New Source Review (NSR) Program Basics

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New Source Review(NSR) Program Basics

• Racqueline Shelton, Raj Rao,
• Jessica Montanez, Wendy Namisnik
• U.S. Environmental Protection Agency
• Office of Air Quality Planning and Standards
• RTP, NC

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What should you gain from
this discussion about NSR?

• A better understanding of the New Source Review
  (NSR) program, including its
• purpose
• benefits
• requirements
• areas of concern
• components
• key terms, definitions, and concepts
• permitting considerations

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First, lets talk about why NSR is important
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What is the purpose of the NSR program?

• To ensure environmental protection while allowing
  economic growth!

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How does NSR ensure environmental protection?

• By controlling increases in air emissions that
  could affect attainment or maintenance of the
  National Ambient Air Quality Standards (NAAQS),
  or could have other adverse effects that can
  occur below the levels of the
  standards (e.g., visibility impairment)
• NAAQS have been set for
• Ozone (smog)
• Carbon Monoxide (CO)
• Particulate Matter (dust/soot)
• For each of the NAAQS pollutants (see Appendix
  A), every area of the U.S. is designated into one
  of the following categories
• Attainment - air quality is lower than the NAAQS
• Nonattainment - air quality is equal to or
  exceeds the NAAQS
• Unclassifiable - no data on air quality treated
  as attainment

• Nitrogen dioxide (NO2)
• Sulfur dioxide (SO2)
• Lead

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What are the benefits of the NSR program?

• A key tool for enabling nonattainment areas to
  reach attainment and for maintaining the National
  Ambient Air Quality Standards (NAAQS)
• Protects/Preserves clean air in national parks
  and wilderness areas, as well as other attainment
  areas

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What are the requirements of the NSR program?

• New or modified sources get permits prior to
  construction
• Sources install state-of-the-art control
  technology
• Sources/agencies make sure air quality impacts
  from the source will be acceptable

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What are the areas of concern in the NSR program?

• Regulations/policies are complex
• Areas of controversy exist in applicability and
  requirements interpretation
• Delays in permit issuance can cause construction
  delays

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• Now lets talk about
• how NSR works

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What are the components of the NSR program?
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PSD - NSR program for major sources in attainment
areas
If an area is in attainment, the goal is to keep
it in attainment in other words, prevent
significant deterioration (PSD) and keep clean
air clean.

• PSD applies to
• attainment pollutants
• new major sources and major modifications at
  existing major sources

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What defines a major source in
an attainment area? (PSD)

• A source with emissions of any one air pollutant
  greater than or equal to a threshold of
• 100 tons per year (tpy), if part of the 28 listed
  source categories. See Appendix B for the list
  of categories.
• 250 tpy, for all other sources not part of the 28
  listed source categories.
• Emissions based on potential to emit (PTE)
• PTE Emissions if operated 24 hours per day, 365
  days per year (8,760 hours/year) PTE includes
  the effect of add-on emission control technology,
  if enforceable.
• Enforceable means that the source must be able to
  show to EPA continual compliance with the
  limitation or requirement.

In NSR, a threshold is a value that makes a
source be subject to the respective NSR
requirements if the source emissions are at or
above this value.
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More on PSD

• Major for One, Major for All If a source emits
  even one pollutant (attainment or non attainment)
  in major amounts, the source will be considered
  major. Then all attainment pollutants, even
  those emitted in non-major amounts, will be
  reviewed for PSD applicability by using their
  respective Significant Emissions Rate (SER).
  Emissions equal to or higher than the SER make
  the pollutant subject to PSD (see Appendix E for
  SER list).
• For example, the SER for SO2, VOC and NOX is
  40tpy, which is lower than the 250 tpy major
  source threshold for PSD. If a major NOx source
  locates in an attainment area for NOx with a PTE
  of 50 tpy for NOx, the source would be subject to
  PSD for NOx.

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PSD permits

• Main requirements
• Require installation of Best Available Control
  Technology (BACT)
• Perform Air Quality Analysis to preserve existing
  clean air
• Perform Additional Impacts Analysis
• Special protections for national parks and
  wilderness areas
• Opportunity for Public Involvement

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NA NSR - NSR program for major sources in
nonattainment areas
If an area is in nonattainment, the goal is to
bring the area into attainment in other words,
improve the existing air quality.

• NA NSR applies to
• Pollutants for which the area is designated
  nonattainment
• new major sources and major modifications at
  existing major sources

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What defines a major source in a nonattainment
area? (NA NSR)

• Emissions of any one air pollutant greater than
  or equal to the major source thresholds in a
  nonattainment area. This threshold is generally
  100 tpy (or lower depending on the nonattainment
  severity) for all sources, regardless of
  category. For a list of the other applicable
  thresholds depending on the nonattainment
  severity, see Appendix C.
• Emissions based on potential to emit (PTE)
• PTE Emissions if operated 24 hrs. per day, 365
  days per year (8,760 hours/year) PTE includes
  the effect of add-on emission control technology,
  if enforceable.
• Enforceable means that the source must be able to
  show to EPA continual compliance with the
  limitation or requirement.

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NA NSR permits

• Main requirements
• Require installation of Lowest Achievable
  Emission Rate (LAER)
• Emission Offsets
• Opportunity for Public Involvement

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How is NA NSR applicability
different from PSD?

• NA NSR major source threshold is 100 tpy (or
  lower in some NA areas) for ALL sources. It is
  irrelevant what category the source belongs to
  because listed source categories do not exist for
  nonattainment NSR.
• At a new major source, NA NSR applies only to the
  NA pollutants with PTE above the major source
  threshold.
• This is unlike PSD, which applies to all
  attainment pollutants with significant emissions
  at a major source. In other words, the Major
  for one, major for all concept does not apply
  for NA NSR.

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What defines a minor source?

• Emissions less than the major source threshold of
  a pollutant
• lt100/250 tpy in attainment areas or
• lt100 tpy in non-attainment areas

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Minor NSR - NSR program for minor sources in
attainment AND nonattainment areas

• Applies to
• New minor sources
• Modifications at minor sources
• Minor modifications at major sources
• Applies in BOTH attainment and nonattainment
  areas
• Can be used to create synthetic minor sources
  this allows sources to avoid major source
  permitting requirements like NSR and Title V (For
  more information on Title V, please see Appendix
  D)

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What is a synthetic minor source?

• A source
• with PTE greater than or equal to the major
  source threshold, but has actual emissions below
  that level
• and brings PTE below the major source threshold
  by accepting enforceable limits on emissions or
  operating conditions

In NSR, actual emissions are the actual rate of
emissions from a source of any regulated
pollutant, calculated using the unit's actual
operating hours, production rates, and types of
materials processed, stored, or combusted over a
specified period of time. Certain conditions
apply.
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• Lets try an
• applicability example

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Example Which pollutants are subject to PSD,
NA NSR, and minor NSR permitting?

• Facts
• Kraft pulp mills produce the dark-colored wood
  pulp used in the manufacture of a variety of
  paper products
• The tons per year (tpy) in the plume are the
  mills potential to emit these pollutants

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Example solution

• Evaluate for PSD
• Determine what the applicable threshold is
• Since kraft pulp mills are one of the 28 listed
  source categories, the major source threshold is
  100 tpy, not 250 tpy
• Determine if the source is major based on the
  threshold
• In this case, the SO2 emissions are 185 tpy,
  which is greater than 100 tpy. This makes the
  mill a major source for PSD. Now we have to
  review all attainment pollutants for PSD
  applicability.

• Mills PTE
• SO2185 tpy
• VOC80 tpy
• PM1010 tpy
• Area is in
• NA for SO2
• Attainment for VOC and PM10

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Example solution (Continued)

• Review the two attainment pollutants based on
  their SER to see if they fall into PSD
• The mills VOC PTE is 80tpy, but VOC is not on
  the SER list. However, it is a precursor for
  ozone, and ozone is on the list with a SER of 40
  tpy. VOC is subject to PSD because PTE is higher
  than 40 tpy.
• PM10 is on the SER list with a SER of 15tpy. The
  mills PM10 PTE is 10tpy, which is less than the
  SER. PM10, not subject to PSD.

• Mills PTE
• SO2185 tpy
• VOC80 tpy
• PM1010 tpy
• Area is in
• NA for SO2
• Attainment for VOC and PM10

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Example solution (Continued)

• Evaluate for NA NSR
• Determine what the applicable threshold is
• Major source threshold for moderate NA is 100
  tpy.
• Determine if the source is major based on the
  threshold
• PTE for SO2, the NA pollutant, is 185 tpy, which
  is greater than the 100 tpy threshold. Mills
  SO2 emissions are subject to NA NSR.
• Evaluate for Minor NSR
• PTE for PM10, is 10 tpy, which is higher than the
  proposed minor NSR threshold of 5 tpy for
  attainment areas. Mills PM10 emissions are
  subject to minor NSR.

• Mills PTE
• SO2185 tpy
• VOC80 tpy
• PM1010 tpy
• Area is in
• NA for SO2
• Attainment for VOC and PM10

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Conclusion

• NSR protects public health and welfare, as well
  as national parks and wilderness areas, even as
  new sources are built and existing sources
  expand.
• NSR ensures that air quality does not worsen
  where the air is currently unhealthy to breathe,
  and that air quality is not significantly
  degraded where the air is currently clean.
• NSR requires that a source should install modern
  pollution control equipment when it is built (for
  new sources) or when it makes a modification that
  increases emissions significantly (for existing
  sources).
• NSR is important because it protects air quality
• while allowing economic growth.

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Appendix ANational Ambient Air Quality Standards
(NAAQS) Values
Pollutants Primary Standards Averaging Times Secondary Standards
Carbon Monoxide 9 ppm (10 mg/m3) 8-hour -------
Carbon Monoxide 35 ppm (40 mg/m3) 1-hour -------
Lead 1.5 µg/m3 Quarterly Average Same as Primary
Nitrogen Dioxide 0.053 ppm (100 µg/m3) Annual (Arithmetic Mean) Same as Primary
Particulate Matter (PM10) 150 ug/m3 24-hour -------
Particulate Matter (PM2.5) 15 µg/m3 Annual (Arithmetic Mean) Same as Primary
Particulate Matter (PM2.5) 35 ug/m3 24-hour -------
Ozone 0.08 ppm 8-hour Same as Primary
Sulfur Oxides 0.03 ppm Annual (Arithmetic Mean) -------
Sulfur Oxides 0.14 ppm 24-hour -------
Sulfur Oxides ------- 3-hour 0.5 ppm (1300 ug/m3)
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Appendix BPSD source categories with 100 tpy
major source thresholds
1. Coal cleaning plants (with thermal dryers) 15. Coke oven batteries
2. Kraft pulp mills 16. Sulfur recovery plants
3. Portland cement plants 17. Carbon black plants (furnace process)
4. Primary zinc smelters 18. Primary lead smelters
5. Iron and steel mills 19. Fuel conversion plants
6. Primary aluminum ore reduction plants 20. Sintering plants
7. Primary copper smelters 21. Secondary metal production plants
8. Municipal incinerators capable of charging more than 250 tons of refuse per day 22. Chemical process plants
9. Hydrofluoric acid plants 23. Petroleum storage and transfer units with a total storage capacity exceeding 300,000 barrels
10. Sulfuric acid plants 24. Taconite ore processing plants
11. Nitric acid plants 25. Glass fiber processing plants
12. Petroleum refineries 26. Charcoal production plants
13. Lime plants 27. Fossil fuel-fired steam electric plants of more than 250 million British thermal units (BTU) per hour heat input
14. Phosphate rock processing plants 28. Fossil-fuel boilers (or combination thereof) totaling more than 250 million BTU/ hour heat input
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Appendix CMajor source thresholds for NA areas
Nonattainment Areas Nonattainment Areas Nonattainment Areas Nonattainment Areas
Pollutant Nonattainment Classification Major Source Threshold Offset Ratio
Ozone Marginal ( 0.085 lt 0.092 ppm) 100 tpy of VOC or NOx 1.1 to 1
Ozone Moderate ( 0.092 lt 0.107 ppm) 100 tpy of VOC or NOx 1.15 to 1
Ozone Serious ( 0.107 lt 0.120 ppm) 50 tpy of VOC or NOx 1.2 to 1
Ozone Severe ( 0.120 lt 0.187 ppm) 25 tpy of VOC or NOx 1.3 to 1
Ozone Extreme ( 0.187 ppm and up) 10 tpy of VOC or NOx 1.5 to 1
Particulate Matter (10µm) Moderate 100 tpy -
Particulate Matter (10µm) Serious 70 tpy -
Carbon Monoxide Moderate (9.1 16.4 ppm) 100 tpy -
Carbon Monoxide Serious (16.5 and up ppm) 50 tpy -
Sulfur Dioxide, Nitrogen Oxides and Lead No nonattainment classifications exist 100 tpy -
1 There are no classification design value
thresholds (i.e., ranges in parenthesis) for PM10
as there are for ozone and CO. All PM10
nonattainment areas were originally classified
moderate, but an area is supposed to be
reclassified to serious if the area does not
attain by its attainment date.
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Appendix DTitle V

• Title V operating permit program for major
  sources where permitting authorities issue
  legally enforceable documents (permits to
  operate). The program is commonly known as Title
  V because the requirements for these permits come
  from Title V of the Clean Air Act Amendments of
  1990.
• Most title V permits are issued by State and
  local permitting authorities. Standards for State
  permit programs are found in the Code of Federal
  Regulations at 40 CFR part 70. However, the EPA
  also issues title V permits to sources in Indian
  country and in other situations, as needed.
  EPA-issued permits are called part 71 permits.
• Major sources that become synthetic minor sources
  avoid Title V requirements.

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Appendix ESignificant Emission Rates (SERs)

• Significant Emission Rate a rate of emissions
  that would equal or exceed any of the following
  rates
• Notwithstanding the above, any emissions rate or
  any net emissions increase associated with a
  major stationary source or major modification,
  which could construct within 10 km of a Class I
  area, and have an impact on such area equal to or
  greater than 1 ?g/m3 (24-hour average)

Pollutant SER (tpy) Pollutant SER (tpy)
Carbon Monoxide 100 Hydrogen sulfide(H2S) 10
Nitrogen Oxide 40 Total reduced sulfur (including H2S) 10
Sulfur Dioxide 40 Reduced sulfur compounds (includes H2S) 10
Particulate Matter 25 PM, 15 (PM10) Municipal waste combustor organics 3.5 x 10-6
Ozone 40 of VOCs Municipal waster combustor metals 15
Lead 0.6 Municipal waste combustor acid gases 40
Fluorides 3 Municipal solid waste landfills emissions 50
Sulfuric acid mist 7