Direct Assistance Guidance Demonstration Form PI1 General Application Beth Akers NSR Permit Reviewer Air Permits Division Autumn Environmental Conference and Expo October 8 2019 Form PI1 General Application ID: 772846
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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 materialsAllows for a quicker review
Milestones Posted new workbook for initial and amendment applications only Expanded use to many NSR applications Renamed to Form PI-1 General ApplicationRequired on all NSR application submittalsReleased version 4.0 OCT 2018 MARCH 2019 JUNE 2019 SEPT 2019
Permit Types Included Minor NSR Nonattainment PSD, GHG PSD Flexible HAP (112 g)PAL Special Permits De Minimis Minor NSR* Flexible PSD, GHG PSD Nonattainment HAP (112 g) PAL Special Permits De Minimis* Minor indicates State-issued permit rather than Federal (Major) Permit. Title V major sites should use the PI-1 workbook for their NSR applications.
Action Types Included Initial Amendment Renewal Alteration Major modificationVoluntary Update Extension to Start of Construction Relocation Change of Location
What’s NOT included? Changes to Qualified Facilities Multiple Plant Permits Alternate Means of Compliance (AMOC) Standard Permits Permits by Rule (PBR) Title V Permits Changes to Qualified Facilities Multiple Plant Permits Alternate Means of Compliance (AMOC) Standard Permits Permits by Rule (PBR) T itle 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 feeSubmitted 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 STEERSConfidential information submitted without encryptionSubmit attachments with the original submittal EASY
Hard Copy Requirements (ePermits) Public notice viewing file Applicable program areas, such as: Federal Land Managers Indian CouncilsNeighboring statesSee Copies sheet on PI-1 for complete details
Submittal Through Email By email to APIRT@tceq.texas.gov Submit attachments in same email as PI-1Separate confidential information. Submit it using:FTP site or email encrypted with passwordConfidential disc or flash drive Confidential hard copy
Original Signature Requirements (email) General Page with original signature required for: Initial Amendment Renewal Renewal/amendment- Major modification- Change of location- Relocation 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 Response required for each permit type to ensure correct conditional formatting throughout workbook. Permit Type Action Type Requested Minor NSR Amendment Renewal Not applicable De Minimis Not applicable Flexible Not applicable PSD Major Modification
Unit Types-Emission Rates Used to generate MAERT Calculates emission increases and decreases Identifies actions associated with facilitiesIdentifies Tier I BACT for most sourcesIdentifies 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/insertGood 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) Emission Point Number (EPN) Source Name Pollutant Tank1 FLARE1 Tank1 VOC Tank2 FLARE1 Tank2 VOC Load Rack 1 FLARE1 Truck Loading VOC Flare1 FLARE1 Flare VOC NO x
Unit Types - Entering Data Use drop-down or enter in a specific pollutant. Consistency matters! For example, “CO” won’t 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 Don’t 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 – Don’t 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 monitoringNew / ModifiedNot New / ModifiedRenewal OnlyConsolidateRemove
Flex Permits All sources must be listed on Unit Types-Emission Rates sheet to address: BACT MonitoringStack ParametersList caps to determine Emission SummarySources may be listed with no emissions if included in a cap
New Flex Permits Sheet Identifies sources and pollutants in caps Lists source contributions to the cap NEW!
Public Notice Emission increases for Public Notice applicability do not include consolidated emissions. Added explanation for GHG notice and removed the public notice threshold CO 2e.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 0-2If 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 classificationAdded PSD/NA netting questions and instructions
Take Advantage of Embedded Links Guidance on: Federal NSR applicability Impacts AnalysisPBR incorporationSIC, NAICS, Texas Secretary of StateHandling of Confidential InformationDelinquent fee information
Additional Updates Alteration conditional formatting Red means amendment is required More Alteration, GHG and Renewal Cert conditional formattingLess information requiredUpdated formulas in Public Notice tab for PM/PM10/PM2.5Changed 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 guidanceUnlocked columns for applicant internal notesAll 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 18Version 3.0 accepted until December 1, 2019Descriptions of updates listed on the web
Materials Sheet Item How submitted Date submitted A. Administrative Information Form PI-1 General Application STEERS 9/01/2019 Hard copy of original signature STEERS 9/01/2019 B. General Information Core Data Form STEERS 9/01/2019 Area map STEERS 9/01/2019 Plot plan STEERS 9/01/2019 Process description STEERS 9/01/2019 Process flow diagram STEERS 9/01/2019 List of MSS activities STEERS 9/01/2019 State regulatory requirements discussion STEERS 9/01/2019 NEW!
Help! How do I start? Form PI-1 General Application Directions ExamplesNew Source Review Application Tools websiteStep-by-step guidance videos available here and on YouTubeTips for completing forms
New Source Review Application Tools Website Current Form PI-1 General Application Electronic Modeling Evaluation Workbook (EMEW) Industry Specific WorkbooksFree Microsoft account if neededList of updates for both PI-1 and EMEW Tips for completing these formsGuidance 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: https://www.tceq.texas.gov/permitting/air/guidance/newsourcereview/nsrapp-tools.html Step-by-Step videos: https://www.tceq.texas.gov/permitting/air/guidance/newsourcereview/nsrapptools-videos.html STEERS: https://www3.tceq.texas.gov/steers/FTP site: https://ftps.tceq.texas.gov/help/
Contact Information Beth Akers Phone: (512) 239-4620 Email: beth.akers@tceq.texas.gov Kate Brown (512) 239-1583Air Permits (512) 239-1250(ask for PI-1 representative for your industry)