Engine Power Generation: Texas Commission on Environmental Quality Issues New Readily Available Permit

The Texas Commission on Environmental Quality (“TCEQ”) Air Permits Division announced the issuance of a new Readily Available Permit (“RAP”) for power generation engines.

TCEQ has previously issued RAPs for the following:

• Simple cycle turbine
• Compressor station
• Tanks and loading increases
• Marine loading

TCEQ developed RAPs for use in appropriate circumstances (i.e., on a case-by-case basis) to authorize New Source Review (“NSR”) initial action for certain types of facilities/emission sources. The RAP is a NSR permit for a type of facility/emission source that is based on certain emission calculations, equipment variables, and site-specific parameters.

A particular RAP provides the applicant the ability to utilize a draft permit for its type of facility/emission source. The intent is to provide the applicant in advance an understanding of what conditions will be included prior to submission of an application. Therefore, a facility/emission source fitting within the scope of a particular RAP potentially expedites the preparation of a draft permit.

TCEQ notes certain qualifications in regards to RAPs which include:

• Subject to change based on new developments such as:
  • Best Available Control Technology
  • Federal requirements
  • Emission factors
• Subject to all NSR public notice requirements

The engine power generation RAP can be utilized for the operation of up to 10 diesel-fired engines and up to 10 associated diesel storage tanks for the purpose of power generation at a new or existing site.

An application workbook has been prepared for this RAP which contains:

• Step-by-step instructions
• Specific qualifying criteria
• Technical information which includes:
  • Emission calculations
  • Best available control technology
  • Draft Special Conditions

Note that TCEQ states that if an applicant cannot meet the qualifying criteria or does not agree with the technical representations in the workbook it will receive a notice that the application has been voided and a different type of authorization should be obtained.

A link to the TCEQ announcement can be found here.