1. Permits by Rule in Conjunction With Existing New Source Review Authorizations
Sabrina Coty-Butler and John Bregger
Air Permits Division
Texas Commission on Environmental Quality
Environmental Trade Fair 2018
Permits by Rule in Conjunction with Existing New Source Review Authorizations
Sabrina Coty-Butler and John Bregger
Air Permits Division
Texas Commission on Environmental Quality
Environmental Trade Fair 2018

2. Permits by Rule (PBRs) Utilization
Presentation Topics
Permits by Rule (PBRs) Utilization
PBR Background
Examples
Pre-Permit Meeting
Presentation Topics
These are the topics we are going to cover in this presentation:
First we are going to give some Permit by Rule (PBR) background information
Next, and the main focus of the presentation, we will discuss some uses of PBRs when a site has an existing authorization.
Please keep in mind that there are a large number of potential uses for PBRs. The following are just a few examples of what is possible, but intended to be a comprehensive look. Each scenario is unique and depends on the situation represented in an application. All applications are subjected to review.
Please note that every project is different and still subject to the prohibitions outlined in the site’s NSR permit conditions, best available control technology (BACT), and any other applicable rules or regulations.
Last, we will discuss the importance of pre-permit meetings and a few additional items.

3. PBR Background Relatively Small Emissions 108 Different PBRs
30 TAC §106.4
Specific PBR authorization requested
Limitations Set By
PBR Background
De Minimis
The smallest of emission sources regulated by the TCEQ are known as De Minimis sources. These sources emit relatively low amounts of air contaminants and are considered to have a minimum impact on air quality. The requirements for claiming the De Minimis authorization are listed in Title 30 Texas Administrative Code (30 TAC) § (a)(1). There is also a list of De Minimis Sources provided by the TCEQ.
De Minimis air emission sources: 30 TAC § (a)(1)
Active list of De Minimis Sources:
PBRs
There are 108 various PBRs that can be claimed or registered to meet the many diverse needs of the companies in Texas. There are some PBRs that can be claimed (i.e., do not need to be registered with the TCEQ). However, many require registration, such as oil and gas sites that handle sour gas. The PBR will state whether registration is required. In addition, some PBRs require approval by the TCEQ before construction begins, such as Bulk Sand Handling Facilities.
All PBRs must meet the general requirements of 30 TAC Chapter 106, Subchapter A. Among those requirements are the emissions limitations of 30 TAC §106.4:
250 tpy Carbon Monoxide (CO) and Nitrogen Oxides (NOX)
25 tpy of Volatile Organic Compounds (VOC), Sulfur Dioxide (SO2), or inhalable Particulate Matter (PM)
15 tpy PM10, 10 tpy of PM2.5
25 tpy of any other contaminant
Various requirements for major sources and Prevention of Significant Deterioration (PSD) sources
For New Source Review (NSR) permitted sites with no preclusion to using PBRs at the site in special conditions
Obtaining NOX allowances, if applicable to the Mass Emissions Cap and Trade Program in Chapter 101
No circumvention
Complying with the Federal Clean Air Act and the Texas Clean Air Act
Requirements can be found at:
Image Attributions
Flare photo:
Storage tanks:
Pugmill:

4. Benefits of Using a PBR PBR NSR 30 TAC §106 No public notice
45-day target date
No customization
No more than $450 fee
NSR
30 TAC §116, Subchapter B
Potential public notice
120-day target date
Special conditions
No less than $900
Benefits of Using a PBR
30 TAC = Title 30, Texas Administrative Code
PBR
30 TAC §106
No public notice
45-day target date
No customization
No more than $450 fee
NSR
30 TAC §116, Subchapter B
Potential public notice
120-day target date
Special conditions
No less than $900
There are many pros to using a PBR to add a facility to a NSR permitted site. These pros are why some prefer authorizing new facilities under PBRs, rather than a permit amendment. Let us look at some common questions during a project review and then we will go over a few scenarios to illustrate PBR usage with case-by-case NSR permits.

5. Common Questions Common Questions Common Questions
Although questions vary during a review, depending on the specifics of each project, a few common questions that usually asked are:
Meet requirements of §106.4 and PBR authorization request?
New piping/fugitives only?
New facilities?
Changing existing facilities’ purposes?
What is it? Where is it coming from? Where is it going? How is it getting there?
What physical changes were made?
Adding or bypassing controls?
Upstream/downstream
Special conditions prohibiting
Did company give us actual emissions or only allowables?
Did company discuss state and federal applicability? [Chapters 115, 117, New Source Performance Standards (NSPS), Maximum Achievable Control Technology (MACT), National Emission Standards for Hazardous Air Pollutants (NESHAP), etc.]
Will it be referenced or incorporated into an associated NSR permit?
Image Attributions
Valve Photo:
Thermal Oxidizer:

6. Incorporate by Consolidation Incorporate by Reference
Incorporation
Incorporation
When using PBRs to authorize modifications and changes to an NSR authorized process, please keep in mind that the PBR must be incorporated into the NSR permit somehow. The two options are incorporation by consolidation or incorporation by reference. It is up to the company to work with the appropriate NSR section to determine which of the two they will do when the time comes to incorporate the PBRs. Generally, this is done when the affected NSR permit is next amended or renewed.
Per the memo from September 26, 2006:
§ (d) Permits by rule under Chapter 106 of this title (relating to Permits by Rule) [may be used] in lieu of [a] permit amendment or alteration.
(1) A permit amendment or alteration is not required if the changes to the permitted facility qualify for an exemption from permitting or permit by rule under Chapter 106 of this title unless prohibited by permit condition as provided in § of this title (relating to General and Special Conditions).
(2) All changes authorized under Chapter 106 of this title to a permitted facility shall be incorporated into that facility's permit when the permit is amended or renewed.
§ (3) Standard permit in lieu of permit amendment. All changes authorized by standard permit to a facility previously permitted under § of this title (relating to Applicability) shall be administratively incorporated into that facility's permit at such time as the permit is amended or renewed.
The PBR and SP Consolidation Memo can be found at
30 TAC § (d) can be found at
30 TAC § (3) can be found at

7. Examples Aggregates General 261/262 140s NSR Tank Series 470s
Surface Coating
433
Tank Series 470s
NSR
Examples of PBRs
Examples
Examples of PBRs
Relationship of NSR to Aggregates, General, Surface Coating, and Tank Series PBRs
For the following examples, assume the underlying permit authorization for the site is an applicable NSR case-by-case permit. PBRs can be used in conjunction with these types of permits as a way to avoid amending NSR permits and obtain an authorization on a more timely basis.
Image Attributions
Geoff Henson– Aggregate works
Houston Chronicle – Tank

8. Fugitives Only Project
Fugitive Only Project – usually adding valves, piping, flanges, or connectors for various purposes
Diagram: Adding valves and sample ports to conduct testing on product lines
For these types of projects, make sure to include why the project was conducted. Reviewers look for justifications to ensure that projects truly are fugitive only and not more comprehensive. Confirming the appropriate authorization ensures that companies remain in compliance.
Example:
Company has added valves and sample ports in order to conduct testing on their product lines. How are these authorized?
Answer: PBRs /262 – depending on what the products are. Demonstrate the requirements as applicable. The project application must include speciated emissions so that a reviewer can confirm the emission limitations of /262 are met. Otherwise, the reviewer will request more information for that project, delaying the timeline for authorization, and may also lead to the project being withdrawn.
A fugitive only project is not a project:
that allows a line to bypass controls otherwise used in the operation
that sends an existing line to a control that it didn’t originally go to
Decreases bottlenecking or otherwise increases throughput and capacity

9. Warning!
WARNING!
§ – Doesn’t have annual notification allowances. Specifically, § (3) states “within ten days.”
 (3) Notification must be provided using Form PI-7 within ten days following the installation or modification of the facilities. The notification shall include a description of the project, calculations, and data identifying specific chemical names, L values, D values, and a description of pollution control equipment, if any.
Rule text can be found here:
Some additional things to be aware of:
Can’t modify or add to any pollution abatement equipment
Can’t use 261/262 if a more applicable PBR is available to your operation

10. Changing Fuels Dryer Natural Gas Changing Fuels
Diagram: Storage tank used to store natural gas will be used to fuel a dryer. Fuel tank changes to store propane to fuel the dryer.
Fuel Change –
ABC Incorporated requests a change in fuel type – from natural gas to propane.
How would you do this? PBRs 261/262 – change in combustion emissions from natural gas to propane.
Demonstrate that the change in fuel and associated combustion emissions would meet § limits for propane (i.e., 6.0 lbs/hr and 10 tpy). Of course, any changes to piping configuration (i.e., fugitives) due to a change in tank would also have to be considered.
What about the storage of your new fuel?
It comes in a pressurized tank that will be switched out.
Appropriate mechanism for the tank in this case is § Fugitive emissions would be covered under this PBR.
**Please note that every project is different and still subject to the prohibitions outlined in the site’s NSR permit conditions, best available control technology (BACT), and any other applicable rules or regulations.

11. adding New Tank for Storage
Truck Loading
Diesel
Truck Loading
Adding New Tank For Storage
Diagram: Addition of a diesel storage tank that will be refilled with fewer trucks
What if the project involves having to construct a new tank?
If you are constructing a new tank, this would be authorized under one of the PBRs in 30 TAC 106 Subchapter U – Tanks, Storage, and Loading. These PBRs are used to authorize the construction and/or associated emissions from tanks, storage, handling, and loading/unloading of chemicals/products/materials. Each of the PBRs has their own nuances and set of requirements, so it is up to the applicant to determine which of the PBRs best suits their particular operation.
In this case, the site has decided that having less trucks coming to the site to deliver diesel would help the company’s bottom line. The company decides that a resolution is to build a diesel tank on site under PBR 472 Organic and Inorganic Liquid Loading and Unloading. Please keep in mind that what you are storing/handing will determine the more appropriate Subchapter U PBR. (We will see more in upcoming slides) These PBRs can be claimed or registered, depending on the size of the tank.
**Please note that every project is different and still subject to the prohibitions outlined in the site’s NSR permit conditions, BACT, and any other applicable rules or regulations.
Link to Subchapter U:
Link to § :
Image Attribution:
Truck created by Ivan Luiz from Noun Project

12. Change of Service Diesel Gasoline Change of Service
Diagram: Change from diesel to gasoline storage
You would need to look through the tank PBRs Subchapter U Tanks, Storage and Loading.
In this case, the change of service can be done under either § or §

13. Change of Service Chemical A Chemical B
Change of Service in NSR Permitted Tank(s)
Diagram: Chemical A authorized under NSR case-by-case permit with change to service of the tank to Chemical B
Company has a tank that currently stores Chemical A authorized under a NSR case-by-case permit. Company wants to change the service of the tank to Chemical B. There are several PBRs that could be used for this type of project. Please look under 30 TAC §106.4, Subchapter U – Tanks, Storage, and Loading, otherwise known as the 470s series, which was discussed earlier. Please remember that changes authorized under one of these PBRs can be claimed or registered.
Whichever PBR is most applicable to a project must be used for authorization.
Link to Subchapter U:

14. IN ADDITION Chemical A Chemical B Chemical A/B
Change of Service in NSR Permitted Tank(s) In Addition
Diagram: Storage tanks that will store multiple chemicals at different times
Company has a tank farm in which they wish to store multiple types of chemicals in the same tank, but not at the same time. This is viewed as chemical flexibility and has a couple of authorization options.
If the proposed chemical is listed in 30 TAC § , then the addition can be authorized under a change of service, §
If the proposed chemical is not listed under 30 TAC § , then the company will now have to account for emissions resulting from Chemical B under 30 TAC §§ /262.

15. Adding a New Process Line
Diagram: Representation of addition of new process line being routed to existing control device
Project: Company wants to add a NEW process line to its operation. This new line will be sent to an existing control device (such as a flare or a thermal oxidizer) that is already authorized under the site’s NSR permit.
Answer: YOU CAN! As long as you meet the special conditions of your NSR permit, ensure the control device still meets BACT, and maintain the permitted control efficiencies, and if the process line or stream is new (i.e., not previously authorized), you can send it to an existing control device. Make sure to include new emissions at this control device and any other affected upstream/downstream sources since you will see an increase in ACTUAL emissions. You will be required to show the ACTUAL emissions associated with the project, not just the allowables. Additionally, make sure that the lines are independent of one another.
Image Attribution:
Created by Ralf Schmitzer from Noun Project

16. Adding A New Process Line and New Control Device
Diagram: Representation of addition of new process line being added and routed to new control device
Can I add a new process line and a new control to my site?
YES! As long as you continue to meet the special conditions and other requirements of your NSR permit and can demonstrate compliance with the applicable PBR, you can add a new line.
The new line would be authorized under the appropriate PBR and the new flare (control device) would be authorized under 30 TAC § So, what would happen if Not Your Company decided to add a thermal oxidizer instead of a flare to control emissions? In the case of using a new process oxidizer, the emissions would need a 30 TAC § and § authorization with respect to the company’s emissions.
Of course, do not forget the usual questions:
Are there any upstream/downstream affects to facilities/emissions already authorized under the NSR permit?
What are the baseline actuals for any NSR permitted sources?
Image Attribution:
Created by Ralf Schmitzer from Noun Project

17. Existing Line Routing to Existing Control Device
To Atmosphere Arrow showing routing direction for example of routing existing process line to an existing flare; Not allowed symbol (additional information can be found in the speaker notes)
Process Line #1
Process Line #2
Existing Line Routing to Existing Control Device
Diagram: Existing Process Line #1 to an existing control device and existing Process Line #2 previously routed to atmosphere and now routing to an existing control device
Company wants to route an existing line of product to an existing control device. How would this be authorized?
Answer: Not under a PBR. This would be considered a pollution control project. The appropriate authorization would be a Pollution Control Standard Permit. The company would need to submit an application for authorization under this type of permit.
Company wants to route an existing line of product to a new control device. How would this be authorized?
Answer: Again, not under a PBR. This would also be considered a Pollution Control project. The appropriate authorization would be a Pollution Control Standard Permit. The company would need to submit an application for authorization under this type of permit.
• If an existing facility is currently uncontrolled, and a project proposes to route the emissions to an existing control device, this change is not authorized under PBRs §§ /262 and must be authorized under standard permit.
• If an existing facility is currently uncontrolled, and a project proposes to route the emissions to a new control device, this change is not authorized under PBRs §§ /262 and must be authorized under standard permit.
Image Attribution:
Created by Ralf Schmitzer from Noun Project

18. Surface Coating Surface Coating Process Line #1 Coating Addition
Spray Booth #1
Surface Coating
Process Line #1
Coating Addition
Spray Booth #2
Surface Coating
Company has an underlying NSR permit for their site and wants to modify their surface coating operations.
Company has requested authorization for a new coating to use during their operations. How can they get approval? Some questions that will need to be answered:
Is this new coating affecting your current authorization?
Does it affect your special conditions? Is there a special condition that limits the type or emissions of a new coating?
Can you provide the actual increase of emissions resulting from the use of a new coating?
Please provide a Material Safety Data Sheet/Safety Data Sheet (MSDS/SDS) for each new coating.
Answer: Adding a new coating to their operation would require an authorization under PBRs /262. Again, selection of an authorization is dependent on whichever of the PBRs is applicable. It could be both. The company will need to account for these new emissions, the actual emissions associated with the project, when showing compliance with the appropriate PBR. Do not just represent that this increase is below the emission allowables as authorized by the NSR permit. This new coating has never been accounted for in emission totals and is considered new. Therefore, it requires it’s own full review and authorization.
Company has requested an additional paint booth to use during their operations. What is the appropriate authorization?
Questions before receiving an answer:
What is the reason for the additional booth?
Will there be an increase in emissions?
Answer: The appropriate authorization would be under
Image Attributions:
Process created by Ralf Schmitzer from Noun Project
Spray Gun created by Delwar Hossain from Noun Project
Paint Can created by Megan Hillman from Noun Project

19. Throughput Increase Throughput Increase Process Line #1 Spray Booth #1
Using the same surface coating example from before – Company has requested an increase in their throughput of widgets coated during operations. What should they do here?
Questions to answer:
What are the current actuals?
What would be the increase? Hourly? Annual? Both?
Does the calculation methodology used in the PBR match the methodology used in the NSR case-by-case permit?
Scenario –
Company is at 100 widgets per hour. The increase requested is 100 widgets per hour, for a total of 200 widgets coated per hour.
Authorizing the increase in throughput under PBRs /262 is acceptable. What we will look at is the actual increase of emissions and not the increase above the allowables. We expect to see an increase in hourly and annual emissions. If a new hour is required in order to achieve the annual throughput, we expect to see those emissions as well.
The same with the previous example, the new spray booth and associated emissions would need to be authorized under
The needs of each company and each site are different, which is why a pre-permit meeting is important.
Image Attributions:
Spray Gun created by Delwar Hossain from Noun Project
Process created by Ralf Schmitzer from Noun Project

20. Throughput Increase 100,000 gallons/year 50,000 gallon/year
Diagram: Tanks shown changing throughput from 50,000 gallons per year to 100,000 gallons per year
This scenario deals with tanks.
Company wants to increase throughput of tanks from 50,000 gallons per year to 100,000 gallons per year. What should the company do?
Questions to ask:
Why is the increase occurring?
Is it the same product being stored?
Answer: Similar to the surface coating example. Authorizing the increase in throughput under PBRs §§ /262 is acceptable. What we will look at is the actual increase of emissions and not the increase above the allowables. We expect to see an increase in hourly and annual emissions. If a new hour is required in order to achieve the annual throughput, we expect to see those emissions as well. When submitted, the actual increase of emissions should match the speciated emission totals. If the totals do not match, a reviewer will contact the company asking for the relevant updates.

21. Upstream and Downstream Effects
Additional Materials
Truck Loading
Upstream and Downstream Effects
Diagram: Raw materials tank depicting upstream/downstream effect of throughput increase from additional materials to storage to truck loading
Going back to the tanks increasing throughput example – Company wants to increase the throughput through the tanks from 50,000 to 100,000 gallons per year.
Additional questions for this type of scenario:
Where is the new raw material or product coming from?
What is happening to it while (in this case) it’s in the storage tank?
Where does it go after the storage tank?
These are questions asked when discussing upstream and downstream effects. If there are any additional throughputs or production changes before or after the storage tanks that are a direct effect or directly affected by the increase in throughput, these will need to be considered.
Remember that each situation is different, but it is good practice to account for any federal applicability issues within the PBR application. We are more than happy to discuss specific situations in a pre-permit meeting.
Image Attribution:
Truck created by Ivan Luiz from Noun Project

22. Effects of Special Conditions on PBRs
There are occasions where even if a project appears to meet all the applicable requirements of 30 TAC §106.4, the related PBR in question, and State/Federal rules and regulations, a PBR still cannot be used for authorization. Situations like these arise from a variety of issues, but we wanted to touch on one in particular, as it is one of the most common issues – NSR permit special conditions that limit the use of PBRs at a site.
We wanted to cover a few scenarios in which a PBR would not be appropriate, and the company will need to work to revise the NSR permit.
Image Attribution:
Created by Jerad Maplethorpe from Noun Project

23. NOT WITH A PBR Adding Stockpiles Stockpile Stockpile Stockpile
Special Conditions
Stockpile
Stockpile
Stockpile
NOT WITH A PBR
Off-Loading Truck
Off-Site Receptor
Adding Stockpiles
Special condition limiting use of PBRs
Background: Aggregate company went through an expansion project that required an amendment to their NSR permit. During the NSR case-by-case permit evaluation, it was determined that the site would not meet the National Ambient Air Quality Standards for particulate matter equal to or less than ten microns in diameter (PM10) and particulate matter equal to or less than 2.5 microns in diameter (PM2.5). These issues with the NAAQS were due to an off-property receptor that was about 100 feet from the site. In order to meet the NAAQS, the company agreed to limit their stockpile acreage to ten acres. After modeling, the company and the TCEQ determined this would be sufficient for the site to meet the NAAQS for PM10 and PM2.5. The NSR permitted emissions were updated as well.
As a result of the company limiting their stockpiles to meet these requirements, a special condition was added to the NSR permit stating, “Any acreage used for stockpiles and/or stockpile purposes will be limited to 10 acres.” This limit was based on their own self imposed limitations and the need to lower emissions due to NAAQS PM10 and PM2.5 concerns.
Several years later, the company submitted a project stating that the original closest off-property receptor has moved, and the company now wants to expand their stockpile acreage to cover the newly available land. The application requests additional stockpile acreage of 16 acres, for a total of 26 acres used for stockpiling. This new expansion has also increased the PM emissions by a large quantity due to the calculation methodology for stockpiles.
Issue: The company has the special condition limiting them to 10 acres of stockpile acreage.
The reviewing engineer for this project worked with the company and appropriate NSR case-by-case staff to determine that the NSR permit would need to be amended through the NSR permit amendment process rather than through a PBR. The self-imposed limitations from the original amendment, as well as the NAAQS impacts concerns, led to the PBR being withdrawn.
Summary: If there is a special condition that limits the use of PBRs, a PBR cannot be used to change the acreage.
Image Attributions:
Dump Truck created by Vectors Market from Noun Project
Dirt created by Shawn Erdely from Noun Project
Barn created by Kelsey Chisamore from Noun Project

24. NOT WITH A PBR Adding Facilities Spray Booth #1 Process Line #1
Special Conditions
Spray Booth #1
Process Line #1
NOT WITH A PBR
Spray Booth #2
Adding Facilities
A special condition prohibits using a PBR to add additional facilities to a site.
A company wants to add an additional surface coating booth to their NSR permitted site. The booth will be used to conduct touch up on pieces that have already been coated. These touch ups will increase the volatile organic compound (VOC) and particulate matter (PM) emissions at the site. The company wants to use a PBR to authorize the new booth, but has some permit special conditions that affect the site-wide operations and emission totals.
We discussed earlier that the appropriate authorization for this scenario would be to use PBR , for a project that meets all the rules and requirements. However, when reviewing all of the applicable rules, regulations, and associated NSR permits, the company notes that they have a special condition in their NSR permit that states “Additional facilities cannot be added using a Permit by Rule.” This is the end of the line for use of a PBR for this particular project. If the special conditions of the NSR prevent the use of a PBR to modify the site or install new pieces of equipment, a PBR cannot be used.
Please look over the special conditions of your NSR permit before attempting to use a PBR for any projects.
As part of a review, TCEQ will look over the special conditions of the NSR permit and ensure that there are no conditions that prohibit the use of the PBR.
In addition, PBR reviewers will also contact case-by-case NSR section members for their input if the reviewer has concerns about the project.
In the case of this project, the company would need to withdraw their application (if one has already been submitted) and work to amend the associated NSR Permit.
Image Attributions:
Contract created by Gregor Cresnar from Noun Project
Spray Gun created by Delwar Hossain from Noun Project
Process created by Ralf Schmitzer from Noun Project

25. Air Pollutant Watch List (APWL) Areas
County
City
TCEQ Region
Year Added
Pollutant of Interest
Bowie and Cass
N/A 5
1999
hydrogen sulfide
El Paso 6
2004
hydrogen sulfide 
Jasper
Evadale 10
2003
Brazoria
Freeport 12
2005
arsenic  cobalt  nickel  vanadium 
Air Pollutant Watch List (APWL) Areas
The purpose of the APWL is to alert technical staff to cities and/or counties with the state of Texas with elevated air concentrations of special interest pollutants. There are a variety of them as can be seen in the list. Applicants should verify if their facilities are located in one of these areas before submitting their applications for project authorization.
When submitting a project in relation to an APWL area, there are three things to ask when conducting the research needed to put an application for a project together:
Am I located in an APWL area?
No – If your site is not located in an APWL area, then there is not further consideration necessary. This is a majority of projects, as there are only four active APWL areas in Texas.
If yes, please proceed to Question 2.
2) Does my project involve a Pollutant of Interest?
After determining that your project is located in one of the current APWL areas, you must ask if your project involves one of the pollutants of interests.
No – If your project doesn’t involve one of the pollutants of interest, then proceed with the project as you would any other project. It will be noted that the project is located in the applicable APWL, but it will not involve one of the pollutants of interests.
If yes, please proceed to Question 3.
3) Did I provide the appropriate information to the TCEQ?
If your project is located in an APWL area and includes a pollutant of interest, then your project must represent the emissions associated with those particular emissions and any offsets. So, if your project involves hydrogen sulfide (H2S), those emissions must be specifically calculated and represented apart from all other emissions. There will also be a review of other projects conducted at the facility involving H2S to determine if there were any previous reductions.
APWL reviews are going to a bit more complicated than this, but this is a general overview to help you get started.
The active APWL areas can be found here:

26. Pre-Permit Meetings Pre-Permit Meetings Overall Process
Purpose of project and how it fits into the process
Affected EPNs and emissions
Pre-Permit Meetings
These meetings are important for many projects:
Bring in technical experts from Rule Registrations Section and/or the NSR permitting sections as schedules allow.
Discuss ideas and concepts behind overall process.
Purpose of project and relation to the process.
Affected emission point numbers (EPNs) and all emissions that will need to be accounted for.
How a project will be authorized? Is a PBR the right method for your project?
Applicable and affected rules and regulations.
Federal applicability and/or any extraneous issues can be discussed.
Image Attribution:
Created by Scott Lewis from Noun Project

27. Pre-Permit Meetings Pre-Permit Meetings
How the project will be authorized?
Applicable and affected rules and regulations
Extraneous issues
Pre-Permit Meetings
We also happy to look at draft permits prior to submittal after the meeting.
Image Attribution:
Created by Scott Lewis from Noun Project

28. Summary PBR Information Common Questions Examples Pre-Permit Meetings
Image Attribution:

29. Update
As of February 1, 2018, all PBRs must be submitted through State of Texas Environmental Electronic Reporting System (STEERS) (additional information can be found in the speaker notes)
Update
Please keep in mind that all PBRs must be submitted through STEERS as of February 1, We will no longer accept hardcopies of any PBR related projects.
STEERS website:
STEERS main phone number: (512)
Image Attribution:

30. Air Permits Main Line: (512) 239-1250
Contact Us
John Bregger: (512) or
Sabrina Coty-Butler: (512) or
Air Permits Main Line: (512)
John Bregger: (512) or
Contact Us
Air Permits Main Line: (512)
John Bregger: (512) or
Sabrina Coty-Butler: (512) or