A Study of Future Projected Actual Emissions and Annual Emissions That Are Reported

摘要

The New Source Review (NSR) reform rules provide an extremely valuable approach for assessing Prevention of Significant Deterioration (PSD) and NonAttainment NSR applicability through the use of baseline actual emissions and future projected actual emissions. Many modifications that used to trigger NSR applicability now are minorNSR permitting projects; however, this minorNSR permitting approach includes a requirement that the projected actual emissions be tracked annually for either a 5year or 10year period. Under the "reasonable possibility" rule there are specific requirements for the manner in which projected emissions must be tracked. This paper will outline the specific requirements that must be followed for performing the postproject emissions tracking. In addition, several case studies will be presented that show how the postproject emission tracking is often an afterthought in the permitting process and the consequences that can result from incorrect or incomplete tracking.