The
Basics
of
the
"
New
Source
Review"
Program
NTAA
4th
Annual
Conference
Oct.
3­
6,
2005
Mohegan
Sun
Casino
Racqueline
Shelton
and
Raj
Rao
OAQPS,
USEPA
2
How
should
you
benefit
from
this
discussion?


Gain
a
better
understanding
of
the
New
Source
Review
(
NSR)
program

Enhance
your
ability
to
comment
effectively
on
the
upcoming
proposed
NSR
rules
for
Indian
Country
3
What
is
a
National
Ambient
Air
Quality
Standard
(
NAAQS)?


A
NAAQS
is
the
maximum
level
of
an
air
pollutant
that
is
considered
healthy

NAAQS
have
been
set
for:
Nitrogen
dioxide
(
NO2)

Particles
(
dust/
soot)
Lead
Sulfur
dioxide
(
SO2)
Carbon
Monoxide
(
CO)

Ozone
(
smog)
4
What
are
attainment
and
nonattainment
areas?

For
each
of
these
pollutants,

every
area
of
the
U.
S.
is
designated
as
one
of
the
following:

 
Attainment
(
air
quality
better
than
NAAQS);

 
Nonattainment
(
air
quality
worse
than
NAAQS);
or
 
Unclassifiable
(
no
data
on
air
quality;
treated
as
attainment)
Attainment
Non
Attainment
NAAQS
Air
Pollution
Concentration
5
What
is
the
purpose
of
the
NSR
program?


Important
tool
to
enable
nonattainment
areas
to
reach
attainment

Preserve/
protect
clean
air
in
national
parks,

wilderness
areas,
and
other
attainment
areas

To
manage
economic
growth
in
a
controlled
manner
6
What
are
the
components
of
the
NSR
program?
New
Source
Review
(
NSR)
Program
Major
source
NSR
in
attainment
areas
(
PSD)
Major
source
NSR
in
nonattainment
areas
(
NA
NSR)
Minor
source
NSR
in
all
areas
7
What
does
the
NSR
program
require?


New
or
modified
sources
get
permits
prior
to
construction

Sources
install
pollution
control
equipment

Sources/
agencies
make
sure
air
quality
impacts
from
the
source
will
be
acceptable
8
What
are
the
benefits
of
the
NSR
program?


The
NSR
program
is
a
key
tool
for
attaining
and
maintaining
the
NAAQS

Requires
technology­
forcing
control
equipment

Protects
national
parks
and
wilderness
areas
9
What
are
the
areas
of
concern
in
the
NSR
program?


Regulations/
policies
are
complex

Applicability
and
pollution
control
equipment
 
areas
of
controversy

Delays
in
permit
issuance
can
cause
construction
delays
10
To
recap
...


NSR
requires
new
or
modified
sources
to
get
a
permit
before
construction
to
limit
emissions

There
are
3
parts
of
the
NSR
program
­
applicability
depends
on
source
size
and
attainment
status
of
area

NSR
has
environmental
benefits
and
is
an
important
tool
to
attain
NAAQS
11
Prevention
of
Significant
Deterioration
(
PSD)


Applies
only
to
pollutants
for
which
the
area
is
designated
attainment

Applies
to
new
major
sources
and
major
modifications
at
existing
major
sources
12
What
is
a
PSD
major
source?


Emissions
of
any
one
air
pollutant
greater
than:

 
100
tons
per
year
(
TPY)
for
28
listed
source
types
 
250
TPY
for
all
other
sources

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
effect
of
controls,
if
enforceable

At
a
new
PSD
major
source,
requirements
apply
to
all
attainment
pollutants
with
significant
emissions,
even
if
not
a
major
source
for
that
pollutant
e.
g.:

 
SO
2
,
VOC
or
NOx:
40
TPY
 
PM10:
15
TPY
13
More
on
PSD
...


Main
requirements:

 
Best
Available
Control
Technology
(
BACT)

 
Air
Quality
Analysis
to
preserve
existing
clean
air
 
Special
protections
for
national
parks
and
wilderness
areas

Currently
being
implemented
by
EPA
Regions
in
Indian
Country
 
40
CFR
52.21
14
Nonattainment
major
NSR
(
NA
NSR)


Applies
only
to
pollutants
for
which
the
area
is
designated
nonattainment

Applies
to
new
major
sources
and
major
modifications
at
existing
major
sources

Main
requirements:

 
Lowest
Achievable
Emission
Rate
(
LAER)

 
Offsets
 
emission
reductions
to
offset
proposed
emissions

No
NA
NSR
rule
currently
applies
in
Indian
Country
15
How
is
NA
NSR
applicability
different
from
PSD?


Major
source
threshold
is
100
TPY
for
all
types
of
sources
(
or
lower
in
some
NA
areas)


At
a
new
major
source,

 
NA
NSR
applies
only
to
the
NA
pollutants
with
PTE
above
major
threshold
 
This
is
unlike
PSD,
which
applies
to
all
attainment
pollutants
with
significant
emissions
16
Finally,
let's
talk
about
minor
NSR

Applies
to:

 
New
minor
sources;

 
Modifications
at
minor
sources;
and
 
Minor
modifications
at
major
sources

Applies
in
attainment
and
nonattainment
areas

Can
be
used
to
create
"
synthetic
minor"
sources
 
allows
sources
to
avoid
major
source
permitting
requirements
like
NSR
and
Title
V

No
minor
NSR
rule
currently
applies
in
Indian
Country
17
What
is
a
synthetic
minor
source?

A
source
 


with
PTE
greater
than
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
0
50
100
150
200
250
300
350
Emissions
(
TPY)
Actual
PTE
Major
source
threshold
18
Let's
try
an
applicability
example
 


New
kraft
pulp
mill
(
one
of
the
28
listed
source
types
under
PSD)


Potential
to
emit:

 
185
TPY
SO
2
 
80
TPY
VOC
(
ozone)

 
10
TPY
PM10

Area
is
attainment
for
ozone
&
PM10

Area
is
nonattainment
for
SO2

Which
pollutants
are
subject
to
PSD,
NA
NSR,

and/
or
minor
NSR
permitting?
19
Example
Solution
 
PSD

Kraft
pulp
mills
are
one
of
the
28
listed
source
types
 
major
source
threshold
is
100
TPY

SO2
emissions
=
185
TPY
(>
100
TPY)
 
major
source
for
PSD

PSD
applies
to
all
attainment
pollutants
with
 

significant
emissions
 
VOC
is
subject
to
PSD
=
80
TPY
( 
40
TPY)
20
Example
Solution
 

NA
NSR
and
minor
NSR

NA
NSR:
SO
2
is
subject
to
NA
NSR
because
 

 
SO
2
is
a
nonattainment
pollutant
 
The
source
is
major
for
SO
2
=
185
TPY
( 
100
TPY)


Minor
NSR:
PM10
=
10
TPY
(<
15
TPY)
is
subject
to
minor
NSR
because
it
is
not
subject
to
PSD
or
NA
NSR
21
In
closing
...


NSR
is
important
because
it
protects
air
quality
while
allowing
economic
growth

EPA
is
proposing
rules
to
fill
NSR
gaps
in
Indian
Country
