Permit Revisions

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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

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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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