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IDNR is revising the Chapter 22 requirements for construction permit exemptions, the Permit By Rule for spray booths, and the Title V insignificant activities to ensure protection of the new or revised national ambient air quality standards (NAAQS) for PM2.5, lead, NO2, and SO2.  Notably, some of the changes include new small unit exemption thresholds and R&D exemption thresholds for PM2.5, lead and hourly NOx.  The welding exemption thresholds are also decreasing, and small combustion unit exemption fuel usage or size thresholds are also changing for certain fuels.

Summary table for Construction Permit Exceptions and PBR

Summary table for Title V Insignificant Activities  

IDNR will begin including PM2.5, NO2, and SO2 in the review and issuance of construction permits for minor projects (those not subject to Prevention of Significant Deterioration (PSD) review) on January 2, 2013.  IDNR already began permitting minor projects for lead on October 31, 2011.  IDNR is also expected to finalize new minor source project increase modeling triggers of 2.15 lb/hr of PM2.5 and 9.0 lb/hr of NOx (a 9.00 lb/hr threshold for SO2 is already in place) to be added to the existing thresholds listed in Form MD.

Trinity recommends expedited construction permitting for planned changes at your facility in order to have IDNR issue permits prior to January 2, 2013 if the proposed changes will have difficulty meeting the new criteria.  Contact Eugene Taylor or Lori Price of Trinity's Iowa office for more details or assistance.