Engr   Sam Crowther, P.E.
date   07-13-87 
keys   continuances legal rnew complete 
            
Legal believes if the permit continuance application is
incomplete, but is received prior to the expiration date,
permit may expire depending on what complete means.  Legal
thinks if it is complete with objective criteria like forms
filled in then it will not expire.  As long as application is
complete with forms filled in, then the permit is extended
until provision of 116.12(f) now 116.314(c) becomes operative. 
Complete for the above purpose does not mean application is
complete enough to authorize public notice or issue a permit. 

Engr   Lawrence E. Pewitt, P.E. 
date   03-14-89 
keys   permit rnew continuance fees              
            
The permit continuance fee is based on allowable emissions. 
The allowable emissions are those established during
continuance review.  In certain cases a company may want the
continuance review of more than one permit conducted at the
same time and combined into one permit after continuance
review.  In this case the continuance fee should be based on
the allowable emissions from each permit.  The base fee plus
the incremental fee must be furnished for each permit
previously issued.    

engr   Sam Crowther, P.E. 
date   09-25-89 
keys   rnew continuance method of control permit 
            
(1)  Improvements in method of control do not need an added
fee; (2)  True amendments handled in an renewal do need the
amendment fee, but do not hold up renewal issuance for
amendment reasons unless the facility is exceeding a permit
condition and issuance will resolve any exceedance reported to
region; (3) renewals at the same plant in the same time frame
can be combined but only after each permit has a renewal fee
and public notice, although one public notice with all permits
listed will suffice.  The combination can occur only after
each permit is continued.  

Engr   Lawrence E. Pewitt, P.E. 
date   03-07-90 
keys   continuance fee rnew permit   
            
If continuance application is withdrawn before issuance, we
keep all of the fee.  This includes if the continuance can be
issued as a standard exemption. 

Engr   Duncan F. Stewart
date   7-16-92  
keys   pn, rnew, new permit                    

Dow Freeport asked to amend and renew permit 2804.  2804
covers two bisphenol trains.  They are physically separate and
run by different management teams.  Dow asked for a separate
permit for one train that required renewal public notice.  The
issue was whether a separate public notice was required for
the new permit.  Legal said no, that the renewal publication
did not cover the combined renewal and amendment, something we
have routinely done in the past.  The new permit is an
administrative convenience, not requiring a separate public
notice.  

date  5-18-94
keys  rnew fee std ex permit

Regulation VI requires standard exemptions be rolled into a
permit when it is renewed or amended.  Renewal fees are based
on the total tons per year of emissions in the permit and the
total fee will include emissions associated with the standard
exempted sources.