1. Standardized Authorizations (Permits by Rule & Standard Permits)
Dana Johnson
Air Permits Division
Texas Commission on Environmental Quality
Environmental Trade Fair 2015

2. Overview Types of NSR Authorizations Submitting Applications
Certifications
Topics of Discussion
Contact Information and Links
Questions
NSR = New Source Review
R&R = Rule Registrations

3. Types of NSR Authorizations
Increasing Emissions
De Minimis
PBRs
Standard Permits
State Permits
NNSR & PSD
Permits by rule (PBRs) and standard permits (SPs) are types of NSR authorizations. They authorize sources with emissions greater than de minimis (below regulatory concern) but less than the level of emissions that would require a case-by-case permit.
The Air Permits Division uses a pyramid approach to permitting. The levels of the pyramid are as follows:
Top Level – De Minimis
Second Level – Permit by Rule
Third Level – Standard Permits
Fourth Level – State Permits (i.e., minor NSR permits)
Fifth Level – Nonattainment New Source Review (NNSR) and Prevention of Significant Deterioration (PSD) (i.e., major NSR permits)
Depending on what type of permit you have, the lower down on the pyramid, the higher emissions you typically have.

4. NSR and Title V ComparisonDM
PBRs SP
State Permits
NNSR & PSD
NSR
Title V
SOP
GOP
Minor
DM = de minimis
PBR = permits by rule
SP = standard permits
NNSR = nonattainment new source review
PSD = Prevention of Significant Deterioration
GOP = general operating permit
SOP = site operating permit
In addition to NSR authorizations, Title V Federal Operating Permits are required when a site becomes a major source or when there are sources that fit into specific defined categories (such as air curtain incinerators and municipal solid waste landfills).
The NSR permit is an authorization to construct facilities, while the Title V permit is an authorization to operate Title V major sources. For a site to have a GOP, it must also first have a PBR authorization and/or a standard permit authorization. For a site to have an SOP, it must also have a case-by-case NSR permit.

5. De Minimis Authorizations
Negligible sources
Industry/activity-specific
Meet all conditions exactly
Typically no paperwork
Keep records
De minimis information DM
PBRs SP
State Permits
NNSR & PSD
NSR
Paperwork is not typically submitted for de minimis authorizations; however, there are steps that can be taken to amend the List of De Minimis Facilities.
The de minimis web page can be found at

6. Example De Minimis Authorizations

7. Examples of De Minimis MSS
Coatings of <100 gallons per year
Chemicals for cleaning
WD-40
MSS = maintenance, start-up, and shutdown
De minimis authorizations are usually a site-wide mechanism, except for activities of completely different characteristics from permitted facilities.

8. Permits by Rule Registration Distance requirements DM
Meet all conditions exactly
Registration
Distance requirements
Specific emission limits DM SP
State Permits
NNSR & PSD
PBRs
NSR
Mention that these will be discussed in more detail.
PBRs are specific to an industry or activity. For example, if you have a flare, you would use the PBR specific to that piece of equipment (facility). You must meet each applicable condition of the rule – no exceptions.
Registration is only required when specifically stated in the rule. If no registration is required, document how you meet each condition of the rule and keep that information available to demonstrate compliance.

9. PBRs Subchapter K: General
§ – Facilities (Emission Limitations)
§ – Facilities (Emission and Distance Limitations)
§ – Routine MSS of Facilities &Temporary Maintenance Facilities
PBRs for similar activities or industries are grouped in subchapters. Some of the most common are Subchapters K, O, and U in Title 30 Texas Administrative Code Chapter 106
PBRs §§ , , and can be found at

10. PBRs Subchapter O: Oil and Gas
§ – Salt Water Disposal (Petroleum)
§ – Oil and Gas Handling and Production Facilities
§ – Pipeline Metering, Purging, and Maintenance
PBRs for similar activities or industries are grouped in subchapters. Some of the most common are Subchapters K, O, and U in 30 TAC Chapter 106.
PBRs §§ , , and can be found athttp://texreg.sos.state.tx.us/public/readtac$ext.ViewTAC?tac_view=5&ti=30&pt=1&ch=106&sch=O&rl=Y .

11. PBRs Subchapter U: Tanks, Storage, and Loading
§ – Organic and Inorganic Liquid Loading and Unloading
§ – Organic Liquid Loading And Unloading
§ – Storage Tank and Change of Service
PBRs for similar activities or industries are grouped in subchapters. Some of the most common are Subchapters K, O, and U in 30 TAC Chapter 106.
PBRs §§ , , and can be found at

12. Standard Permits Industry/activity-specific Renew every 10 years DM
Fee req’d at registration DM
State Permits
NNSR & PSD SP
PBRs
NSR
Give general and specific requirements; wait on authorization; federally enforceable.

13. Standard Permits R&R Section
Oil and gas:
30 TAC §
Non-rule
MSW landfills:
Landfills
Landfills at major sites
30 TAC = Title 30 Texas Administrative Code
MSW = municipal solid waste
The corresponding standard permit numbers are as follows:
Oil and Gas (6002)
Non-Rule Oil & Gas Standard Permit (Adopted 2/27/11; implemented 4/1/11) (6002)
Municipal Solid Waste (MSW) Landfills (6010)
Municipal Solid Waste (MSW) Landfills at GOP Major Sites (6517)
Only the Oil & Gas Standard Permit remains as in rule; the remaining standard permits are now non-rule. Both rule and non-rule are equally as enforceable.

14. Standard Permits Mech./Ag./Const. Section
Construction industry
Agricultural industry
The corresponding standard permit numbers are as follows:
Concrete Batch Plants (6004)
Permanent Rock and Concrete Crushers (6013)
Temporary Rock and Concrete Crushers (6006) *Regional Use Only
Permanent/Temporary Hot-Mix Asphalt Plants (6007)
Concrete Batch Plants with Enhanced Controls (6008)
Sawmills (6012)
Anhydrous Ammonia Storage and Distribution (6014)
Bulk Fertilizer Handling(6015)
Cotton Gins (6016)
Feedmills (6017)
Grain Elevators (6018)
Peanut Drying/Handling (6019)
Temporary/Permanent Polyphosphate Blenders (6020)

15. Standard Permits Comb./Coatings Section
Electric Generating Units
Animal Carcass Incinerators
Boilers (>40 MM Btu/hr)
MM Btu/hr = million British thermal units per hour
The corresponding standard permit numbers are as follows:
Electronic Generating Units (6005)
Animal Carcass Incinerators (6009)
Boilers (6011)

16. Submitting Applications Preferred Order
Introduction/ Cover letter
Table of Contents
Core Data
PI-7,
PI-7-CERT, or PI-1S
Payment 1 2 3
Introduction/Cover letter
Table of Contents
Administrative documents:
Core Data Form
PI-7, PI-7-CERT, or PI-1S
Copy of check or ePay Voucher
The PI-7 and the PI-7-CERT are forms required when registering for a PBR.
PI-7: The purpose is to only register emissions under a PBR.
PI-7-CERT: Submitted to register and certify emissions for a PBR. It can also be used for the sole purpose of certifying emissions even if not registered. This purpose is not encouraged, but is accepted.
The PI-7 and the PI-7-CERT can both be found at
The Form PI-1S is the form for required when seeking authorization for standard permits. Instructions can be found at
The Core Data Form and its instructions and guidance can be found at

17. Submitting Applications Preferred Order
Process flow diagram
Plot plan 6
Project description 5
Process description 4
Process description
Project description
Process flow diagram/plot plan
The process goes more quickly if the permit reviewer has adequate information to address the following in the project description:
What is the company doing that requires review by the R&R Section?
Is this a new facility or a change to an existing facility?
If it is an existing facility, how is the original facility authorized?
Does the registration or authorization claimed fit the situation?
Has the facility met all the conditions of the claimed registration or authorization?
Does the facility meet the applicable general requirements?
Are there any additional federal, state, or local rules that apply?
Are the emission limits and emission point names clearly listed?
Moving forward, it is recommended that companies begin submitting a Table 1(a) to answer this question. The Table 1(a) will soon become mandatory for certified registrations.   This is really good information. Should it be in the slides, too (maybe between Slides 25 and 26)?

18. Example Process Description
COMPANY NAME owns and operates the SITE AND/OR UNIT NAME located in COUNTY NAME.
The site associated gas from the well flows through a 500,000 Btu/hr line heater (HTR1), where it is periodically heated to reduce the formation of hydrates. The gas then flows into the two stage separator, where the liquids (water) are separated from the gas. The gas then flows to the gas sales meter while the liquids flow into the produced water tanks (TK1 and TK2) on the site. The tank vapors are vented to the atmosphere, while the liquids are eventually trucked off-site (TRUCK).

19. Example Project Description (Initial)
COMPANY NAME has submitted a Form PI-7-CERT for the initial authorization of the SITE NAME in accordance with PBR OR STANDARD PERMIT, APPLICABLE RULE(S).

20. Example Project Description (Revision)
COMPANY NAME has submitted a Form PI-7-CERT to authorize the following revisions at the SITE NAME in accordance with PBR OR STANDARD PERMIT, APPLICABLE RULE(S):
Addition of one (1) 1,430-hp compressor engine (EPN: C1)
Removal of one (1) 250,000 Btu/hr glycol dehydrator (EPN: DEHY1)
Update associated fugitive emissions (EPN: FUG)
All other emission sources will remain as currently authorized.

21. Submitting Applications Preferred Order
Summary of emissions:
Short-term (lb/hr) and long-term (tpy)
Speciations (if applicable)
Detailed emission calculations:
TCEQ spreadsheet
Other TCEQ approved methods
Summary of emissions
Short-term
Long-term
Speciations
Detailed emission calculations
TCEQ spreadsheet
Other approved methods 7 8

22. Example Table 1(a) Page 1 FIN = facility identification number
TPY = tons per year
VOC = volatile organic compound
NOX = oxides of nitrogen
CO = carbon monoxide
PM10 = particulate matter equal to or less than ten microns in diameter
PM2.5 = particulate matter equal to or less than 2.5 microns in diameter
SO2 = sulfur dioxide
HAPs = hazardous air pollutants
This is an example of how the emission point number (EPN) and each individual contaminant are listed on a Table 1(a). The EPN is clearly listed along with the type of unit. Also, all applicable contaminants and their hourly and annual emissions are clearly represented.
When submitting the Table 1(a), you do not need to complete Column (B) (the FIN). You only need to submit Page 1.

23. Example Summary of Emissions
EPN = emission point number
VOC = volatile organic compound
NOX = oxides of nitrogen
CO = carbon monoxide
PM10 = particulate matter equal to or less than ten microns in diameter
PM2.5 = particulate matter equal to or less than 2.5 microns in diameter
SO2 = sulfur dioxide
HAPs = hazardous air pollutants
lbs/hr = pounds per hour
tpy = tons per year

24. Submitting Applications Preferred Order
Technical information
New/existing site
Upstream/ downstream effects
Impacts/NAAQS 10
Compliance
Federal rules
State rules
Local rules
Current checklist 9
Compliance with applicable rules:
Federal, state, and local
Current checklist
Technical information:
New or existing site
Upstream or downstream effects
Impact analysis/NAAQS
NAAQS = National Ambient Air Quality Standards

25. Submitting Applications Preferred Order
Maps 12
Supporting information
Lab analysis
Manufacturer info.
MSDS or SDS
Reports 11
Supporting information/documentation:
Lab analysis
Manufacturer information
MSDS or SDS
Process simulation reports
Maps
MSDS = Material Safety Data Sheets
SDS = Safety Data Sheets

26. Sending the Application
STEERS: ePermitting software
AirOG: for ing updates
STEERS = State of Texas Environmental Electronic Reporting System
Electronically through STEERS (includes link to STEERS page)
Updates to applications not assigned can be submitted through AirOG (includes address
Hardcopy
STEERS can be found at or
Hardcopy

27. High Volume Submittals Pre-Permitting Meeting
an example application to staff before the meeting
Discuss the process and expectations at the meeting
For high volume submittals, we ask that you contact us to set up a pre-permit meeting and at that time submit an example application for our staff to look over. At the scheduled meeting, we will go over the example application with you and discuss our expectations.

28. Response Letters E-mail: Mail: Immediate Easy to forward Easy storage
Lost mail
Unexpected delays

29. Streamlining
STEERS
Certifications
Updating guidance and forms

30. STEERS (ePermits) What is available through ePermits?
Am I required to use ePermits?
The following are currently available through ePermits:
General MSS Registrations
APD Certifications
Notifications and registrations for Barnett Shale (BSH) PBRs and standard permits
Registrations for PBRs and standard permits Non-BSH
New Source Review (NSR) Administrative Action(s):
Submit an Air NSR Change of Ownership
New Source Performance Standard (NSPS-OOOO):
Submit a Well Completion/Flowback Notification (40 CFR § )
General MSS Registrations:
Submit an APD Maintenance, Startup, and Shutdown for un-registered facilities
Submit an APD Maintenance, Startup, and Shutdown for registered facilities
APD Certifications:
Submit an APD Certification for un-registered facilities
Submit an APD Certification for registered facilities
Notifications and registrations for Barnett Shale (BSH):
Submit an Oil and Gas Site (OGS) Historical Notification
Submit OGS New Project Notification for New and Existing Registrations
Submit OGS PBR Level 1 and 2 New and Existing Registration
Submit OGS Non-rule Standard Permit for New and Existing Registrations
Registrations for Permits By Rule and Standard Permits for Non-BSH:
Submit a § (l) or Standard Permit New Registration
Submit a § (l) - Revision to Existing Registration
Submit a Standard Permit Existing Registration
- Notification is required for projects constructed or facilities modified on or after 4/1/2011 and subject to § (a)-(k) or the non-rule standard permit (a-k).
- Level 1 and 2 Registration is required either 90 or 180 days after submitting the OGS New Project Notification; a more detailed registration is required through ePermits.
- Non-Rule OGS New Project Registration is required 90 days after submitting the OGS New Project Notification; a more detailed registration for the standard permit is required via hard copy.
- All other PBRs are now available through ePermits and some will get an automatic response.

31. Certifications What is PTE? When must I certify? How do I certify?
What happens to my certification?
Potential to emit (PTE): The maximum capacity of a stationary source to emit a pollutant under its physical and operational design.
If owners and operators of sites are trying to avoid requirements, they will likely have to certify emissions to establish PTE limits. Certification can occur with either a PI-7-CERT or an APD-CERT form.
An individual who is willing to take personal responsibility/accountability or the person we are issuing the permit to is usually the Responsible Official or Technical Contact.

32. Reasons to Certify Emission limitations for Title V applicability
Federal applicability
Control/destruction efficiency claims
Operating hours
Above is only a partial list of the most common reasons companies voluntarily certify or are asked to certify a project by a permit reviewer. For a full list, please consult the PI-7-CERT or APD-CERT form(s).

33. Topics of Discussion Fees Current Checklist
Emission Calculation Spreadsheet
Welcome, Mr. Short
If a site has a revision to submit within six months of authorization, a fee may be required. If there are questions, please contact the R&R Section.
When preparing your application, confirm that the most recent forms are being used since some of the information and requirements may have changed.

34. Contact Air Permits Division
Main line: (512)
Main line: (512)

35. Links Air Permits by Rule Standard Air Permits
The links above will take you to the main web page(s) for Air Permits by Rule and Standard Air Permits, respectively. On the Air Permits by Rule page, you can search the index for air permits by rule, learn how to claim a permit by rule, as well as find other information regarding permits by rule. At the Standard Air Permits page, you can find more information regarding the various air standard permits available and how to apply for the appropriate one.
Air Permits by Rule can be found at
Standard Air Permits can be found at

36. Contact SBLGA Website: Small Business & Local Government Assistance
Main line:
(800)
Main line: (800)
Small Business and Local Government Assistance website can be found at

37. Questions?