New Source Review Reform Activities

The federal and state processes for reviewing and approving equipment and process changes affecting a facility's air emissions have proven to be environmentally beneficial, but very complex and time consuming. As a result, EPA and several states, in response to industry concerns, are trying to improve the process, making it easier and quicker to meet permitting requirements while maintaining the key benefits of the pre-construction review process.

In 1994, the EPA issued guidance to state agencies indicating that certain types of pollution control projects could be excluded from federal major source NSR requirements. This guidance extends a similar policy established in 1992 for electric utilities to all of industry. The policy has no effect on state permitting requirements that are not derived from the CAAA. The exclusion may be used regardless of category. Low-NOx burners, for example, might qualify, but the permitting agency must approve the exclusion.

Under the EPA's new guidance, both add-on emissions control projects and fuel switches to less polluting fuels can be excluded from NSR as "pollution control projects." The eligible projects include:

• The installation of conventional and advanced flue gas desulfurization and sorbent injection for SO2.

• Electrostatic precipitators, baghouses, high-efficiency multi-clones, and scrubbers for particulate or other pollutants.

• Regenerative thermal oxidizers (RTO), catalytic oxidizers, condensers, thermal incinerators, flares, and carbon absorbers for VOC and toxic air pollutants. Projects undertaken to accommodate switching to an inherently less polluting fuel such as natural gas also qualify for exclusion. In some instances, where the emissions unit's capability would otherwise be impaired as a result of the fuel switch, this may involve certain necessary changes to the pollution-generating equipment to maintain the normal operating capability of the unit at the time of the project. Those would also be excluded.

Permitting authorities may also apply the new EPA exclusion to switches to inherently less polluting raw materials and processes and certain other types of "pollution prevention" projects. For instance, many coating users may be making switches to water-based or powder paint application systems as a strategy for meeting RACT or switching to a non-toxic VOC to comply with MACT requirements.

Permitting authorities would be allowed to consider excluding raw material substitutions, process changes, and other pollution prevention strategies where the pollution control aspects of the project are clearly evident and the project will result in substantial emissions reductions per unit of output for one or more pollutants. In judging whether a pollution prevention project can be considered for exclusions as a pollution control project, permitting authorities would also consider as a relevant factor whether a project is being undertaken to bring a source into compliance on Act requirement. For more information on the flexibility afforded to pollution prevention projects, review the documentation on the EPA's website.

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