snglprop.txt

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          Texas Natural Resource Conservation Commission
                      Interoffice Memorandum

To:  New Source Review Permit (NSRP) Permit Engineers
Date:  March 16, 1998
From:  Victoria Hsu, P.E., Director, NSRP Division
Subject:  Permit Actions associated with Single Property Designations.

Recently there have been several companies which, for business reasons, wish to sell portions of
their existing permitted facilities to separately owned and operated entities.  Usually these actions
also involve a petition to the commission for a Single Property Designation (SPD) under 101.2
(b) due to the close proximity of the two properties.  The purpose of this memo is to describe
how NSRP staff should handle administrative permit actions which split existing NSR permits.

  1) In order to be considered a permit split, there must be no new construction, no increase in
emission and no change in the character of emissions.  This is strictly an administrative action.
  2) The holder of the new permit must provide NSRP with a completed PI-1 form (for
information purposes - no technical information) and  must be current on their franchise tax.
  3) No fee will be required.  No compliance history will be required.  This may change to be
consistent with the agency rules regarding permit changes of ownership (currently 116.110(c)).
  4) No public notice will be required.
  5) No BACT or impacts review will be required.  An impacts review may be necessary if the
companies do not obtain a Single Property Designation for whatever reason.
  6) The "new" permit will be renewed based on the date that the original permit was issued.
  7) A new permit number will be issued for the split off permit.
  8) For database purposes, there should be a CRVN project for the existing permit and the new
permit and a MSPD project for each if a Single Property Designation is involved.  There will not
be a CRVW project issued.

Any questions should be directed to David Howell at 239-1270.