Presentation on theme: "New Source Review (NSR) Program Basics"— Presentation transcript:
1 New Source Review (NSR) Program Basics Racqueline Shelton, Raj Rao,Jessica Montanez, & Wendy NamisnikU.S. Environmental Protection AgencyOffice of Air Quality Planning and StandardsRTP, NC
2 What should you gain from this discussion about NSR? A better understanding of the New Source Review (NSR) program, including its:purposebenefitsrequirementsareas of concerncomponentskey terms, definitions, and conceptspermitting considerations
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 NAAQSNonattainment - air quality is equal to or exceeds the NAAQSUnclassifiable - no data on air quality; treated as attainmentNitrogen 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 constructionSources install state-of-the-art control technologySources/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 complexAreas of controversy exist in applicability and requirements interpretationDelays in permit issuance can cause construction delays
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 pollutantsnew 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 airPerform Additional Impacts AnalysisSpecial protections for national parks and wilderness areasOpportunity 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 nonattainmentnew 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 OffsetsOpportunity 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 sourcesModifications at minor sourcesMinor modifications at major sourcesApplies in BOTH attainment and nonattainment areasCan 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 leveland brings PTE below the major source threshold by accepting enforceable limits on emissions or operating conditionsMajor Source Threshold50100150200250300350Emissions(tpy)ActualPTEIn 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 anapplicability example
23 Example: Which pollutants are subject to PSD, NA NSR, and minor NSR permitting? 10 tpy PM1080 tpy VOC185 tpy SO2New Kraft Pulp MillArea inattainmentfor PM10 and VOCArea in moderate NAfor SO2Facts:Kraft pulp mills produce the dark-colored wood pulp used in the manufacture of a variety of paper productsThe 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 isSince kraft pulp mills are one of the 28 listed source categories, the major source threshold is 100 tpy, not 250 tpyDetermine if the source is major based on the thresholdIn 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 tpyVOC=80 tpyPM10=10 tpyArea is in:NA for SO2Attainment for VOC and PM10Note 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 PSDThe 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 tpyVOC=80 tpyPM10=10 tpyArea is in:NA for SO2Attainment for VOC and PM10
26 Example solution (Continued) Evaluate for NA NSRDetermine what the applicable threshold is:Major source threshold for moderate NA is 100 tpy.Determine if the source is major based on the thresholdPTE 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 NSRPTE 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 tpyVOC=80 tpyPM10=10 tpyArea is in:NA for SO2Attainment 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 qualitywhile allowing economic growth.
29 Appendix B PSD source categories with 100 tpy major source thresholds 1. Coal cleaning plants (with thermal dryers)15. Coke oven batteries2. Kraft pulp mills16. Sulfur recovery plants3. Portland cement plants17. Carbon black plants (furnace process)4. Primary zinc smelters18. Primary lead smelters5. Iron and steel mills19. Fuel conversion plants6. Primary aluminum ore reduction plants20. Sintering plants7. Primary copper smelters21. Secondary metal production plants8. Municipal incinerators capable of charging more than 250 tons of refuse per day22. Chemical process plants9. Hydrofluoric acid plants23. Petroleum storage and transfer units with a total storage capacity exceeding 300,000 barrels10. Sulfuric acid plants24. Taconite ore processing plants11. Nitric acid plants25. Glass fiber processing plants12. Petroleum refineries26. Charcoal production plants13. Lime plants27. Fossil fuel-fired steam electric plants of more than 250 million British thermal units (BTU) per hour heat input14. Phosphate rock processing plants28. 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 AreasPollutantNonattainment ClassificationMajor Source ThresholdOffset RatioOzoneMarginal (≥ < ppm)100 tpy of VOC or NOx1.1 to 1Moderate (≥ < ppm)1.15 to 1Serious (≥ < ppm)50 tpy of VOC or NOx1.2 to 1Severe (≥ < ppm)25 tpy of VOC or NOx1.3 to 1Extreme (= ppm and up)10 tpy of VOC or NOx1.5 to 1Particulate Matter (10µm)Moderate100 tpy-Serious70 tpyCarbon MonoxideModerate (9.1 – 16.4 ppm)Serious (16.5 and up ppm)50 tpySulfur Dioxide, Nitrogen Oxides and LeadNo nonattainment classifications exist1 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 VTitle 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)PollutantSER (tpy)Carbon Monoxide100Hydrogen sulfide(H2S)10Nitrogen Oxide40Total reduced sulfur (including H2S)Sulfur DioxideReduced sulfur compounds (includes H2S)Particulate Matter25 PM, 15 (PM10)Municipal waste combustor organics3.5 x 10-6Ozone40 of VOCsMunicipal waster combustor metals15Lead0.6Municipal waste combustor acid gasesFluorides3Municipal solid waste landfills emissions50Sulfuric acid mist7