On July 23, 2015 the Arizona Department of Environmental Quality (ADEQ) released proposed revisions to their updated New Source Review (NSR) program. These newly proposed revisions address items cited in the June 29, 2015 Environmental Protection Agency (USEPA) final limited approval/limited disapproval (LA/LD) of the proposed ADEQ NSR program.

Proposed revisions to the ADEQ NSR program definitions include:

  • Revised definition of "allowable emissions" to incorporate applicable emissions limitations (including those with a future compliance date).
  • Revised definition of "proposed final permit".
  • Revised definition of "regulated NSR pollutant" to include VOC and ammonia in PM2.5 nonattainment areas.
  • Revised definition of "PM10 minor baseline date" to be equivalent to the baseline date established for total suspended particulate (TSP).

Proposed revisions to the ADEQ NSR program elements include:

  • Permit applicability criteria change from "uncontrolled potential to emit" to "maximum capacity to emit with elective limits".
  • Eliminated requirements associated with the state HAPs program.
  • Implemented more rigorous public notice requirement for the new registration program.
  • Incorporated monthly averaging periods and daily compliance obligations.
  • Revised the VOC and HAPs content elective limit requirements from a concentration basis to a limitation of the total VOC and/or HAP content.
  • Revised approach on the permitting of insignificant activities.
  • Eliminated the proposed minor NSR public notice exemptions.
  • Removed ability to use minor permit revision procedures under certain project conditions.
  • Extended permit application review timeline.

The ADEQ is conducting a public meeting to review and discuss the proposed revisions on August 26, 2015. Join Trinity's complimentary luncheon on October 15, 2015 for a detailed overview of these changes and the projected impacts to industry.