The
background
papers
on
the
candidate
national
program
priorities
are
intended
to
initiate
further
discussion.
When
priorities
are
selected
more
detailed
strategies
with
in­
depth
background
information,
numerical
targets,
schedules,
milestones
and
performance
measures
will
be
developed.
______________________________________________________________________________

December,
2003
Page
1
of
2
Proposed
Priority
Clean
Air
Act/
New
Source
Review/
Prevention
of
Significant
Deterioration
(
NSR/
PSD)

Universe
and
Types
of
Facilities
This
current
priority
includes
major
sources
of
air
pollution,
including
electric
utilities,
refineries,
pulp
and
paper
mills,
wood
product
manufacturing,
steel
mills,
chemical
manufacturing
plants,
and
other
large
industrial
facilities.
EPA
believes
that
the
number
of
facilities
that
should
have
obtained
NSR
and
PSD
permits
is
over
1,000.
Many
thousands
more
have
obtained
permits
that
limit
their
emissions
in
order
to
be
classified
as
"
synthetic
minors,"
but
if
they
are
not
meeting
their
permit
conditions
they
would
have
triggered
NSR
or
PSD
review.
A
smaller
but
potentially
substantial
number
of
additional
sources
have
bypassed
the
permitting
process
entirely
(
either
through
ignorance
or
deliberate
deception).
Investigation
of
these
sources,
involving
a
thorough
review
of
internal
company
documents,
often
reveals
that
the
sources
are,
in
fact,
subject
to
NSR
and
PSD
requirements.

Geographic
Range
PSD
programs
apply
throughout
the
Nation.
NSR
programs
apply
in
all
areas
that
are
not
in
attainment
of
the
National
Ambient
Air
Quality
Standards
(
NAAQS),
or
that
have
plans
for
maintenance
of
those
standards
after
being
reclassified
from
nonattainment
status.

Environmental
Risks
The
PSD
and
NSR
programs
directly
control
emissions
of
criteria
air
pollutants,
and
the
PSD
program
requires
sources
to
address
a
number
of
toxic
air
pollutants.
Criteria
air
pollutants,
which
include
ozone,
carbon
monoxide,
nitrogen
dioxide,
sulfur
dioxide,
particulate
matter
and
lead,
have
been
identified
by
EPA
as
having
chronic
and
acute
effects
on
public
health
and
welfare.

Noncompliance
Information
NSR
requirements
in
the
Clean
Air
Act
(
CAA)
are
intended
to
ensure
that
the
construction
of
new
sources
or
modification
of
existing
sources
does
not
jeopardize
the
attainment
of
National
Ambient
Air
Quality
Standards
(
NAAQS)
in
nonattainment
areas.
PSD
requirements
ensure
that
areas
with
relatively
clean
air
are
not
significantly
degraded
by
the
influx
of
new
air
pollution
sources.
Both
PSD
and
NSR
requirements
can
add
substantial
costs
to
the
construction
or
operation
of
new
sources,
thereby
creating
an
incentive
for
sources
to
avoid
permit
review
by
state
or
federal
authorities.
In
addition,
some
sources
may
have
unintentionally
violated
these
requirements
due
to
misunderstandings
of
the
applicable
law.
Avoidance
of
the
required
review
results
in
inadequate
control
of
emissions,
thereby
contributing
thousands
of
unaccounted
tons
of
pollution
each
year,
particularly
of
Nitrogen
Oxides
(
NOx),
Volatile
Organic
Compounds
(
VOC),
The
background
papers
on
the
candidate
national
program
priorities
are
intended
to
initiate
further
discussion.
When
priorities
are
selected
more
detailed
strategies
with
in­
depth
background
information,
numerical
targets,
schedules,
milestones
and
performance
measures
will
be
developed.
______________________________________________________________________________

December,
2003
Page
2
of
2
Sulfur
Dioxide
(
S02)
and
Particulate
Matter
(
PM).
These
emissions
worsen
problems
in
nonattainment
areas
and
threaten
to
drive
attainment
areas
into
non­
attainment.
A
review
of
permitting
history
over
the
past
few
years
indicates
that
states
are
issuing
very
few
PSD
or
NSR
approvals,
despite
the
fact
that
trade
association
journals
and
economic
indicators
show
that
industrial
facilities
have
significantly
increased
their
production
and
modified
their
processes
to
a
degree
that
should
have
triggered
many
PSD
and
NSR
actions.
