TCEQ Spring Trade Fair Updates

After visiting Austin for the Texas Commission on Environmental Quality (TCEQ) Trade Fair on May 2019, ALL4 came back with some big takeaways that we wanted to share.  The biggest announcements came in the form of updates regarding TCEQ operations, the New Source Review (NSR) permitting tools, and the Readily Available Permit (RAP) process.  We highlight the biggest topics below, so read on to see if any of the following updates pertain to your environmental compliance!

General TCEQ Updates

Kicking off the Trade Fair in style, TCEQ announced their new focus on customer service.  They intend to reduce response time to calls and emails and went so far as to guarantee returned calls within 24 hours.  To speed along permitting, the TCEQ has removed a layer of signatures in the signature chain.  They have removed the 21 days of review for this step by downgrading the regional review from formal to informal.  Additionally, TCEQ announced NSR permitting will consist of a coordinated concurrent review between air permits and modelling divisions effective June 1^st.  The TCEQ has also developed and implemented interactive checklists to make sure the permitting stays on track.  Lastly, the TCEQ has been working on increasing the number of Permits by Rule (PBR’s) and Standard Permits available through e-Permitting.  This allows for more access to expedited permitting at all stages of interaction with the state regulators. 

NSR Permit Application Workbook Updates

The next order of business was this year’s workbook update presentations.  As many know, TCEQ rolled out new workbooks for NSR permitting and modelling this past October.  Both workbooks became effective permitting requirements as of June 1^st.  The NSR permitting workbook was renamed to the “Form PI-1 General Application Workbook” and updated with revised instructions to improve clarity.  TCEQ further explained the Air Permits Division (APD) prefers to receive all application materials electronically.  That being said, courtesy copies must still be printed and sent to their respective destinations.  The TCEQ clarified the differences between a permit renewal and a permit amendment using the drop downs in the workbook.  Another addition is a column in the Stack Parameters tab indicating the parameters are not required to be filled in if an Electronic Modeling Evaluation Workbook (EMEW) is being submitted with the application.  This also stresses the need for the complete application with required materials, including the EMEW, when submitting a permit application to ensure concurrent review.  Lastly, they mentioned the TCEQ may proceed to issue a permit if no response is received on Standard Conditions (SC) within the allotted time frame.

EMEW Updates

After the updates on air permit application forms, the TCEQ discussed EMEW updates.  Similar to the permitting application forms, the EMEW had formatting, wording, and sample problem updates.  The speciated chemicals sheet was updated to reflect the most recent Toxicology Effects Screening Levels (ESL) List.  TCEQ added a tab to account for Secondary PM_2.5 calculations so modelling teams no longer have to create their own calculations.  Another convenient addition was the added columns for applicant internal comments to assist in the modelling review.  Alongside other various bugfixes in the workbooks, both groups pointed out that they are still receiving feedback, and as always, you should confirm the version number before submitting an application.

RAPs Updates

Last, but not least, TCEQ’s announcement of two upcoming RAPs could significantly help permit applicants.  For those that don’t already know, RAPs are NSR permits with consistent SC, Maximum Allowable Emissions Rate Table (MAERT), and Best Available Control Technology (BACT).  All three are pre-determined and non-negotiable, which can be a little daunting at first.  However, RAPs allow for quick turnaround with around 90 days of review versus the normal 285-365 days a normal NSR application can take.  Additionally, it allows for consolidated Public Notices and a built-in air quality impact analysis to save from the costs of developing models and getting them approved.  The current RAPs available include simple cycle turbines and compressor stations.  The next two RAPs to be released will be an existing tank loading increase RAP and an existing or initial engine powered generators NSR permit.  The engine powered generator NSR permit would allow up to 10 engines to be permitted.  These two RAPs are expected to be released this summer.

Look at Rachel Henn’s most recent blog.  If you’re interested on hearing more about these updates, additional topics covered during the event, or recent activity at the TCEQ, don’t hesitate contact us.