Major New Source Review (NSR)—Part 1 Genevieve Damico U.S. EPA, Region 5

What should you learn from this discussion? Purpose of New Source Review (NSR) The NSR permitting programs and requirements Which NSR requirements apply to an individual project

What is the purpose of the NSR program? Preserve existing clean air in attainment areas and allow economic growth Assist efforts to attain clean air in NAA and allow economic growth Preserve/protect air quality in national parks & wilderness areas

What are the NSR programs ?

What does major NSR require? New or modified sources get permits prior to construction Public notice Sources evaluate pollution control equipment Sources analyze impact on air quality and other effects

What Some Benefits of the NSR program? PSD program has kept > 300 million tons of criteria pollutants out of air Some sources remain minor (take enforceable limit), resulting in lower emissions Requires technology-forcing control equipment Protects national parks and wilderness areas

What Are Some of the Complexities of the NSR program? Regulations/policies are complex Sources have a big economic incentive to avoid NSR Many areas of controversy Who needs permit What pollution control equipment required Pressure to issue permits to avoid construction delays

QUIZ TIME

How do you determine if PSD or NNSR permitting is applicable? Determine source’s potential to emit (PTE) Assess attainment status of source’s geographic area Determine applicable major source thresholds Determine if source is major for PSD or NNSR pollutants

1) What is the source’s potential to emit (PTE)? PTE: maximum capacity of source to emit a pollutant under its physical and operational design Base on operating 24 hrs. per day, 365 days per year (8760 hours/year) Include controls, if enforceable permit conditions or SIP/TIP/FIP conditions

2) What is the attainment status of source’s geographic area? Determine if area is in attainment or nonattainment for each criteria pollutant emitted Can contact EPA Regional office Can contact permitting authority Search database www.epa.gov/air/data

3) What are the applicable major source thresholds? PSD 100 TPY, if one of 28 industrial source categories listed 250 TPY for all other source categories NNSR 100 TPY, except lower for severe, serious, and extreme NAA

4) Is the source major for PSD or NNSR pollutants? Compare PTE of each pollutant emitted to “respective” PSD and NNSR major source thresholds Source major if one pollutant exceeds a threshold

Small-Group Activity: PSD or NNSR Pollutants? Potential to emit 260 TPY CO 55 TPY NOx 80 TPY VOC (ozone) Area is attainment for NOx & CO Area is moderate nonattainment for ozone List which pollutants are subject to PSD permitting and/or NNSR permitting Gas Processing Plant

Small Group Activity: PSD or NAA NSR Pollutants? (cont.) Potential to emit 185 TPY SO2 111 TPY VOC (ozone) 10 TPY PM10 Area is attainment for ozone & PM10 Area is nonattainment for SO2 List which pollutants are subject to PSD permitting and/or NNSR permitting Kraft Pulp Mill

What did we learn? NSR designed to protect and clean up air quality Sources must get permits before constructing NSR consists of 3 permitting programs PSD and NNSR requires sources to evaluate pollution controls Source could be subject to both PSD & NNSR permitting