PCAQCD Begins Design of Their New Minor NSR Program



PCAQCD has begun the process of designing their own version of the Minor New Source Review (NSR) program which currently exists at the ADEQ and MCAQD.  While no official stakeholder meetings or rule development have started the agency has developed several key concepts for the new program which are different than those under the ADEQ and MCAQD programs.  Some of the key concepts are as noted below.  The agency expects to start stakeholder meetings and rule development in 2017.

  • Retain the current de minimis amount of 1 tpy
  • Establish a three-tiered Minor NSR program
    • BACT required for nonattainment pollutants with allowables above 50% of any major source threshold
    • BACT required for modifications above the significance levels
    • Note:  The proposed Minor NSR BACT analysis has to meet the more rigorous EPA "top-down" methodology
    • Modeling required for attainment pollutants with allowables above 50% of any major source threshold
    • Modeling required for modifications above the significance levels but could implement BACT in lieu of modeling
    • RACT required for any source with allowables under 50% of any major source threshold but could implement modeling in lieu of RACT
  • For Insignificant Activities
    • Potentially create an insignificant activity definition for fired equipment less than 0.5 MMBtu/hr used solely for heating buildings for personal comfort, or producing hot water for personal use
    • Potentially modify the insignificant activity for engines (from < 325 brake hp and < 72 hr/yr, to < 325 brake hp and < 100 hr/yr)
    • Potentially create an insignificant activity definition for spray painting use < 5 gal/hr
  • Fees
    • Increase all permit processing fees
    • Charge fees for review of modeling related documentation (i.e., modeling protocol as well a final report)