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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.

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Presentation on theme: "New Source Review (NSR) Program Basics Racqueline Shelton, Raj Rao, Jessica Montanez, & Wendy Namisnik U.S. Environmental Protection Agency Office of Air."— Presentation transcript:

1 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

2 2 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

3 3 First, lets talk about why NSR is important

4 4 What is the purpose of the NSR program? To ensure environmental protection while allowing economic growth!

5 5 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:see Appendix A 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 How does NSR ensure environmental protection? Nitrogen dioxide (NO2) Sulfur dioxide (SO2) Lead

6 6 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

7 7 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

8 8 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

9 9 Now lets talk about how NSR works

10 10 What are the components of the NSR program? New Source Review (NSR) Program Major NSR in attainment areas (PSD) Major NSR in nonattainment areas (NA NSR) Minor NSR in all areas

11 11 PSD - NSR program for major sources in attainment areas PSD applies to: attainment pollutants new major sources and major modifications at existing major sources 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.

12 12 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.Appendix B 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.

13 13 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).Appendix E For example, the SER for SO 2, VOC and NO X is 40tpy, which is lower than the 250 tpy major source threshold for PSD. If a major NO x 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.

14 14 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

15 15 NA NSR - NSR program for major sources in nonattainment areas NA NSR applies to: Pollutants for which the area is designated nonattainment new major sources and major modifications at existing major sources If an area is in nonattainment, the goal is to bring the area into attainment; in other words, improve the existing air quality.

16 16 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.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.

17 17 NA NSR permits Main requirements: Require installation of Lowest Achievable Emission Rate (LAER) Emission Offsets Opportunity for Public Involvement

18 18 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.

19 19 What defines a minor source? Emissions less than the major source threshold of a pollutant <100/250 tpy in attainment areas or <100 tpy in non-attainment areas

20 20 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)Appendix D

21 21 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. Major Source Threshold 0 50 100 150 200 250 300 350 Emissions (tpy) Actual PTE

22 22 Lets try an applicability example

23 23 Example: Which pollutants are subject to PSD, NA NSR, and minor NSR permitting? 10 tpy PM 10 80 tpy VOC 185 tpy SO 2 New Kraft Pulp Mill Area in attainment for PM 10 and VOC Area in moderate NA for SO 2 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

24 24 1.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 SO 2 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: SO 2 =185 tpy VOC=80 tpy PM 10 =10 tpy Area is in: NA for SO 2 Attainment for VOC and PM 10 Example solution

25 25 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. PM 10 is on the SER list with a SER of 15tpy. The mills PM 10 PTE is 10tpy, which is less than the SER. PM 10, not subject to PSD. Mills PTE: SO 2 =185 tpy VOC=80 tpy PM 10 =10 tpy Area is in: NA for SO 2 Attainment for VOC and PM 10

26 26 2.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 SO 2, the NA pollutant, is 185 tpy, which is greater than the 100 tpy threshold. Mills SO 2 emissions are subject to NA NSR. 3.Evaluate for Minor NSR PTE for PM 10, is 10 tpy, which is higher than the proposed minor NSR threshold of 5 tpy for attainment areas. Mills PM 10 emissions are subject to minor NSR. Mills PTE: SO 2 =185 tpy VOC=80 tpy PM 10 =10 tpy Area is in: NA for SO 2 Attainment for VOC and PM 10 Example solution (Continued)

27 27 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.

28 28 Appendix A National Ambient Air Quality Standards (NAAQS) Values PollutantsPrimary StandardsAveraging TimesSecondary Standards Carbon Monoxide9 ppm (10 mg/m 3 )8-hour------- 35 ppm (40 mg/m 3 )1-hour------- Lead 1.5 µ g/m 3 Quarterly AverageSame as Primary Nitrogen Dioxide0.053 ppm (100 µg/m 3 )Annual (Arithmetic Mean) Same as Primary Particulate Matter (PM 10 ) 150 ug/m 3 24-hour------- Particulate Matter (PM 2.5 ) 15 µg/m 3 Annual (Arithmetic Mean) Same as Primary 35 ug/m 3 24-hour------- Ozone0.08 ppm8-hourSame as Primary Sulfur Oxides0.03 ppmAnnual (Arithmetic Mean) ------- 0.14 ppm24-hour------- 3-hour0.5 ppm (1300 ug/m 3 )

29 29 Appendix B PSD source categories with 100 tpy major source thresholds 1. Coal cleaning plants (with thermal dryers)15. Coke oven batteries 2. Kraft pulp mills16. Sulfur recovery plants 3. Portland cement plants17. Carbon black plants (furnace process) 4. Primary zinc smelters18. Primary lead smelters 5. Iron and steel mills19. Fuel conversion plants 6. Primary aluminum ore reduction plants20. Sintering plants 7. Primary copper smelters21. 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 plants23. Petroleum storage and transfer units with a total storage capacity exceeding 300,000 barrels 10. Sulfuric acid plants24. Taconite ore processing plants 11. Nitric acid plants25. Glass fiber processing plants 12. Petroleum refineries26. Charcoal production plants 13. Lime plants27. Fossil fuel-fired steam electric plants of more than 250 million British thermal units (BTU) per hour heat input 14. Phosphate rock processing plants28. Fossil-fuel boilers (or combination thereof) totaling more than 250 million BTU/ hour heat input

30 30 Appendix C Major source thresholds for NA areas 1 There are no classification design value thresholds (i.e., ranges in parenthesis) for PM 10 as there are for ozone and CO. All PM 10 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. Nonattainment Areas PollutantNonattainment Classification Major Source Threshold Offset Ratio OzoneMarginal ( 0.085 < 0.092 ppm)100 tpy of VOC or NOx 1.1 to 1 Moderate ( 0.092 < 0.107 ppm)100 tpy of VOC or NOx 1.15 to 1 Serious ( 0.107 < 0.120 ppm)50 tpy of VOC or NOx 1.2 to 1 Severe ( 0.120 < 0.187 ppm)25 tpy of VOC or NOx 1.3 to 1 Extreme (= 0.187 ppm and up)10 tpy of VOC or NOx 1.5 to 1 Particulate Matter (10µm) Moderate100 tpy- Serious70 tpy- Carbon MonoxideModerate (9.1 – 16.4 ppm)100 tpy- Serious (16.5 and up ppm)50 tpy- Sulfur Dioxide, Nitrogen Oxides and Lead No nonattainment classifications exist100 tpy-

31 31 Appendix D Title 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.Title VClean Air Act –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.State and local permitting authorities40 CFR part 70 Major sources that become synthetic minor sources avoid Title V requirements.

32 32 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/m 3 (24-hour average) Appendix E Significant Emission Rates (SERs) PollutantSER (tpy)PollutantSER (tpy) Carbon Monoxide100Hydrogen sulfide(H 2 S)10 Nitrogen Oxide40Total reduced sulfur (including H 2 S)10 Sulfur Dioxide40Reduced sulfur compounds (includes H 2 S)10 Particulate Matter25 PM, 15 (PM 10 )Municipal waste combustor organics3.5 x 10 -6 Ozone40 of VOCsMunicipal waster combustor metals15 Lead0.6Municipal waste combustor acid gases40 Fluorides3Municipal solid waste landfills emissions50 Sulfuric acid mist7


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