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EPA- NSR Rule. EPA-Baseline Emissions. Defining Baseline Emissions Source allowed to look back over last 10 years to select any 24-month priod upon which to establish baseline against which emissions increases are measured May select different 24-month period for each regulated NSR pollutant
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EPA-Baseline Emissions • Defining Baseline Emissions • Source allowed to look back over last 10 years to select any 24-month priod upon which to establish baseline against which emissions increases are measured • May select different 24-month period for each regulated NSR pollutant • Non-utility sources are only required to submit a report to the permitting authority if post-change emissions increase by a significant amount and are in excess of the source’s pre-change projection
EPA – NSR Applicability Test • Applicability Test • Allows the use of “actual-to-projected-actual” emissions test to predict emissions 5 years into the future • Expands “demand growth exclusion” to all existing sources
EPA – Clean Unit Exclusion • Clean Unit Exclusion • Provides automatic designation as “Clean Unit” for any unit that has installed BACT or met LAER I the last 10 years • Allows sources to receive “Clean Unit” status if they demonstrate other controls are “comparable to BACT” • Ignores any emission increases from any project at a “Clean Unit” (I.e., no NSR at Clean Units) for 10 years • Any source may qualify as a Clean Unit if controls are comparable to BACT. Owner of source must show that emissions limitation is equal o the average of all emissions limitation determined as BACT within the last five years from the RACT/BACT/LAER database.
EPA-Pollution Control Project (PCP) Exclusion • Pollution Control Project Exclusion • Expands NSR exemption for PCPs (I.e., projects that result from NSR due to decreases in emissions of another pollutant) to all source categories • Eliminates requirement that “primary purpose” of PCP must be to reduce emissions • Lists PCPs presumptively deemed “environmentally beneficial” and allow othrs to demonstrate that they are “environmentally beneficial”
EPA – Plantwide Applicability Limits (PAL) • Plantwide Applicability Limits • Allows facility to take PAL (I.e., source-wide emission cap), under which any changes are exempt from NSR • PAL based on average actual emissios of 24 months over the past 10 years and the potential to meit of new sources added after 24 months • The PAL is 10 years and PAL does not decline • New source allowed to operate under PAL without controls