Tribal Minor New Source Review Registrations

Tribal Minor New Source Review Registrations

Kaushal Gupta, Environmental Engineer, Air Permits SectionUSEPA Region 5 Air & Radiation Division

Tribal Minor NSR & Title V Permit Review TrainingJune 11, 2013

What We’ll Cover

• Who must register or apply for a permit, and when.

• What the registration form requires.• What EPA Region 5 is doing about

registration.

U.S. Environmental Protection Agency2

Benefits of Registration

• Why have a registration program?– Helps EPA get an early picture of the air quality situation in Indian Country

before permits are required.– Helps tribes and sources get acquainted with the rule before permits are

required.– Helps develop a working relationship among all parties before permits are

required.– Gives EPA advance warning of potential jurisdictional issues.


Who has to register?

• Only true minor sources must register.• True minor sources are those whose

Potential to Emit (PTE) is below the major source threshold.


U.S. Environmental Protection Agency

When True Minors Must Register and Apply for Permits

• New true minors– New true minor sources will not need a permit and will only need to register

within the first 36 months of the program (ending September 1, 2014).– After the first 36 months of the program or 6 months after a general permit

for a source category is published, new sources will need a permit if the source’s emissions exceed the minor source thresholds.

5

When True Minors Must Register and Apply for Permits

• Existing true minors– Existing true minor sources will only need to register within the first 18

months of the program (by March 1, 2013).– After the first 36 months of the program or 6 months after a general permit

for a source category is published, existing sources will need a permit only for a modification that exceeds the minor source thresholds.


What about other sources?

• Major Sources: those whose PTE are equal to or greater than the major source threshold, and who cannot (or do not wish to) reduce their actual emissions to below the threshold

• Synthetic Minor Sources: those whose PTE are equal to or greater than the major source threshold, but who can (and are willing to) reduce their actual emissions to below the threshold.



“Major”

“Synthetic Minor”

“True Minor”

When major/synthetic minor sources must register and apply for permits

• Existing major and synthetic minor sources should have their permits already. They do not need to register.

• New major and synthetic minor sources must apply for and receive permits before construction. They do not need to register.


Registration Form

• General Source Information– Company Name– Source Name– Type of Operation: the generally accepted name for the operation (i.e.,

asphalt plant, gas station, dry cleaner, sand & gravel mining, oil and gas well site, tank battery, etc.).

– Portable Source: If the source operates in more than one location. E.g. asphalt batch plants and concrete batch plants.

– Temporary Source: If operations are expected to stop within the next 2 years.

– NAICS Code: North American Industry Classification System.


Available at http://www.epa.gov/air/tribal/tribalnsr.html

Registration Form

• General Source Information, cont’d– SIC Code: Standard Industrial Classification Code. Although the new North

American Industry Classification System (NAICS) has replaced the SIC codes, much of the Clean Air Act permitting processes continue to use SIC Codes.

– Physical Address– Reservation– County– Latitude & Longitude– Section-Township-Range


Registration Form

• Contact Information– Owners– Operator– Source Contact: local contact authorized to receive

requests for data and information. – Compliance Contact: local contact responsible for the

source’s compliance with this rule.


Registration Form

• Attachments– Narrative description of the operations– Identification and description of all emission units and air pollution

generating activities (with the exception of the exempt emissions units and activities listed in §49.153(c)

– Identification and description of any existing air pollution control equipment and compliance monitoring devices or activities

– Type and amount of each fuel used– Type raw materials used– Production Rates– Operating Schedules


Registration Form

• Attachments, cont’d– Any existing limitations on source operations affecting emissions or any

work practice standards, where applicable, for all regulated NSR pollutants at the source.

– Total allowable (potential to emit if there are no legally and practically enforceable restrictions) emissions, including all calculations for the estimates.

– Estimates of the total actual emissions, including calculations.– Other information that may be pertinent to emissions


Registration Form

• Table of estimated emissions– Total actual and total allowable emissions estimates for particulate matter,

PM10, PM2.5, sulfur oxides, nitrogen oxides, carbon monoxide, volatile organic compound, lead and lead compounds, fluorides (gaseous and particulate), sulfuric acid mist, hydrogen sulfide, total reduced sulfur, and reduced sulfur compounds.

– Include fugitive emissions if source belongs to one of the categories listed under Clean Air Act Section 302(j)

• Fugitive emissions: Air pollutants released to the air other than those from stacks or vents, including small releases from leaking plant equipment such as valves, pump seals, flanges, or sampling connections, and large open area releases such as from landfills, waste ponds, or unpaved roads.


Emission Calculators

• EPA has made spreadsheet-based calculators available at http://www.epa.gov/air/tribal/tribalnsrcalculators.html

• Calculators are available for some of the common source categories in Indian country:– Gas stations, dry cleaning operations, auto body shops, sawmills, landfill

operations, hot-mix asphalt plants, concrete batch plants, printing operations, rock crushing and stone processing operations, surface coating operations, degreasers/solvents/cleaners, industrial boilers, stationary internal combustion engines

• Output Summary Printout page indicates whether the source needs to register.


Emission Calculators

• Information required– Facility contact information– Attainment status of source’s area– Facility usage (hours of operation, fuel usage, number of units processed,

etc.)– Emission controls and operational restrictions

• Filling in the above information leads to completed Total Emissions and Output Summary Printout pages


AP-42 Emissions Factors

• Compilation of EPA’s emission factor information for over 200 source categories.

• May be useful to sources for which registration calculators are unavailable.

• http://www.epa.gov/ttnchie1/ap42/


Region 5’s Registration Program

• Region 5 began a HQ-funded pilot program to build an inventory of sources in Indian country.

• Region 5 contracted with Inter-Tribal Council of Michigan to develop inventory.

• ITCM developed an inventory of approximately 1,000 sources that were potentially subject to the Tribal Minor NSR Rule.



• Region 5 developed:– Mailing lists based on the inventory– Cover letter for the registration form

• Mailing lists and cover letter were vetted with all of R5’s tribes• In November-December 2012, Region 5 sent the cover letters to

the sources on the mailing lists.• Results so far

– Approx. 70 registrations– Approx. 150 forms returned as undeliverable– Many sources contacted Region 5 or their tribal authorities to get technical

assistance or to confirm that they would not need to register– Some jurisdictional issues have come up



• Region 5’s plans for the data– Upload registrations to EPA’s national database– Resolve incomplete and missing registrations– Share results with tribes– Formulate tribal permitting, outreach, and enforcement strategies


Registration in Other Regions

• Region 8– Thousands of oil & gas sources utilizing a “bulk registration” process

• Region 10– Has its own pre-existing Federal Air Rules for Reservations (FARR)

program• Some other Regions have expressed interest in following R5’s

example


Summary

• Only true minor sources need to complete the registration form; larger sources must apply for permits.

• True minors won’t need to apply for permits until Sept. 2014.• The registration form requires the source to estimate its

potential and actual emissions.• EPA has made easy-to-use emission calculators available for

many types of sources.• EPA Region 5, with help from tribal governments and

organizations, began a source inventory and outreach program that has assisted in registration.


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Tribal Minor New Source Review Registrations

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