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. 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. First, let’s talk about why NSR is important

4. What is the purpose of the NSR program?
To ensure environmental protection while allowing economic growth!
We’ll talk more about attainment and nonattainment areas in a minute

5. 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

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. 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. 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. Now let’s talk about
how NSR works

10. What are the components of the NSR program?

11. 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

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.
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.
So if the source is major for one pollutant, it is a major source for PSD. Then the PSD requirements apply for all pollutants emitted in significant amounts.
Notice that for ozone, we look at emissions of VOC and NOx. This is true for the major source cut-off and the significant level. Sources do not emit ozone. It is formed in the air by complex chemical reactions involving VOCs and NOx.

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).
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.

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. 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

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.
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.
Applicability (2nd bullet) sounds like PSD, but ...

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

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. 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. 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)

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

22. applicability example
Let’s try an
applicability example

23. Example: Which pollutants are subject to PSD, NA NSR, and minor NSR permitting?
10 tpy PM10
80 tpy VOC
185 tpy SO2
New Kraft Pulp Mill
Area in
attainment
for PM10 and VOC
Area in moderate NA
for SO2
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 mill’s potential to emit these pollutants

24. 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.
Mill’s PTE:
SO2=185 tpy
VOC=80 tpy
PM10=10 tpy
Area is in:
NA for SO2
Attainment for VOC and PM10
Note that the source is a major source for PSD purposes, even though it has a major emission level only of a nonattainment pollutant.

25. Example solution (Continued)
Review the two attainment pollutants based on their SER to see if they fall into PSD
The mill’s 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 mill’s PM10 PTE is 10tpy, which is less than the SER. PM10, not subject to PSD.
Mill’s PTE:
SO2=185 tpy
VOC=80 tpy
PM10=10 tpy
Area is in:
NA for SO2
Attainment for VOC and PM10

26. 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. Mill’s 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. Mill’s PM10 emissions are subject to minor NSR.
Mill’s PTE:
SO2=185 tpy
VOC=80 tpy
PM10=10 tpy
Area is in:
NA for SO2
Attainment for VOC and PM10

27. Conclusion NSR is important because it protects air quality
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. Appendix A National Ambient Air Quality Standards (NAAQS) Values
Pollutants
Primary Standards
Averaging Times
Secondary Standards
Carbon Monoxide
9 ppm (10 mg/m3)
8-hour
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)
Particulate Matter (PM10)
150 ug/m3
24-hour
Particulate Matter (PM2.5)
15 µg/m3
35 ug/m3
Ozone
0.08 ppm
Sulfur Oxides
0.03 ppm
0.14 ppm
3-hour
0.5 ppm (1300 ug/m3)

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 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

30. Appendix C Major source thresholds for NA areas
Nonattainment Areas
Pollutant
Nonattainment Classification
Major Source Threshold
Offset Ratio
Ozone
Marginal (≥ < ppm)
100 tpy of VOC or NOx
1.1 to 1
Moderate (≥ < ppm)
1.15 to 1
Serious (≥ < ppm)
50 tpy of VOC or NOx
1.2 to 1
Severe (≥ < ppm)
25 tpy of VOC or NOx
1.3 to 1
Extreme (= ppm and up)
10 tpy of VOC or NOx
1.5 to 1
Particulate Matter (10µm)
Moderate
100 tpy -
Serious
70 tpy
Carbon Monoxide
Moderate (9.1 – 16.4 ppm)
Serious (16.5 and up ppm)
50 tpy
Sulfur Dioxide, Nitrogen Oxides and Lead
No nonattainment classifications exist
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.

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.
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.

32. Appendix E Significant 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)
Carbon Monoxide
100
Hydrogen sulfide(H2S) 10
Nitrogen Oxide 40
Total reduced sulfur (including H2S)
Sulfur Dioxide
Reduced sulfur compounds (includes H2S)
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
Fluorides 3
Municipal solid waste landfills emissions 50
Sulfuric acid mist 7