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Introduction to New Source Review (NSR) Permits. Alec Castellano Air Permits Division Texas Commission on Environmental Quality Environmental Trade Fair 2014. Overview. TCEQ Authority How to Authorize a New Source How to Make Changes to an Authorization When to Renew and How

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introduction to new source review nsr permits

Introduction toNew Source Review (NSR) Permits

Alec Castellano

Air Permits Division

Texas Commission on Environmental Quality

Environmental Trade Fair 2014

overview
Overview
  • TCEQ Authority
  • How to Authorize a New Source
  • How to Make Changes to an Authorization
  • When to Renew and How
  • The Application Review Process
  • Processing Time
tceq authority
TCEQ Authority
  • 30 TAC §116.119 - De minimis facilities
  • 30 TAC §106.4 - PBR
  • 30 TAC Chapter 116, Subchapter F - SP
    • 30 TAC §116.615 – General conditions
  • 30 TAC Chapter 116 – NSR
how to a uthorize a n ew s ource
How to Authorize a New Source
  • NSR permit
    • Facility does not qualify for de minimis, PBR, or SP
    • 30 TAC Chapter 116
  • Requirements
    • Submittal of Form PI-1, and fee
    • Public notices
    • BACT
    • Air quality analysis
completing an application
Completing an Application

Forms and Tables

Completing an Application

Area Map

Process Flow

Technical Information

Federal Applicability

completing an application1
Completing an Application

Forms and Tables

  • Complete Form PI-1 and submit
  • Submit copy to region and applicable local program
  • Evaluate proposed project considering:
    • State requirements
    • Federal requirements
completing an application2
Completing an Application

Forms and Tables

  • Core Data Form
  • Table 1(a) – Emission Point Summary
  • Equipment, process, and control device tables
  • Table 2 – Material Balance
  • Table 30 – Fee
area map
Area Map

Area Map

3000 ft

Location of facility

N

3000 ft.

completing an application3
Completing an Application
  • Emissions information
    • Emissions data and calculations
    • Maximum operating schedule
    • Full disclosure of contaminants

Technical Information

completing an application4
Completing an Application
  • State requirements
    • Protection of public health and welfare
    • Measurement of significant air contaminants
    • BACT

Technical Information

completing an application5
Completing an Application
  • State requirements (cont’d)
    • Performance demonstration
    • Mass cap and trade allowances

Technical Information

completing an application6
Completing an Application
  • Federal applicability
    • NSPS
    • NESHAPs
    • MACT
    • Nonattainment
    • PSD
    • HAPs

Federal Applicability

examples
Examples

Examples

  • We are seeking authorization for _____.
  • Our maximum hours of operation are _____.
  • We process a total of X per Y.
  • We are not subject to this potentially applicable standard because _____.
how to authorize c hanges to a permitted facility
How to Authorize Changes to a Permitted Facility
  • PBR or SP
  • Alteration
  • Amendment
  • Changes to an NSR permit include:
    • PBR or SP
    • Alteration
    • Amendment
nsr alterations
NSR Alterations

Alteration when the change;

results in a decrease in allowable emissions;

does not cause a change in control of emissions; and

does not cause a change in character of emissions.

nsr amendment
NSR Amendment

An amendment is triggered if there is a/an:

change in character of emissions or a new contaminant;

increase in emission rates; or

change in method of control.

example
Example

An applicant would like to increase the emission rate for one facility while decreasing emissions by the same amount from another facility.

Is this an alteration?

An applicant would like to increase the emission rate for one facility while decreasing emissions by the same amount from another facility.

Is this an alteration?

example1
Example

NO.

An increase in emission rate of a facility, even though the emissions could be offset by another facility, cannot be authorized through an alteration.

example2
Example

A company wants to decrease the height of a stack venting an emission source. There will be no increase in emissions. Can this be authorized by an alteration?

A company wants to raise the stack venting an emission source. There will be no increase in emissions.

Can this be authorized by an alteration?

Yes. This change can be processed as an alteration.

Yes

This change can be processed as an alteration.

example3

A company wants to increase the throughput on a source controlled by a baghouse. The emissions from the baghouse listed on the MAERT will not increase.

Can this be authorized by an alteration?

Example

A company wants to increase the throughput on a source controlled by a bag house.

The emissions from the bag house listed on the MAERT will not increase.

Can this be authorized by an alteration?

No. Although the emissions from the baghouse listed on the MAERT do not increase, the actual emissions from the baghouse do increase.

NO

Although the emissions from the baghouse listed on the MAERT do not increase, the actual emissions from the baghouse do increase.

nsr renewals
NSR Renewals
  • General expectations for permit renewals
    • No changes to existing authorization
    • Same control technology
    • Same emissions
    • Requirements will not be more (or less) stringent
  • No changes to existing authorization
  • Same control technology
  • Same emissions
  • Permit requirements should not be more (or less) stringent

General Expectations for Permit Renewals

nsr renewals1
NSR Renewals
  • Compliance history and permit renewals
    • Unsatisfactory compliance history
  • Unsatisfactory compliance history

Compliance History and Permit Renewals

nsr renewals2
NSR Renewals
  • Requirements:
    • Renewal notification letter
    • Form PI-1R
    • Renewal application fee
    • Public notice
    • Technical information
  • Renewal notification letter
  • Form PI-1R
  • Renewal application fee
  • Public notice
  • Technical information

Renewal Requirements

renewal notification letter
Renewal Notification Letter
  • Notification 180 days before expiration date
  • Extensions granted only if not notified
  • Current company contact information
  • Notification 180 days before expiration date
  • Extensions granted only if not notified
  • Current company contact information

Renewal Notification Letter

form pi 1r
Form PI-1R
  • Include the following:
    • Applicant information
    • Important general information
    • Facility and source information
    • Type of permit renewal and associated actions
    • Permit fee information
    • Public notice information
    • Renewal Certification option
    • Technical information
    • State regulatory requirements
    • Federal regulatory requirements
      • NSPS, NESHAPs, and MACT
    • Copies of the application
    • Signature
  • Complete Form PI-1R and submit
  • Submit copy to region and applicable local program
  • Don’t forget about these items:
    • Type of permit renewal and associated actions
    • Application fee

Form PI-1R

renewal application fee
Renewal Application Fee

If the total authorized emissions represented in Table 1(a) are 12 tpy, how much is the renewal fee?

$600 + ($35(7)) = $600 + $245 = $845

renewal certification option
Renewal Certification Option

Renewal Certification Option

  • Abbreviated renewal process
  • Only under specific conditions
  • A new permit isn’t issued – only a letter
  • Permit is good for another 10 years
  • A new permit isn’t issued – only a letter
  • Permit is good for another 10 years
  • Abbreviated renewal process
  • Only under specific conditions

Outline

application review process step 1 receipt of application
Application Review ProcessStep 1. Receipt of Application

All applicable information should be submitted with the General Application (Form PI-1).

application r eview process step 2 administrative review
Application Review ProcessStep 2. Administrative Review
  • Air Permits Initial Review Team (APIRT)
    • Creates the project record
    • Checks for administrative completeness
    • Searches for delinquent fees
    • Requests regional site review
    • Notifies company of completeness or deficient items
    • Sends first public notice package
    • Applicant reviews draft notice for accuracy
    • Transfers administratively complete application to technical review staff
first public notice
First Public Notice

NORI

  • NORI
  • 30 TAC Chapter 39
  • 30 TAC Chapter 55

30 TAC Chapter 39

30 TAC Chapter 55

application review process step 3 technical review
Application Review ProcessStep 3. Technical Review
  • Permit reviewer
    • Verifies compliance history (if applicable)
    • Confirms emissions sources and calculations
    • Verifies compliance with first public notice requirements
  • Checks for PBRs or SPs to be incorporated
    • Reviews BACT and air quality analysis
    • Determines compliance with state/federal regulations
    • Prepares and sends the draft permit for comment/approval after determining application technically complete
    • Prepares and sends second notice package (if applicable)
    • Conducts public meeting (if applicable)
    • Responds to comments (from public notices/meeting)
second public notice
Second Public Notice

NAPD

  • NAPD
  • 30 TAC Chapter 39
  • 30 TAC Chapter 55

30 TAC Chapter 39

30 TAC Chapter 55

public participation
Public Participation

Contested case hearing requests

  • The public can:
    • Request a contested case hearing
    • Request a public meeting and
    • Make comment
  • The agency will:
    • Participate in contested case hearing, if required
    • Conduct public meeting, if applicable
    • Consider and respond to all timely comments

Public meeting requests

Comments

public notice tips
Public Notice Tips

Public Notice Tips (cont’d):

Public Notice Tips:

a) Take and upload the photo to Facebook and

share it with everyone else.

  • Have application in public place and signs posted when notice is published
  • Keep application and signs posted until the end of the last designated comment period
  • Maintain updated versions of the application in public place
  • Submit the proper documents according to the checklist provided in your notice package
  • Review the draft notice when received
  • Ensure that all pollutants are listed and address or driving directions are correct
  • Use the wording provided by the TCEQ for the notice
  • Publish alternative language notice in alternative language newspaper
  • Review the draft notice when received
  • Ensure that all pollutants are listed and address or driving directions are correct
  • Use the wording provided by the TCEQ for the notice
  • Publish alternative language notice in alternative language newspaper
  • Have application in public place and signs posted when the notice is published
  • Keep application and signs posted until the end of the last designated comment period
  • Maintain updated versions of the application in public place
  • Submit the proper documents at the appropriate times

b) Snap a few as memories for good measure for

your eyes only.

c) Take a photo, but delete it immediately after

showing it to other nurses.

d) Do nothing. You ever took any photos of patients

or coworkers because you value your job and

your patient’s privacy.

Following this guidance will help expedite the public notice process and help ensure that re-notice is not required.

public notice example

My public notice was published in the appropriate newspaper and my application was posted in a public place on Monday. The signs were posted on-site Wednesday.

Is this acceptable?

Public Notice Example

The public notice is published in the appropriate newspaper and posted in a public place on Monday. The signs are posted on-site Wednesday.

Is this acceptable?

No. The signs must be posted on-site at the same time as the notice is published in the newspaper and posted in a public place. Your notice period will be extended as a result.

No.

The signs must be posted on-site at the same time as the notice is published in the newspaper and posted in a public place. Your notice period will be extended as a result.

public notice example1

Yes.

We recommend that the signs and application should remain in place from the beginning of the first notice until the end of the designated comment period for second notice.

My client has already been through first notice. Second public notice is required. Should his signs and application remain in place until the end of the designated comment period?

Public Notice Example

Second public notice is required for your project.

Should your signs and application remain in place until the end of the designated comment period?

Yes. We recommend that the signs and application should remain in place from the beginning of the first notice until the end of the designated comment period for second notice.

texas commission on environmental quality public notice verification form air permit
TEXAS COMMISSION ON ENVIRONMENTAL QUALITYPublic Notice Verification Form Air Permit

TEXAS COMMISSION ON ENVIRONMENTAL QUALITY

Public Notice Verification Form Air Permit

Applicant Name: John Doe

Site or Facility Name: Company ABC

TCEQ Account Number (if applicable): AB-1234-C Permit Number: 12345

Regulated Entity Number: RN123456789 Customer Number: CN1234567890

All applicants must complete all applicable portions of this form. Send this completed form to the TCEQ to the attention of the Office of the Chief Clerk within 10 business days after the end of the designated comment period. For more information regarding public notice, refer to the instructions in the public notice package.

texas commission on environmental quality public notice verification form air permit1
TEXAS COMMISSION ON ENVIRONMENTAL QUALITYPublic Notice Verification Form Air Permit

TEXAS COMMISSION ON ENVIRONMENTAL QUALITY

Public Notice Verification Form Air Permit

Applicant Name: John Doe

Site or Facility Name: Company ABC

TCEQ Account Number (if applicable): AB-1234-C Permit Number: 12345

Regulated Entity Number: RN123456789 Customer Number: CN1234567890

All applicants must complete all applicable portions of this form. Send this completed form to the TCEQ to the attention of the Office of the Chief Clerk within 10 business days after the end of the designated comment period. For more information regarding public notice, refer to the instructions in the public notice package.

application review process step 4 issuance of permit
Application Review ProcessStep 4. Issuance of Permit

If all of the applicable steps in the administrative and technical reviews are successfully completed, a permit will be issued for a non-contested application.

processing time
Processing Time
  • Target Times
    • PBR =45 days
    • SP = 45 to 195 days
    • NSR Alteration = 120 days
    • NSR Renewal = 270 days
    • NSR New Construction = 285 days
    • NSR Amendment = 315 days
    • Nonattainment/PSD= 365 days
summary
Summary
  • Authority
  • Authorizing a new source
  • Making changes
  • Renewing
  • Application review
  • The final permit
  • Summary
  • Authority
  • Authorizing a new source
  • Making changes
  • Renewing
  • Application review
  • The final permit
questions thank you
Questions?Thank you!

Air Permit Division

(512) 239-1250