the future of permitting air permits initial review
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Johnny Bowers Air Permits Division Texas Commission on Environmental Quality Advanced Air Permitting Seminar 2012. The Future of Permitting Air Permits Initial Review. Want your administrative review to move in a timely manner? Help us help you. A Speedy Administrative Review Help us by. - PowerPoint PPT PresentationTRANSCRIPT
Johnny Bowers
Air Permits Division
Texas Commission on Environmental Quality
Advanced Air Permitting Seminar 2012
The Future of Permitting
Air Permits Initial Review
Want your administrative review to move in a timely manner?
Help us help you.
Including a complete cover letter with: An overview Type of project (new request or update) RO and TC information CN/RN/permit or registration number Portable unit information
A Speedy Administrative Review
Help us by...
1. Cover letter2. Application form3. Core Data Form4. Table 30 or 30-R (if applicable)5. Copy of fee payment (if applicable)6. Technical documents7. Confidential information
A Speedy Administrative Review
Help us by...
Sending your application in this order:
Use 2-Hole PunchNo StaplesNo Binders
A Speedy Administrative Review
Help us by...
When submitting your application:
Checking for delinquent fees and penalties
A Speedy Administrative Review
Help us by...
Before submitting your application:
APIRT continues to streamline the process to:
Ensure your application is ready for technical review
Identify deficiencies earlier
Minimize public notice issues
Enhanced Adminstrative Review
What we’re doing...
Compliance History
Key changes
Projected target dates:
30-day review period begins: September 17th
CH ratings published to Web: November 15th
Compliance HistoryHelpful Link and Email
For additional information: Compliance Histories
For questions: [email protected]
David Reyna
Air Permits Division
Texas Commission on Environmental Quality
Advanced Air Permitting Seminar 2012
The Future of Permitting
Permits by Rule
Want your PBR review to move in a timely manner?
Help us help you.
Application content Incomplete submittals High volume submittals Q2
Enhanced Application Review Abbreviated review – faster replies ePermitting
Future of PBR Processing
1. Introduction2. Process flow diagram3. Summary of emissions4. Emission calculations5. Impact analysis/NAAQS6. How you meet the rules being claimed7. Maps8. Tables
A Speedy PBR Review
Help us by...
Sending technical content in this order:
Sending a complete application
Responding quickly to deficiency notices
A Speedy PBR Review
Help us by...
With a complete application, we can give you:
A timely review
A complete accurate review of project at time of arrival
A shorter review timeframe
Minimal or no deficiency notices
A Speedy PBR Review
What we’re doing...
Scheduling a pre-permit meeting with Austin and regional staff
Submitting an example application to staff before the meeting
Discussing the process and expectations at the meeting
High Volume Submittals
Help us by...
Accepting batch electronic submittals (AIROG, ePermitting)
Providing feedback on the example application
High Volume Submittals
What we’re doing...
Purpose
Expectations
Application content
Minimize delays at every stage
Faster response (e-mail)
Q2
Purpose
AIROG notification
Expectations
Reply
Enhanced Application Review
Limited quantification factors and techniques
Obligation to comply on applicant
Minimal review
Certification where appropriate
Abbreviated ReviewVoluntary Claims
State and federal applicability
Calculations and character of emission expected
Obligation to comply on applicant
Certification where appropriate
Abbreviated Review Required Registrations
Current oil and gas projects in ePermitting for Barnett Shale area:
Historical notification
New/existing notifications
New/existing Level 1 and 2 registrations
ePermitting
State-wide oil and gas new/revision §106.352(l)
State-wide oil and gas new/revision standard permit §116.620
Planned MSS §106.263
APD certifications
All other PBR’s
ePermittingProposed Projects:
Kristi Mills-Jurach, P.E.
Air Permits Division
Texas Commission on Environmental Quality
Advanced Air Permitting Seminar 2012
The Future of Permitting
New Source Review
2005 2006 2007 2008 2009 2010 2011 20120
500
1000
1500
2000
2500
3000
3500
Pro
jects
Receiv
ed
Pro
ject
ed
NSR Projects Received
Streamline permitting process to improve issuance time
Manage large increase of projects
Improve communication with applicants on application requirements
New Source Review Goals
Federal permits (NA/PSD) – 365 days
Initial NSR permits (non-major) – 285 days
Amendments (non-major) – 315 days
Renewals – 270 days
Revisions – 120 days
Standard permits (without PN) – 45 days
NSR Permitting Timeframes
In-person meeting or conference call
Be prepared to discuss: Federal applicability (netting and offsets)
BACT
NAAQS and health effects
Air Pollutant Watch List
Pre-Application Meetings
Conducting preliminary impacts evaluation before submitting application
Scheduling pre-modeling meeting early in technical review
Becoming familiar with NAAQS requirements and Toxicology Division guidelines
Impacts Evaluation
Help us by...
In your modeling report: Showing impacts are acceptable Identifying any assumptions used
Promptly responding to modeling requests: 30-day initial modeling request 15-day follow-up request 30/15-day requests for deficient modeling
protocols and reports
Impacts EvaluationCont’d.
Help us by...
Identifying application purpose: Changes and corrections
Providing supporting documentation: Vendor guarantees MSDS with 100% speciation Excel files (where possible)
Complete Applications
Help us by...
Providing calculations: Methodology Factors Examples
Identifying the worst case for total emissions by pollutant type
Including calculations for each species to be modeled
Complete ApplicationsCont’d.
Help us by...
Following the PI-1 instructions Providing baseline actual emissions
For PBR and std. permit incorporations: Addressing in amendments and renewals Providing impacts and/or BACT, as applicable
Complete ApplicationsCont’d.
Help us by...
Successfully implemented in Coatings in 2007
Expanding to all sections in some capacity
Enhanced Administrative Review
May require separate permitting action
May include technical corrections that require new calculations
PBR/SP issued after “admin. complete” may not be incorporated
Scope Changes
Identifying key contacts
Having applicant and consultant both involved
Ensuring the technical contact has the ability to make agreements on behalf of company
Expecting more formal deficiency letters
Open Communication
Help us by...
Tools are available on TCEQ Web site
Contact NSR sections with questions
Chemical: Beryl Thatcher
Coatings and Combustion: Rebecca Partee
Mech/Ag/Construction: Stephanie Howell, P.E.
Resources
Our shared goal is to issue permits in a timely manner:
Focus is on approvable projects
Applicants can directly affect timeliness of permit processing
Conclusion
Kristi Mills-Jurach, P.E.
(512) 239-1261
Contact Information
Questions??