# Presentation: 012310

## 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***

## 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

## 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!***_

**Notes:**
We’ll talk more about attainment and nonattainment areas in a minute

## 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

- 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
_***Nonattainmen***__**t**_** ****- **air quality is equal to or exceeds the NAAQS
_***Unclassifiable***_** - **no data on air quality; treated as attainment

- How does NSR _*ensure*_ environmental protection?

*** ******Nitrogen dioxide (NO2)***
*** ******Sulfur dioxide (SO2)***
*** ******Lead***

## 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 technology***_
- Sources/agencies make sure _***air quality impacts***_ from the source will be _***acceptable***_

## 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

_***how NSR works***_

## What are the components of the NSR program?

## PSD - NSR program for major sources in attainment areas

- PSD applies to:
_***attainment pollutants***_
_***new major sources***_ and _***major modifications***_ at _***existing major sources***_

***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.***

## 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**__._

**Notes:**
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.

## 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

- NA NSR applies to:
_***Pollutants ***_for which the area is _***designated nonattainment ***_
_***new major sources***_ and _***major modifications***_ at _***existing major sources***_

***If an area is in nonattainment, the goal is to bring the area into attainment; in other words, ***_***improve the existing***_*** air quality.***

## 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.

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

## 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 NSR.***

## 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 emissions below***_ that level
- and brings PTE below the major source threshold by _***accepting enforceable limits***_ on emissions or operating conditions

**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.**

## Let’s try an  
applicability example

_***applicability example***_

## Example: Which pollutants are subject to PSD,   NA NSR, and minor NSR permitting?

**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

## Example solution 

- _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

**Example solution**** **

**Notes:**
Note that the source is a major source for  PSD purposes, even though it has a major emission level only of a nonattainment pollutant.

## 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. _**PM**__**10**__**, 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

## 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.

- _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 SO**__**2**__** 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 PM**__**10**__** 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

**Example solution (Continued)**

## Conclusion

- 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 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)  | Same as Primary  |
| Particulate Matter (PM10)  | 150 ug/m3  | 24-hour | -------  |
| Particulate Matter (PM2.5)  | 15 μg/m3 | Annual (Arithmetic Mean)  | Same as Primary  |
|  | 35 ug/m3  | 24-hour | -------  |
| Ozone | 0.08 ppm  | 8-hour | Same as Primary  |
| Sulfur Oxides | 0.03 ppm  | Annual (Arithmetic Mean)  | -------  |
|  | 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 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 |

## Appendix CMajor source thresholds for NA areas

**1**** There are no classification design value thresholds (i.e., ranges in parenthesis) for PM****10**** as there are for ozone and CO.  All PM****10**** 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.  **

| Nonattainment Areas |  |  |  |
| --- | --- | --- | --- |
| Pollutant | Nonattainment Classification | Major Source Threshold | Offset 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 (10μm) | 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 Oxides and Lead | No nonattainment classifications exist | 100 tpy | - |

## 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](http://www.epa.gov/air/caa/contents.html#titlev)__ of the __[Clean Air Act](http://www.epa.gov/air/caa/contents.html)__ 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)

- 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)

- Appendix ESignificant Emission Rates (SERs)

| 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 |  |  |