At its Autumn Environmental Conference and Expo held on October 9-11 in Austin, the Texas Commission on Environmental Quality (TCEQ) revealed that it will institute a number of significant changes for 2019 regarding how New Source Review (NSR) air permit applications will be processed. These changes are being made in an effort to reduce the review time of NSR permit applications received by the agency. Presentations from the TCEQ Autumn Environmental Conference and Expo on the new permitting procedures may be viewed here.
New Air Dispersion Modeling Submission Procedures
Beginning January 1, 2019, air dispersion modeling (if required) must be submitted with the permit application for minor NSR permitting actions. For NSR permitting actions triggering federal Prevention of Significant Deterioration (PSD) review, an air dispersion modeling protocol must be submitted concurrent with the application. If an application is deficient in these items, the applicant will be given a 10-day Notice of Deficiency to submit the required modeling/protocol before the project is voided. In order to facilitate the air dispersion modeling submissions, TCEQ has prepared an Electronic Modeling Evaluation Workbooks (EMEW) for minor NSR screening modeling (i.e., the SCREEN3 air dispersion model) and for projects that use the AERSCREEN, AERMOD, or ISC/ISC-PRIME air dispersion models. Starting June 1, 2019, all modeling analyses must be submitted using the appropriate EMEW in lieu of an Air Quality Analysis modeling report, which is intended to streamline the modeling submission process, facilitate the prevention of common errors found in model input calculations, and speed up the overall permitting timeline. Implications of the new procedure include additional lead time in preparing the permit application submittal and the potential need for updating the modeling analysis if TCEQ requires any adjustments in emission rates or other permit representations that impact modeling during the technical review process.
New NSR Application Submission Procedures
Beginning June 1, 2019, initial NSR applications and NSR permit amendments will be required to be submitted electronically (by email) and in hardcopy form. The electronic and hardcopy applications must include a newly developed "NSR Application Workbook", which combines various application elements, including TCEQ Form PI-1, Table 30, Table 1(a), public notice applicability, general Best Available Control Technology (BACT) requirements, and minimum monitoring requirements. TCEQ requests that the completed NSR Application Workbook be submitted in its native (i.e., spreadsheet) format with the electronic filing of an NSR application.
The modeling EMEWs and NSR Application Workbook are currently available here from TCEQ and may be used immediately, if desired. If you have questions regarding how the proposed air dispersion modeling and permit application submission changes may impact your permitting plans, contact the Trinity office nearest you by calling (800) 229-6655 for more information.