TCEQ Posts Hurricane Harvey Response/Recovery Guidance

We know many of you, including your colleagues, family, and friends, were affected by Hurricane Harvey and you have all been and will continue to be in ALL4’s thoughts.  As the clean-up activities continue and facilities assess damage, begin start-up and return to normal operations, we wanted to share guidance that the Texas Commission on Environmental Quality (TCEQ) has developed.

TCEQ has developed a webpage dedicated to hurricane response

The hurricane response page includes relevant information related to TCEQ environmental regulations and policies in association with disaster response including the status of TCEQ rules during the disaster, along with guidance on fuel waivers, waste management, drinking water, wastewater treatment, and air quality.  Additional guidance is also provided including agency statements on the Crosby Texas Arkema Plant situation.  While all the guidance is relevant under the circumstances, the available guidance pertaining to air permits (air permits = drop attached file on our network to download), originally dated August 2013, is important for facilities with air permits that are responding to damage to operations inflicted by Harvey.

The air permit guidance addresses outdoor burning, facility repairs, emissions reporting, facility maintenance, startup, or shutdown, allowable temporary modifications, and allowable deadline extensions.  The air permit guidance is very detailed and provides answers to what are likely very common questions facing many facilites that were impacted by Harvey.  As an example, TCEQ addresses questions including but not limited to:

• If I need to make minor repairs to facilities because of hurricane damage, do I need to provide notice to anyone?
• What should I do if I need to temporarily exceed the maximum allowable emission rates or temporarily increase the production, capacity, or throughput stated in my authorization?
• Can compliance test dates be waived or extended?
• Can I get an extension to Title V permit reporting and certification deadlines for a site or a reporting entity impacted by the hurricane?
• What should I do if I need to temporarily exceed the maximum allowable emission rates or temporarily increase the production, capacity, or throughput stated in my authorization?

Based on the guidance, TCEQ will be very accommodating during the recovery process.  However, please note that there are notification and recordkeeping obligations associated with the repairs, temporary sources (e.g., generators, etc.), start-up, and other actions related to the recovery effort.

Please contact ALL4’s Houston Office Director, Kristin Gordon at 281.201.1241 or kgordon@all4inc.com if you need air quality assistance during recovery and start-up activities at your facility.  Should you find your day to day environmental tasks are piling up as you assist with these hurricane response activities, don’t hesitate to reach out to ALL4.  We’re more than happy to help in any way that we can.  For an update on ALL4 Houston, please see Kristin’s statement.