seimp.txt
seimp.txt
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Texas Natural Resource Conservation Commission
Interoffice Memorandum
To: New Source Review (NSR) Program Staff
Date: August 31, 1994
From: Jeff Saitas, P.E., NSR Program Director
Subject: Implementation of Regulation VI, Rule 116.116(c)
1. The subject rule requires that changes to permitted
facilities that have been authorized by standard exemption
(STDX), rather than amendment, to be "incorporated into
that facility's permit" when it is next amended or
renewed. The purpose of this memo is to provide
instructions for implementation of this requirement.
2. The intent of this rule is to provide permit holders with
means to expeditiously make needed modifications to
permitted facilities by STDX, but ensure that the modified
facilities are ultimately permitted. The incorporation of
these facilities operating under STDX into subsequent
permit amendments or renewals terminates authorization by
exemption and initiates authorization under permit. This
will be accomplished as outlined below.
3. Procedures
a. There is no one source that identifies the STDX that
would need to be incorporated. The database is a good
source for all exemptions that have been registered
(XRVW) or claimed (XLTR) since June 1993 and the
permit file sometimes contains documentation on STDX
previously registered or claimed with regions.
However, requesting the applicant to provide this
information is probably the most effective way to
identify them.
b. The next step is to determine from those exemptions
that, exist at a facility, those that were
specifically a modification to the facility whose
permit is being amended or renewed. Incorporation
applies only to changes that have the potential to
cause a modification to a permitted facility, i.e.
modifications to the permitted facility that change
character of emissions, increase emissions or alter
the method of control.
c. Incorporation into the permit amendment or renewal
will take the form of adding the STDX emission points,
sources, contaminants and emission rates to the
maximum allowable emission rate table, and including
any pertinent operating limitations, recordkeeping
requirements, etc. in the special provisions.
d. The following are considerations when incorporating
STDX into permits during amendment or renewal:
1. STDX emission rates do not count toward emission
increases for determining whether public notice is
required for amendments.
2. STDX process, materials or equipment are not
subject to BACT evaluation for the amendment under
review.
3. STDX emissions will not be included with those
used in determining the necessity for modeling and
health effects evaluation (under the Interim
Policy for Modeling and Effects Review
Applicability Guidance Document for Non-Criteria
Pollutants) for amendments. STDX emissions will
only be included in health effects evaluation of
contaminants emitted from the facility when
plantwide modeling is required to be performed by
the Interim Policy.
4. STDX capital cost will not be included with other
capital costs in determining amendment fee, but
STDX emissions will be included with those of the
permitted facility in determining renewal fee.
e. If the STDX is registered or has been acknowledged by
letter from the TNRCC as being exempt, the
registration will be voided at the time of
incorporation. This can be accomplished by these
three steps:
1. Indicate in the provisions that the permit now
includes previously standard exempted
facility(ies) and/or in the cover letter that
transmits the amended or renewed permit. Transfer
the documentation in the STDX file to the permit
file so that the representations in the permit
file are complete.
2. Enter similar explanatory information in the
remarks section of the Point Source Database
(PSDB) for the permit being amended or renewed.
3. Void the PSDB for the STDX registration, as
applicable.