the future of permitting air permits initial review

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: comphist@tceq.texas.gov

Johnny Bowers

(512) 239-6770

johnny.bowers@tceq.texas.gov

Contact InformationAPIRT

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:

David Reyna

(512) 239-6051

david.reyna@tceq.texas.gov

Contact InformationR&R

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

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2000

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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

kristi.mills-jurach@tceq.texas.gov

Contact Information

Questions??