Permit Revisions, Why Does PDEQ Care?
Pima County Department of Environmental Quality (PDEQ)
oversees the provisions of your air quality permit,
including those regarding permit revisions. Because
PDEQ recognizes
that business growth benefits more than just the business,
we want you to be able to make changes to your operations
as easily as possible.
Application Packet
for Air Quality Permit Transfer
What is a Permit Revision?
Based upon state and federal requirements, an Air Quality
Permit Revision may be required when a permitted facility
forsees changes in its operation such as a change of ownership,
change in potential to emit air pollutant or equipment
swapping.
There are many changes or modifications you the business
person can make to your facility which may affect your
air quality permit. A brief description of the
two types of simple changes and two types of more complex revisions follow.
1) ADMINISTRATIVE CHANGES
These are changes which can be made upon submittal of the
requested change to
the department, including:
1. correct typographical errors,
2. change a name, address or telephone number,
3. change equipment identification numbers, building numbers, etc.
4. change to more frequent monitoring or reporting requirements,
5. change in ownership, following provisions listed in Title 17 and with prior
notice.
2) FACILITY CHANGES ALLOWED WITHOUT PERMIT REVISIONS
A permittee may make changes seven days after sending prior
written notice to
PDEQ if all of the following apply.
The changes do not:
...qualify as modifications under any provision of Title
I of the Clean Air Act (increase actual emissions)
....result in emissions that exceed the permit's allowable
emissions
....violate any existing or new applicable requirements (violate any
rules to which the source is subject, or cause the source to be subject to
rules to which it was not previously subjected)
....contravene permit conditions concerning
monitoring, record keeping, reporting, or compliance.
For example: when substituting
one printing press with another identical or substantially similar model, a
simple notification to the department in writing seven
days before installing the new
equipment may be all that is necessary. 3) MINOR PERMIT REVISIONS
A permittee may make changes immediately upon applying
to PDEQ if all of the
following apply.
The changes must not:
...violate any applicable rule
...involve
substantive changes to existing monitoring, reporting,
or record keeping
requirements
...require or change a case-by-case
determination of an emission limitation or other standard
...establish or change
a permit condition for which there is no applicable requirement and which the
permittee has assumed in order to avoid an applicable requirement,
...be a major source modification,
...involve fuels not covered by existing permit,
...increase a source's potential to emit above significant levels,
...require processing as a significant permit revision.
It's important to know
that no "shield" exists for these revisions. If the revision is determined
not to be a minor permit revision, the permittee will be required to apply for
a significant permit revision and may be required to return to the pre-revision
status or be subject to enforcement action. 4) SIGNIFICANT PERMIT REVISIONS
A permittee making a change which does not qualify for
any of the categories listed previously is making a
change that will require a significant permit revision.
Such a change will require public notice and may not be made until the permit
is revised and reissued.
Example 1: A facility currently holding an air quality
permit decides to add a hard- chrome plating line.
The addition would involve substantive changes
to existing monitoring, recordkeeping and reporting requirements, requiring
a significant
permit revision. The significant permit revision would have to be filed
and approved by PDEQ before the facility could add
the plating line.
Example 2: A facility holds an air quality permit with
federally enforceable voluntary air emission levels.
A proposed operational change would cause
those levels to be exceeded, placing the facility's potential to emit
above permitted
levels. Again, the significant permit revision would have to be filed
and approved by PDEQ before the operational change
could be implemented.
Last Word: If neither of the two permit changes nor the
minor permit revision apply to you, apply for a significant
permit revision.
Where Can I Get Assistance?
PDEQ's Business Assistance Program staff will assist
you in determining how your proposed change in operations
will affect your air quality
permit. Assistance
with completing the forms and determining potental to emit is also
available. Additionally, meetings with PDEQ permitting staff are
gladly arranged
at the request of the permittee.
For further assistance, contact the Business Assistance
Program at 724-7400.
This brochure is designed as a guideline to assist business
owners/operators in determining how changes to their
facility may affect their
air quality permit. Associated fees are not mentioned. For
additional information,
refer to sections
17.12.230 - 17.12.260 of Title
17 of Pima County Code, Air
Quality Control.
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