Federal Air Quality Compliance Basics: Permits
EPA administers two types of authorizations: New Source Review (NSR) permits and Operating (or Title V) permits. EPA can issue these types of permits directly or a delegated state or local air pollution control agency with an approved State Implementation Plan (SIP) can issue them. Implementation varies by delegated entity because NSR and Title V permits can be issued as separate permits or as a combined permit. Regardless of the issuing agency or format, some form of public involvement is required for all permits. NSR Permits NSR permits are pre-construction authorizations that consist of a set of operating conditions and/or emissions limits established for specific emissions sources. To ensure ongoing compliance, NSR permits may also include monitoring, recordkeeping, and reporting requirements. NSR permit conditions are often separate from, and in addition to, state regulations and federal regulations. There are three classifications of NSR permits: -Prevention of Significant Deterioration (PSD) permits are issued for new major sources or major modifications at existing major sources in attainment areas in order to maintain attainment of the National Ambient Air Quality Standards (NAAQS). PSD permits require that Best Available Control Technology (BACT) be applied to the permitted emissions sources and that an air quality impacts analysis be conducted. -Nonattainment NSR (NNSR) permits are issued for new major sources or major modifications at existing major sources in nonattainment areas in order to allow for economic development and to keep nonattainment areas progressing towards attainment of NAAQS. NNSR permits require that the Lowest Achievable Emission Rate (LAER) be applied to the permitted emissions sources and emissions offsets or credits must be obtained. -Minor NSR permits are issued for new minor sources or modifications at existing minor sources in both attainment and nonattainment areas in order to maintain or achieve attainment of NAAQS. The operating conditions and/or emissions limits found in minor NSR permits are often crafted to specifically avoid or stay below various NSR major source thresholds. Title V Permits Title V permits are post-construction authorizations that function as umbrella permits by rolling in all applicable requirements at a major source including NSR permit conditions, federal regulations, and state regulations. Title V permits are intended to improve compliance by setting a high bar for accountability. Major source thresholds are applied on a per pollutant basis. Below are example major source thresholds. Please note that these tables are not fully comprehensive or representative of all potentially applicable major source thresholds.
