August 23, 2010: Definition of Site Guidance Document Revised
The guidance document was reformatted to be consistent with other air permit guidance documents posted to our external website. Under the Purpose Section, the last paragraph was added to clarify that the TCEQ site definition guidance is consistent with the federal definitions of a major source as listed in 40 CFR Part 51, 40 CFR Part 70, and the SIP approved 30 TAC Chapter 122.
Furthermore, there were some clarifications made under the common control section. References to day-to-day control were removed as this was never a singular factor in determining common control. Overall operational control was emphasized as individuals who are under management higher in the organizational structure would be considered to be under common control.
Additional clarification was provided under the Leased Properties section for co-located properties. Such co-located properties are generally assumed to be under common control unless contracts, lease agreements, or other legal documentation demonstrates that the co-located properties are not dependent on one another.
Under the Oil and Gas Owned Properties Section, reference to the January 12, 2007 EPA Memorandum - Source Determinations for Oil and Gas Industries was removed as it had been rescinded by EPA’s September 22, 2009 Memorandum - Withdrawal of Source Determinations for Oil and Gas Industries. Clarification was provided that the TCEQ site definition guidance is in agreement with the 2009 EPA memo that all relevant factors must be evaluated in order to make a proper site determination for oil and gas properties.
Questions? We Can Help
If you have questions contact us.