New Source Review (NSR) Program Basics by djz44927


									             New Source Review
              Program Basics
    Racqueline Shelton, Raj Rao,
Jessica Montanez, & Wendy Namisnik

     U.S. Environmental Protection Agency
  Office of Air Quality Planning and Standards
                     RTP, NC
         What should you gain from
        this discussion about NSR?
• A better understanding of the New
  Source Review (NSR) program, including
  areas of concern
  key terms, definitions, and concepts
  permitting considerations

First, let’s talk about why
NSR is important

What is the purpose of the NSR program?

  To ensure environmental
  protection while allowing
      economic growth!

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)                          Nitrogen dioxide (NO2)
    Carbon Monoxide (CO)                  Sulfur dioxide (SO2)
    Particulate Matter (dust/soot)        Lead

•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

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

What are the requirements of the NSR program?

• New or modified sources get permits prior
  to construction

• Sources install state-of-the-art control

• Sources/agencies make sure air quality
  impacts from the source will be

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

Now let’s talk about
 how NSR works

What are the components of the NSR program?

                  New Source Review

   Major NSR           Major NSR
                                      Minor NSR
  in attainment    in nonattainment
                                      in all areas
   areas (PSD)      areas (NA NSR)

     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

                 What defines a major source in
                  an attainment area? (PSD)

• A source with emissions of any one air                              In NSR, a
  pollutant greater than or equal to a threshold of:               threshold is a
    100 tons per year (tpy), if part of the 28 listed source         value that
     categories. See Appendix B for the list of categories.            makes a
    250 tpy, for all other sources not part of the 28 listed         source be
     source categories.                                            subject to the
• Emissions based on “potential to emit” (PTE)                        respective
    PTE = Emissions if operated 24 hours per day, 365
     days per year (8,760 hours/year); PTE includes the            requirements
     effect of add-on emission control technology, if               if the source
     enforceable.                                                  emissions are
        Enforceable means that the source must be able to           at or above
         show to EPA continual compliance with the limitation or      this value.

                         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.

                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

 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
  new major sources and major
   modifications at existing major sources

 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.

             NA NSR permits

• Main requirements:
  Require installation of Lowest Achievable
   Emission Rate (LAER)
  Emission Offsets
  Opportunity for Public Involvement

              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
     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

   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)

      What is a synthetic minor source?
A source –
• with PTE greater than or
  equal to the major source
  threshold, but has actual                      300
                                                                                   Major Source
  emissions below that                           250                               Threshold
  level                                          200                            Actual
                                                 150                            PTE
• and brings PTE below the                       100
  major source threshold by                        50
  accepting enforceable
  limits on emissions or
  operating conditions                                     Emissions
  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
     Let’s try an
applicability example

 Example: Which pollutants are subject to PSD,
     NA NSR, and minor NSR permitting?
                                 Area in
             80 tpy
                               moderate NA           Facts:
      10 tpy VOC 185 tpy SO2     for SO2
      PM10                                   •Kraft pulp mills
                                             produce the dark-
                                             colored wood pulp
                                             used in the
   Area in                                   manufacture of a
 attainment                                  variety of paper
for PM10 and                                 products
                                             •The tons per year
                                             (tpy) in the plume
                                             are the mill’s
                                             potential to emit
                                             these pollutants

New Kraft Pulp Mill

                       Example solution
                1. Evaluate for PSD
                   •    Determine what the applicable threshold is
Mill’s PTE:             Since kraft pulp mills are one of the 28
                         listed source categories, the major source
• SO2=185 tpy
                         threshold is 100 tpy, not 250 tpy
• VOC=80 tpy
• PM10=10 tpy      •    Determine if the source is major based on
Area is in:             the threshold
• NA for SO2            In this case, the SO2 emissions are 185
                         tpy, which is greater than 100 tpy. This
• Attainment for         makes the mill a major source for PSD.
  VOC and PM10
                         Now we have to review all attainment
                         pollutants for PSD applicability.

        Example solution (Continued)

                   •   Review the two attainment pollutants based
                       on their SER to see if they fall into PSD
Mill’s PTE:             The mill’s VOC PTE is 80tpy, but VOC is not
• SO2=185 tpy            on the SER list. However, it is a precursor for
• VOC=80 tpy             ozone, and ozone is on the list with a SER of
                         40 tpy. VOC is subject to PSD because
• PM10=10 tpy            PTE is higher than 40 tpy.
Area is in:             PM10 is on the SER list with a SER of 15tpy.
• NA for SO2
                         The mill’s PM10 PTE is 10tpy, which is less
                         than the SER. PM10, not subject to PSD.
• Attainment for
  VOC and PM10

         Example solution (Continued)
                   2. Evaluate for NA NSR
Mill’s PTE:          •   Determine what the applicable threshold
• SO2=185 tpy               Major source threshold for moderate NA
• VOC=80 tpy                 is 100 tpy.
                     •   Determine if the source is major based on
• PM10=10 tpy            the threshold
Area is in:                 PTE for SO2, the NA pollutant, is 185 tpy,
                             which is greater than the 100 tpy threshold.
• NA for SO2                 Mill’s SO2 emissions are subject to NA
• Attainment for
  VOC and PM10
                   3. 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.
• 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.

                                Appendix A
             National Ambient Air Quality Standards (NAAQS) Values

   Pollutants         Primary Standards      Averaging Times          Secondary
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     Same as Primary
Particulate Matter        150 ug/m3               24-hour                -------
Particulate Matter         15 µg/m3          Annual (Arithmetic     Same as Primary
      (PM2.5)                                     Mean)
                           35 ug/m3               24-hour                -------
     Ozone                 0.08 ppm               8-hour            Same as Primary
  Sulfur Oxides            0.03 ppm          Annual (Arithmetic          -------
                           0.14 ppm               24-hour                -------
                             -------              3-hour          0.5 ppm (1300 ug/m3)

                                        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   22. Chemical process plants
    more than 250 tons of refuse per day
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

                                         Appendix C
                           Major source thresholds for NA areas
                                       Nonattainment Areas
                                                                         Major Source          Offset
        Pollutant             Nonattainment Classification
                                                                          Threshold            Ratio
          Ozone                Marginal (≥ 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                    Moderate                          100 tpy              -
                                            Serious                          70 tpy               -
     Carbon Monoxide              Moderate (9.1 – 16.4 ppm)                  100 tpy              -
                                  Serious (16.5 and up ppm)                  50 tpy               -
Sulfur Dioxide, Nitrogen     No nonattainment classifications exist          100 tpy              -
    Oxides and Lead
 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.

                       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.
                                         Appendix E
                      Significant Emission Rates (SERs)

Significant Emission Rate – a rate of emissions that would
equal or exceed any of the following rates:
         Pollutant           SER (tpy)                     Pollutant                    SER (tpy)
 Carbon Monoxide       100                Hydrogen sulfide(H2S)                       10
 Nitrogen Oxide        40                 Total reduced sulfur (including H2S)        10
 Sulfur Dioxide        40                 Reduced sulfur compounds (includes H2S)     10
 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        40
 Fluorides             3                  Municipal solid waste landfills emissions   50
 Sulfuric acid mist    7

  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)


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