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Introduction to New Source Review (NSR) Permits

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

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  1. Introduction toNew Source Review (NSR) Permits Alec Castellano Air Permits Division Texas Commission on Environmental Quality Environmental Trade Fair 2014

  2. 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

  3. 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

  4. 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

  5. Completing an Application Forms and Tables Completing an Application Area Map Process Flow Technical Information Federal Applicability

  6. 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

  7. 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

  8. Area Map Area Map 3000 ft Location of facility N 3000 ft.

  9. What’s wrong with this picture?

  10. Process Flow Diagram Process Flow

  11. Process Flow Diagram Process Flow

  12. Completing an Application • Emissions information • Emissions data and calculations • Maximum operating schedule • Full disclosure of contaminants Technical Information

  13. Completing an Application • State requirements • Protection of public health and welfare • Measurement of significant air contaminants • BACT Technical Information

  14. Completing an Application • State requirements (cont’d) • Performance demonstration • Mass cap and trade allowances Technical Information

  15. Completing an Application • Federal applicability • NSPS • NESHAPs • MACT • Nonattainment • PSD • HAPs Federal Applicability

  16. 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 _____.

  17. How to Authorize Changes to a Permitted Facility • PBR or SP • Alteration • Amendment • Changes to an NSR permit include: • PBR or SP • Alteration • Amendment

  18. 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.

  19. 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.

  20. 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?

  21. 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.

  22. 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.

  23. 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.

  24. Renewing an NSR Permit Renewals

  25. 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

  26. NSR Renewals • Compliance history and permit renewals • Unsatisfactory compliance history • Unsatisfactory compliance history Compliance History and Permit Renewals

  27. 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

  28. 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

  29. 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

  30. 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

  31. 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

  32. Application Review ProcessStep 1. Receipt of Application All applicable information should be submitted with the General Application (Form PI-1).

  33. 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

  34. First Public Notice NORI • NORI • 30 TAC Chapter 39 • 30 TAC Chapter 55 30 TAC Chapter 39 30 TAC Chapter 55

  35. 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)

  36. Second Public Notice NAPD • NAPD • 30 TAC Chapter 39 • 30 TAC Chapter 55 30 TAC Chapter 39 30 TAC Chapter 55

  37. 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

  38. 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.

  39. 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.

  40. 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.

  41. TEXAS COMMISSION ON ENVIRONMENTAL QUALITY Public 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.

  42. TEXAS COMMISSION ON ENVIRONMENTAL QUALITY Public 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.

  43. 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.

  44. 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

  45. 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

  46. Questions?Thank you! Air Permit Division (512) 239-1250

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