rnew.txt
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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 Engr Lawrence E. Pewitt, P.E. date 03-07-90 keys continuance fee rnew permit If continuance application is withdrawn before issuance, we keep all of the fee.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.