As debuted back in October 2018, the Texas Commission on Environmental Quality (TCEQ) has created two workbooks, a New Source Review (NSR) application workbook and an electronic modeling evaluation workbook (EMEW), in order to increase consistency, accuracy, and efficiency during the permit review process.
The NSR workbook will be a combination of several existing forms, such as the PI-1/PI-1R, Table 30/30R, Public Notice, BACT Tier I, and Table 1(a). All forms that are incorporated into the NSR workbook will no longer be available on the TCEQ form website as of June 1, and the NSR application workbook will be renamed the PI-1 to align with the language in 30 TAC Chapter 116. Applicants must submit the NSR application workbook for all NSR permitting actions, including initial, amendment, renewal, and alteration. Only the signature page (first page of the NSR workbook) is required to be submitted as a hard copy to the TCEQ Air Permits Division. When submitting the application to the appropriate TCEQ Regional Office and/or the local air pollution control office, the NSR application workbook is required to be submitted as a hard copy (no email submittal).
Below are some highlights from the NSR application workbook as noted by TCEQ during the Trade Fair in May:
- Complete the workbook in the same order of the tabs because as you answer questions in earlier tabs, cells in later tabs will be grayed out, if not required;
- Only list the stack parameters if the EMEW workbook is not being submitted as a part of the application;
- The Public Notice tab determines public notice applicability for all project types;
- The renewal and amendment fees can be combined in one payment although the workbook will calculate these separately;
- The ozone (non)attainment status of the county can be adjusted. This is important for the DFW and HGB nonattainment areas as redesignation to serious ozone nonattainment is anticipated later this year. During the submittal process, you can make the site applicable to the more stringent standards before the resdesignation;
- During the Best Available Control Technology (BACT) assessment, the sources that are renewed and not modified are only listed to show compliance with Tier I evaluations. A BACT evaluation is not required for these sources;
- The monitoring tab is only for PSD applications, it will be grayed out if the PSD application is not selected;
- When adding the emission summary information for each source, copy from your own similar workbook for emission calculations. The NSR workbook does not include calculations, only final emission rates.
The EMEW workbook will also be required as of June 1, 2019. The goal of this workbook is to initiate discussion of modeling impacts upfront, alongside the application submittal. This encourages adjustment of emission calculation and inclusion of control devices if necessary to pass modeling. This workbook can be used for both AERMOD and SCREEN3. This workbook, like the NSR workbook, will be emailed to TCEQ Air Permits Initial Review Team (APIRT). Hard copy submittals are only necessary for the appropriate TCEQ Regional Office, local air control program, and as part of any applicable public notice. It is also important that the EMEW be completed in order tab by tab. When information is not required in later tabs, the workbook will automatically gray out unnecessary sections. The EMEW workbook is expected to replace the traditional air quality analysis (AQA) for minor permit application. This will facilitate a more efficient review process for TCEQ. Note that major source NSR modeling requires a protocol upfront with the application and completion of the EMEW for major sources as well as a more traditional AQA later in the permit review process.
As TCEQ releases new versions of the workbooks, they will allow for a transition period for workbook submittal. A spreadsheet compare tool can be used to compare versions of each workbook to see what has been updated by TCEQ. Feedback on these workbooks is also welcomed by the TCEQ. Click here to learn more about the workbooks.
For more information on these changes and what this could mean for your facility, please contact Katie Jeziorski in Trinity's Dallas office at (972) 661-8100, or your local Texas office to see how Trinity can guide you through the NSR permit application and air dispersion modeling process.