Texas Natural Resource Conservation Commission Austin Texas Interoffice From: Lawrence E. Pewitt, P.E. Director, Permits Division To: Regional Directors and Permit Engineers Date: April 16, 1987 Subject: Permit Renewal In order to proceed with permit renewal review, the following procedures will be used to determine applicability and schedule for permit renewal: 1. Changes in Ownership - The date of the first operating permit will be used to determine the fifteen year period for permit renewal for permits issued prior to December 1, 1991. Any permit issued on or after December 1, 1991 is subject for renewal every ten years after the date of issuance. 2. Changes in Location - The date of the last operating permit issued will be used to determine the fifteen year period for permit renewal for permits issued prior to December 1, 1991. Any permit issued on or after December 1, 1991 is subject for renewal every ten years after the date of issuance. A company may want to claim a standard exemption for the facilities addressed by permit renewal review. If this occurs, the company may request the permit be voided with all conditions of the applicable standards met. As a reminder, there is at least one advantage of a permit because a standard exemption can not be amended. The permit scheduled for renewal will be allowed to expire provided the company complies with the standard exemption. However, any minor change to a standard exempted piece of equipment may require a new permit. When voiding a previously issued permit for facilities that have not been removed or destroyed, we will need to determine if the company wants to have the opportunity to continue the permit. Updated August 30, 1994