New Source Review Issues: New Unit Emissions Tracking and PM-2.5 NSR Final Rule Requirements

摘要

This article addresses two topics dealing with new source review (NSR): 1. A more detailed discussion of the gray areas regarding project emissions tracking and reporting; and 2. A discussion of the requirements imposed by the May 16, 2008 final rule on implementing the NSR program for PM-2.5 (particulate matter with an aerodynamic diameter ≤ 2.5 microns). Among other things, EPA's December 31, 2002 rulemaking (colloquially referred to as the Reform Rule) established two types of "emission unit:" 1) new emission units (those that are or will be newly constructed and that have existed for less than two years from the date the unit first began operating), and 2) existing units (all emission units that are not new). Under the Reform Rule, new emission units are subject to a different calculation (post-project emissions are the unit's potential to emit [PTE] and pre-project emissions are either zero-for the initial permitting of the unit-or the pre-project PTE of the unit-for all other permitting).