TCEQ Direct Assistance Guidance Demonstration Form PI-1 ...

Direct Assistance Guidance Demonstration: Form PI-1 General Application Beth Akers NSR Permit Reviewer, Air Permits Division Autumn Environmental Conference and Expo October 8, 2019 Form PI-1 General Application Replaces previous PI-1 with an interactive form Improves efficiency of the permitting process Provides improved application materials Allows for a quicker review

Milestones OCT 2018 Posted new workbook for initial and amendment applications only MARCH Expanded use to many NSR applications Renamed to Form PI-1 General Application 2019 JUNE 2019 Required on all NSR application submittals

SEPT 2019 Released version 4.0 Permit Types Included Minor NSR Nonattainment

PSD, GHG PSD Flexible HAP (112 g) PAL Minor NSR* Special Permits De Minimis

Flexible PSD, GHG PSD Nonattainment HAP (112 g) PAL Action Types Included Initial

Amendment Renewal Alteration Major modification Voluntary Update Extension to Start of Construction Relocation Change of Location Whats NOT included? to Qualified

FacilitiesFacilities ChangesChanges to Qualified Plant Permits Plant Permits MultipleMultiple Alternate Means of Compliance Means of Compliance (AMOC) Alternate

(AMOC) Standard Permits Permits Standard by Rule by (PBR) Permits Permits Rule (PBR) Title V Permits Title V Permits Consolidates Many Forms The new PI-1 contains data previously submitted

through: PI-1, PI-1R, or PI-D Table 1(a) for emission rates and stack parameters Table 30 and Table 30R for permit fee Submitted either through ePermits or email Submittal Through ePermits ePermits is now available for NSR applications Original signature not needed Regional office and local program are notified through STEERS Confidential information submitted without

encryption Submit attachments with the original submittal EASY Hard Copy Requirements (ePermits) Public notice viewing file Applicable program areas, such as: Federal Land Managers Indian Councils Neighboring states See Copies sheet on PI-1 for complete

details Submittal Through Email By email to [email protected] Submit attachments in same email as PI-1 Separate confidential information. Submit it using: FTP site or email encrypted with password Confidential disc or flash drive Confidential hard copy Original Signature Requirements (email) General Page with original signature required for:

Initial Major modification Amendment Change of location Renewal Relocation Renewal/amendment - Major modification

- Change of location - Relocation Hard Copy Requirements (email) Hard copies required for: Regional office Local programs Public notice viewing file Applicable programs as listed on PI-1 Printing Set Up Files received and filed electronically at TCEQ

Central File Room Both PDF version and Excel versions stored Print setup set for PDF versions Getting Started Complete sheets in sequence from top to bottom and left to right. Do not complete the workbook sheets out of order. If you can see the sheet title, there are questions applicable on that sheet. Scroll down. Complete all yellow cells. Pay attention to red cells.

General Permit Action Type Permit Type Action Type Requested Minor NSR Amendment Not applicable Not applicable Not applicable Major Modification Renewal De Minimis

Flexible PSD Response required for each permit type to ensure correct conditional formatting throughout workbook. Unit Types-Emission Rates Used to generate MAERT Calculates emission increases and decreases Identifies actions associated with facilities Identifies Tier I BACT for most sources Identifies minimum monitoring requirements Unit Types Copying from MAERT Columns D-H match your MAERT, so you can copy

data from an existing MAERT. Unit Types Copy / Paste Do not cut, insert, or delete rows. Use paste as values or match destination formatting. Unit Types-Copy/Paste Restrictions Only copy and paste yellow cells; do not paste across columns M-N. Blank Table Worksheet

Formatting matches Unit Types-Emission Rates sheet No formulas Copy/paste/delete/insert Good place to add PM10 and PM2.5 Unit Types - Emission Rates Include all sources on the permit. If a control device controls multiple sources, list each source to address BACT and monitoring separately. Facility ID Number (FIN) Tank1 Tank2 Load Rack 1

Flare1 Emission Point Number (EPN) FLARE1 FLARE1 FLARE1 FLARE1 Source Name Tank1 Tank2 Truck Loading Flare

Pollutant VOC VOC VOC VOC NOx Unit Types - Entering Data Use drop-down or enter in a specific pollutant. Consistency matters! For example, CO wont be combined with Carbon Monoxide in Emissions Summary. A blank is treated as 0 to minimize data entry. You can enter <0.01 emission rate.

Data can have several decimal places. Unit Types- Industry Type Dont miss the industry type drop-down selection above the table! Permit primary industry Chemical / Energy (Select one) Chemical / Energy Coatings Combustion Mechanical / Agricultural / Construction Unit Types Dont forget Columns O and P

Do not miss columns (O-P), which trigger BACT and monitoring requirements to populate. Description for other will be used on BACT and Monitoring sheets. Consider the Effects Include in Emission Summary used for Public Notice Summary Only considers annual emissions, not hourly emissions Column A Action and Unit Type triggers BACT

and monitoring New / Modified Not New / Modified Renewal Only Consolidate Remove Flex Permits All sources must be listed on Unit Types-Emission

Rates sheet to address: BACT Monitoring Stack Parameters List caps to determine Emission Summary Sources may be listed with no emissions included in a cap if New Flex Permits Sheet NEW!

Identifies sources and pollutants in caps Lists source contributions to the cap Source Nam e Total Flare 1 Tank 1 Fug Total FL-1 TK-1 FUG

Total Site Flare Storage Tank Fugitives Total Yes Yes No Change EPN

Proposed FIN FIN has a pollutant in any cap? Current this cell is this intentionally cell isthis intentionally blank

cell is intentionally blank this cell blank is intentionally blank VOC 5 2 3 9 5 4

4 3 1 Public Notice Emission increases for Public Notice applicability do not include consolidated emissions. Added explanation for GHG notice and removed the public notice threshold CO2e. Send APD electronic (.PDF) copies of tear sheets and affidavits.

Projects Requiring Impacts Review Include an impacts summary with submittal. Qualitative analysis Modeling & Effects Review Applicability (MERA) steps 0-2 If modeling is conducted, an EMEW is required. MERA steps 3-8 Site-wide Modeling (using screen or refined) PSD Permitting requires a protocol. BACT Tier I BACT will be populated. Expand the height of the row to see the full text. Additional details are required in red cells of the

additional notes column. Include Tier II, Tier III, and/or LAER in the additional notes column or as an attachment. BACT for Renewals Do not require current Tier 1 BACT. If source does not meet Tier 1, list the control technique currently in use. Must be economically feasible and technically practicable.

Added Action column to identify modified sources vs. renewed sources. Monitoring Minimum monitoring requirements populated. Attach additional information if necessary. Use the drop downs to indicate how emissions will be measured for pollutants above PSD major source thresholds. Federal Applicability Summary only Table 1F, 2F, 3F, 4F are still required, if applicable

Added optional dropdown to request a different ozone classification Added PSD/NA netting questions and instructions Take Advantage of Embedded Links Guidance on: Federal NSR applicability Impacts Analysis PBR incorporation SIC, NAICS, Texas Secretary of State Handling of Confidential Information Delinquent fee information

Additional Updates Alteration conditional formatting Red means amendment is required More Alteration, GHG and Renewal Cert conditional formatting Less information required Updated formulas in Public Notice tab for PM/PM10/PM2.5 Changed monitoring requirement to apply to FINS instead of EPNs

More Additional Updates Stack parameters not needed with EMEW BACT for bulk fuel terminal and facilities using plant fuel gas Improved Impacts sheet layout, dropdowns and guidance Unlocked columns for applicant internal notes All fees now on Fee sheet Still More Additional Updates Updated formulas not compatible with Excel 2013 Using versions and patch numbers in lieu of dates

Current version is 4.0, released September 18 Version 3.0 accepted until December 1, 2019 Descriptions of updates listed on the web Materials Sheet Item A. Administrative Information Form PI-1 General Application Hard copy of original signature B. General Information Core Data Form Area map Plot plan Process description

Process flow diagram List of MSS activities State regulatory requirements discussion NEW! How submitted Date submitted STEERS 9/01/2019 STEERS 9/01/2019

STEERS 9/01/2019 STEERS 9/01/2019 STEERS 9/01/2019 STEERS

9/01/2019 STEERS 9/01/2019 STEERS 9/01/2019 STEERS 9/01/2019 Help! How do I start?

Form PI-1 General Application Directions Examples New Source Review Application Tools website Step-by-step guidance videos available here and on YouTube Tips for completing forms New Source Review Application Tools Website Current Form PI-1 General Application Electronic Modeling Evaluation Workbook (EMEW) Industry Specific Workbooks Free Microsoft account if needed

List of updates for both PI-1 and EMEW Tips for completing these forms Guidance videos for both PI-1 and EMEW Examples Multiple operating scenarios Caps, Grouped emission points Change in AP-42 emission factors Consolidating emissions Flex Permits Remember The PI-1 is a tool. Each application will be reviewed case by case. Draft permit will be reviewed and approved by applicant.

Faster and with fewer questions! Helpful Links NSR Application Tools: srapp-tools.html Step-by-Step videos: srapptools-videos.html STEERS:

FTP site: Contact Information Beth Akers Phone: (512) 239-4620 Email: [email protected] Kate Brown (512) 239-1583 Air Permits (512) 239-1250

(ask for PI-1 representative for your industry)

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