. Degassing of stationary VOC storage vessels with a nominal storage capacity of 250,000 gallons or more, or a nominal storage capacity of 75,000 gallons and storing materials with a true vapor pressure greater than 2.6 psia, and a vapor space partial pressure greater than or equal to 0.5 psia of VOC is performed in the application area.

Indicate “YES” or “NO.”

For SOP applications and GOP applications for GOP 511, indicate “YES” or “NO.” For GOP 512, 513, 514, and 517 applications, indicate “N/A.”



  • 5. Degassing of VOC transport vessels with a nominal storage capacity of 8,000 gallons or more and a vapor space partial pressure greater than or equal to 0.5 psia of VOC is performed in the application area.

Indicate “YES” or “NO.”

  • 6. Degassing of VOC marine vessels with a nominal storage capacity of 10,000 barrels (420,000 gallons) or more and a vapor space partial pressure greater than or equal to 0.5 psia of VOC is performed in the application area.

For SOP applications and GOP applications for GOPs 511, 512, 513, and 514, indicate “YES” or “NO.” For GOP 517 applications, indicate “N/A.”

  • 7. Degassing of VOC marine vessels with a nominal storage capacity of 10,000 barrels (420,000 gallons) and a vapor space partial pressure greater than or equal to 0.5 psia VOC that have sustained damage as specified in 30 TAC § 115.547(5) is performed in the application area.

For SOP applications and GOP applications for GOPs 511, 512, 513, and 514, indicate “YES” or “NO.” For GOP 517 applications, indicate “N/A.”

M. Petroleum Dry Cleaning Systems

1. The application area contains one or more petroleum dry cleaning facilities that use petroleum based solvents.

For an application area located in one of the following counties, indicate “YES” or “NO”: Brazoria, Chambers, Collin, Dallas, Denton, Ellis, El Paso, Fort Bend, Galveston, Hardin, Harris, Jefferson, Johnson, Kaufmann, Liberty, Montgomery, Orange, Parker, Rockwall, Tarrant, or Waller. Otherwise, indicate “N/A.”

If the response to Question III.N.1 is “YES,” provide either unit attribute information on Form OP-UA41 and provide applicability determinations on OP-REQ3 or negative applicability determinations on Form OP-REQ2. If the response to Question III.N.1 is “NO,” applicability determinations are not necessary in the permit application.




Form OP-REQ1 (Page 12)

III. Title 30 TAC Chapter 115 – Control of Air Pollution from Volatile Organic Compounds (continued)

N. Vent Gas Control (Highly-reactive volatile organic compounds (HRVOC))

1. The application area includes one or more vent gas streams containing HRVOC.

For an application area located in one of the following counties, indicate “YES” or “NO”: Brazoria, Chambers, Fort Bend, Galveston, Harris, Liberty, Montgomery, or Waller. Otherwise, indicate “N/A.”

2. The application area includes one or more flares that emit or have the potential to emit HRVOC.

For an application area located in one of the following counties, indicate “YES” or “NO”: Brazoria, Chambers, Fort Bend, Galveston, Harris, Liberty, Montgomery, or Waller. Otherwise, indicate “N/A.”

If the response to Question III.N.1. and III.N.2. are both “NO” or “N/A,” go to Section III.O. If the response to Question III.N.1. is “YES,” continue with Question III.N.3.

3. All vent streams in the application area that are routed to a flare contain less than 5.0% by weight of HRVOC at all times.

Indicate “YES” or “NO.”

4. All vent streams in the application area that are not routed to a flare contain less than 100 ppmv of HRVOC at all times.

Indicate “YES” or “NO.”

If the response to Questions III.N.3. and III.N.4 are both “NO’, go to Sections III.O.

5. The application area contains pressure relief valves that are not controlled by a flare.

Indicate “YES” or “NO.”

6. The application area has at least one vent stream which has no potential to emit HRVOC.

Indicate “YES” or “NO.”
7. The application area has vent streams from a source described in 30 TAC

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