### Non-Attainment New Source Review (NA- NSR) Requirements US Environmental Protection Agency Office of Air Quality Planning and Standards RTP, NC

### What is the purpose of this NA- NSR discussion?  To gain better understanding of the NANSR:

 Requirements  Definitions & Key Terms

### Details about NA- NSR Requirements

### What are the major NA- NSR program requirements?  LAER (Lowest Achievable Emission Rate)  Offsets at prescribed ratios  Alternative sites analysis  Statewide facility compliance  Public Involvement

### What is the Lowest Achievable Emission Rate (LAER)?  Most stringent emission limitation for such category or source:

 Continued in the implementation plan or  Achieved in practice  Does not consider economic, energy of other environmental factors  Cannot be less stringent than any NSPS

### What is the Lowest Achievable Emission Rate (LAER)? (continued)  Generally expressed as:  Numerical emissions limit (lb/MMBtu) or  Emissions rate (lb/hr)  Emissions rate could result from one or a combination of:

 Changes in raw materials processed  Process modifications  Add -on controls

### What other things can be considered for establishing a LAER limit?

 Technology transfers from other:  Gas stream controls  Classes or categories producing similar gas streams  Process controls and modifications  That are similar to the source category in question

### Where can you find information about previous LAER limits?  Implementation plan limits for particular class/category of sources or the sources themselves  Preconstruction/operating permits issued in other nonattainment areas  RACT/BACT/LAER Clearinghouse

### What is the process for demonstrating that a certain LAER limit is unachievable?
 Source noncompliance with an implementation plan limit doesn’t automatically demonstrate limit is unachievable 1. Determine specific reasons for noncompliance 2. Assess ability of the source to comply

### What are emissions “offsets”?  Emissions reductions from existing sources to stabilize emissions
 Sources must obtain offsets as a condition for permit approval
 Developed in accordance with applicable State or local NA rules.

### What is the purpose of obtaining offsets?  Allow industrial growth while moving area towards attainment of NAAQS  Demonstration that area will attain the NAAQS not needed  Provide positive air quality benefit

### What are the factors considered for obtaining offsets?  Pollutants requiring offsets & amount offset required  Location of offsets relative to proposed source  Allowable sources for offsets  “Baseline” for calculating emissions reduction credits  Enforceability of proposed offsets

### Which pollutants require offsets and what are they? Nonattainment Areas Pollutant Nonattainment Classification Offset Ratio Ozone Marginal (≥ 0.085 < 0.092 ppm) 1.1 to 1 Moderate (≥ 0.092 < 0.107 ppm) 1.15 to 1

Serious (≥ 0.107 < 0.120 ppm) 1.2 to 1 Severe (≥ 0.120 < 0.187 ppm) 1.3 to 1 Extreme (= 0.187 ppm and up) 1.5 to 1 Particulate Matter (10μm) Moderate

- Serious

- Carbon Monoxide Moderate (9.1

– 16.4 ppm)

- Serious (16.5 and up ppm)

- Sulfur Dioxide, Nitrogen Oxides and Lead No nonattainment classifications exist

-

### Where should offsets be located relative to the proposed source?  Sources of offsets should impact air quality in the same general area as the proposed source

 Offsets from the same air quality control region acceptable  Showing of air quality improvement at each location affected by the proposed source not needed

### Which offset sources are not allowed?  Emissions reductions:  resulting from other regulatory actions  counted in major modification “netting”  Exception:  Emissions reductions validly “banked” under approved implementation plan

### How is the offset baseline calculated?

 Offsets will be based on emissions reductions below implementation plan limits in effect at time of permit application
 Applicant required to use actual emissions as baseline when no meaningful or applicable implementation plan requirement exists

### What are the enforceability provisions of the proposed offsets?  Acceptable offsets must be:  Creditable  Quantifiable  Federally enforceable  Permanent

### What are the alternative site analysis requirements?

### What are the requirements for statewide facility compliance?  Other major sources in the same State under the control of the owner /operator of proposed source must be:

 In compliance with or  On schedule for compliance with all emission limitations & standards of the CAA  See CAA section173(a)(3)

### What are the public involvement requirements?  Reviewing authority must:  Prepare a draft permit  Provide adequate public notice to affected community and general public  Provide 30-day public comment period on draft permit  Provide opportunity for public hearing on draft permit