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Texas Natural Resource Conservation Commission
               Austin                       Texas
                           Interoffice

From:  Lawrence E. Pewitt, P.E.  Director, Permits Division
To:  Regional Directors and Permit Engineers
Date:  April 16, 1987
Subject:  Permit Renewal

In order to proceed with permit renewal review, the following
procedures will be used to determine applicability and
schedule for permit renewal:

1.  Changes in Ownership - The date of the first operating
    permit will be used to determine the fifteen year period
    for permit renewal for permits issued prior to December 1,
    1991.  Any permit issued on or after December 1, 1991 is
    subject for renewal every ten years after the date of
    issuance.  

2.  Changes in Location - The date of the last operating
    permit issued will be used to determine the fifteen year
    period for permit renewal for permits issued prior to
    December 1, 1991.  Any permit issued on or after December
    1, 1991 is subject for renewal every ten years after the
    date of issuance.  

A company may want to claim a standard exemption for the
facilities addressed by permit renewal review.  If this
occurs, the company may request the permit be voided with
all conditions of the applicable standards met.  As a
reminder, there is at least one advantage of a permit because
a standard exemption can not be amended.  The permit scheduled
for renewal will be allowed to expire provided the company
complies with the standard exemption.  However, any minor
change to a standard exempted piece of equipment may require
a new permit.

When voiding a previously issued permit for facilities that
have not been removed or destroyed, we will need to determine
if the company wants to have the opportunity to continue the
permit.  

Updated August 30, 1994