Major New Source Review (NSR) Part 2 Genevieve Damico U.S. EPA, Region 5

What should you learn from this discussion? Why a source may not be subject to NSR What sources subject to PSD permitting must do What sources subject to NNSR permitting must do

Why might a new source not be subject to major NSR? PTE < major source thresholds Source is “grandfathered” (built before August 7, 1977) Source opted for “synthetic minor”

What must a major source subject to PSD do? Control technology analysis – Best Available Control Technology(BACT) Air quality analysis Additional impact analysis

What is Best Available Control Technology (BACT)? Emissions limit, case-by-case Limit must be at least as stringent as applicable NSPS Top-down analysis Selection of controls based on energy, environment, and/or economics

What is an air quality analysis and its purpose? Assessment of existing air quality Modeling estimate of ambient concentrations from proposed project Will new + existing emissions cause or contribute to NAAQS or PSD increment violation? Increment is maximum increase over baseline concentration

What is an additional impact analysis? Assesses area impacts of increased pollution on Soils Vegetation Visibility

What is done with the PSD information? Source submits the analyses in PSD permit application to permitting authority Permitting authority evaluates analyses/application to determine requirements for PSD permit Permitting authority issues the permit for public comment

What must a major source subject to NNSR do? Control technology analysis – Lowest Achievable Emissions Rate (LAER) Obtain offsets Alternative sites analysis Show statewide facility compliance w/air regulations

What is the Lowest Achievable Emission Rate (LAER)? Most stringent limitation achieved in practice for such source class or category Technology “forcing” Limit must be at least as stringent as applicable NSPS Unlike BACT, does not consider energy, environment, or economics

What are offsets? Net emissions increases must be “offset” (reduced) by greater emissions decreases Allow NAA to move toward attainment status while allowing some industrial growth Emissions reductions may come from that source (if existing) or other sources within same or nearby NAA Lack of available offsets can limit economic growth in NAA

Offsets (cont.) Offsets required in addition to LAER, not in lieu of LAER Offset emission reductions must be Quantifiable Permanent In effect before source commences operation

What is an “alternative sites analysis”? Analysis of alternative sites, sizes, production processes, and environmental control techniques Demonstrates benefits of proposed source significantly outweigh environmental and social costs resulting from its construction or modification at that location

What is statewide facility compliance? Source owner must certify that all major sources owned/operated in state in compliance with all applicable CAA requirements Compliance also with federally-approved SIP Presumably would apply to reservations instead of states, and to TIPs

What is done with the NNSR information? Source submits the analyses in NNSR permit application to permitting authority Permitting authority evaluates analyses/application to determine requirements for NNSR permit Permitting authority issues permit for public comment

What did we learn? Not all new sources are subject to major NSR permitting PSD requires BACT, NNSR requires LAER LAER is more stringent than BACT PSD requires analysis to determine impact on air quality NNSR requires “offsets” to clean up dirty air

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