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

2. 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

3. 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

4. What are the NSR programs ?

5. 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

6. 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

7. 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

8. QUIZ TIME

9. 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

10. 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

11. 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

12. 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

13. 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

14. 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

15. 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

16. 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