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

2. 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

3. 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”

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

5. 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

6. 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

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

8. 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

9. 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

10. 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

11. 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

12. 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

13. 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

14. 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

15. 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

16. 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

17. QUIZ TIME