New Source Review Permits

A New Source Review (NSR) permit identifies the emissions that must be regulated, establishes emission standards to be met, specifies specific test or monitoring methods to determine regulatory compliance, and indicates reporting and record keeping requirements.

Basic Elements

While each NSR permit is unique to a facility, it must always contain certain basic elements:

• A Specification of the Legal Authority to issue the permit
  • Basis
    • Regulation (SIP, NSPS, NESHAP)
    • new source review, (i.e., BACT or LAER requirements),
  • Conditional Provisions
  • Effective and Expiration Dates
• Technical Specifications - identify emissions units and corresponding limits
  • brief description of the source or type of equipment
    • size or capacity
    • model number or serial number
    • source's identification of the unit.
  • Identification of Emission Units
    • Usually 2 means of expressing Emission Limits
      • Emissions Cap (lb/hour, etc.)
      • Continous Emissions Limit (lb/MMBTU, etc.) to ensure compliance at any operating capacity

• Emissions Compliance Demonstration
  • When , what and how Emission ComplianceTests should be performed
    • Test Conditions
    • Testing Frequency
    • Responsibility for performing the test
    • Source construction modified to accommodate testing
    • Procedures for establishing exact testing protocol
    • Notification of Test Dates to accommodate Regulatory Personnel
  • Where continuous quantification of emissions are not possible
    • Mass emissions
    • Opacity correlations
    • Pressure drop  (e.g., scrubber venturi throat)
    • Raw material input/mass emissions output ratios
    • Engineering correlations associated with specific work practices.
• Definition of Excess Emissions
  • Prevents unit malfunctions from becoming the standard operating condition
    • precisely define excess emissions
    • outline reporting requirements
    • specify actions the source must take
    • indicate time limits for correction by the source
  • Permit conditions that define Excess Emissions
    • Start Up
    • Shut Down
    • Malfunctions and Breakdowns
      • fabric filter bag leaks or breaks
      • baghouse seal ruptures
      • fires in electrostatic precipitators due to excessive build up of oils or other flammable materials
      • failure to monitor and replace spent activated carbon beds in carbon absorption units.
• Administrative Procedures
  • recordkeeping and reporting requirements
    • continuous monitoring data
    • excess emission reports
    • malfunctions
    • surrogate compliance data
    • notification requirements for performance tests
    • commencing or delay of construction
    • entry and inspection procedures
    • Requirement to obtain a permit to operate
    • Specification of procedures to revoke, suspend, or modify the permit
• Other Specific Conditions which do not fit in the above elements
  • the permanent shutdown of (or reduced emissions rates for) other emissions units to create offsets or netting credits
  • post-construction monitoring
  • continued Statewide compliance
  • a water truck to be dedicated solely to a haul road
  • require a copy of the effective permit to be on-site at all times
  • 10 minute warmup for an incinerator
  • requiring that replacement fabric filters and baghouse seals be kept available at all times
  • Any source-specific condition which needs to be included in the permit to ensure compliance