Texas Natural Resource Conservation Commission
Interoffice Memorandum

To:  Permit Engineers
From:  Victoria Hsu, P.E., Director, New Source Review Permitting Division
Date:  April 30, 1997
Subject:  Standard Permits for Pollution Control Projects

The following guidance is being provided for the implementation of new language contained in
section 116.617(1) which will become effective May 22, 1997.  The language reads as follows:

"This standard permit cannot be used if the registrant receives notification that in the opinion of
the executive director there are significant health effects concerns resulting from an increase in
emissions of any air contaminant other than those for which a NAAQS has been established,
until those concerns are addressed by the registrant to the satisfaction of the executive director."

For those standard permit claims involving MANDATORY control requirements, no action by
the executive director is the presumed default except in cases where unacceptable health effects
concerns are identified.  In this case, if unacceptable health effects would be expected to result,
the engineer should raise such concerns to his/her team leader/section manager and seek input
from the Toxicology and Risk Assessment Section (TARA).  If the section manager is in
agreement with him/her, the concerns identified by the engineer should be discussed with the
NSRP Division Director for a final determination on the acceptability of the standard permit 
claim.

For example, if a regulation dictates a specific type of control device or limits the choice of
control options, the executive director would not object to that standard permit claim.  In another
case, if the regulated entity had a choice of control options and had chosen an option that resulted
in wholly unacceptable impacts, the agency should consider raising an objection to that standard 
permit claim.

For standard permit claims involving VOLUNTARY control approaches, the engineer should
keep in mind that the standard permit was written to facilitate the construction of projects
involving an overall reduction in emissions or a change to a pollutant that is less toxic (i.e. those
with a higher ESL).  For VOC compound changes, a simple ratio equation of the relative
emission rates and relative ESL's should be used.  Where combustion devices are being used to
abate emissions, there will be no additional review of the emissions of non-criteria pollutants
except for the combustion of chlorinated compounds.  The requirements for the review of criteria
pollutants is already contained within the standard permit.  The acceptability of the combustion
of chlorinated compounds will need to be reviewed on a case-by-case basis.  No additional
review will be necessary if the combustion device is followed by a scrubber.  If the project does
not fall under any of these guidelines, the permit engineer in coordination with his/her team
leader/section manager and the division director, if necessary, should consider the reductions
and/or pollutant changes associated with the project for consistency with the intent of the
standard permit, TARA's assessment of the relative effects and any other environmental benefits
that would be gained from the project.  A final determination of acceptability would be based
upon the project representing a net positive environmental change.