What is the timing of submittals and the circumstances and methods of submittals?
A. As of January 2003, the Air Quality Bureau required by letter that all Title V sources submit current estimates of flash emissions using the method that is appropriate to the source. Non-Title V sources have a similar obligation to evaluate flash emissions. All sources (both Title V and non-Title V) must submit the appropriate permit application if flash emissions cause the source to exceed an applicability threshold. The AQB’s emission inventory for year 2002 required all major and minor sources with permits to submit emissions from flashing of oil and gas liquids by April 1, 2003. The AQB will not normally re-open a NSR or Title V permit nor request that the owner/operator revise such a permit solely to incorporate VOC emissions from flashing operations. If a pre-existing and now-known VOC flash emission would exceed a VOC emission limit in a NSR or Title V permit the owner/operator may wish to revise that permit. NSR permits would be revised using either the technical revision pr
