Interim Report of the Committee on Changes in New Source Review Programs for Stationary Sources of Air Pollutants (2005) / Chapter Skim
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The operator must also show that the construction or modification will not result in significant deterioration of air quality in areas that meet the National Ambient Air Quality Standards (NAAQS) 1,2 or interfere with 1The NAAQS specify the maximum allowable concentrations of criteria pollutants in ambient air that are protective of public health and welfare.
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Regulatory revisions were also made in October 2003 concerning the extent of equipment replacements or other modifications for which an NSR permit would not be required, even if pollutant emissions increased significantly, so long as the source did not exceed its maximum level of allowable emissions.4 EPA and other supporters of the revisions say the changes will provide greater flexibility in operating the facilities, increase energy efficiency, and help to modernize American industry, all without damaging the environment. Opponents say that the EPA revisions will slow progress in cleaning the nation's air, thus damaging human health, and that the NSR changes are not necessary to provide operating flexibility to industry.
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In addition, Congress did not ask the committee to investigate any effects of the NSR changes other than on human health (such as changes in atmospheric visibility, climate, or ecological consequences of pollutant deposition)
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. A large and growing body of published epidemiologic and toxicologic research establishes associations between exposure to the criteria pollutants and various health effects, including increased occurrence of cardiopulmonary disease, cardiopulmonary and cancer mortality, poor birth outcomes (low birth weight and small for gestation age)
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From page 5... ...
Such sources are typically located on the periphery of urban areas and near convenient transport facilities or near sources of raw materials. Large stationary sources contribute substantial emissions of nitrogen oxides, sulfur dioxide, particulate matter, and volatile organic compounds nationwide, including areas with concentrations of criteria pollutants associated with an increased risk of adverse health impacts.
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A review of common repair and replacement practices for selected types of process facilities showed that such practices can vary considerably in frequency and cost.7 Likewise, a wide range of pollution prevention and control options can vary in effectiveness and cost for a given emission source, such as a utility boiler. Typically, "pollution control" refers to "end-of-pipe" techniques for removing pollutants from an exhaust gas after the pollutants have been formed in an upstream process.
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Assessing all the factors of interest requires an evaluation of how the firms, industry sectors, or economy will alter investments and operations (including pollution control and pollution prevention) in response to changes in the NSR rules and the resulting changes in efficiency and pollutant emissions.
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From page 8... ...
-- Adoption by industry and utilities -- Performance histories of selected technologies -- Trends in emissions generated per unit of product produced · Life-cycle material-use impacts, considering economy-wide impacts through the supply chain and product delivery use, reuse, and disposal -- Number of products introduced into commerce with reduced hazardous properties · Substitution of materials with less polluting substances Energy · Innovation, implementation, and improvement in use of new efficiency technologies that enable energy efficiency in electricity gen eration and industrial processes · Energy efficiency of operating units and plants · Industry sector-wide energy use · Life-cycle energy-use impacts, considering economy-wide impacts through the supply chain and product delivery, use, reuse, and disposal Emissions · Trends in emissions for individual units, plants, industries, states, regions, and the nation as a whole · Relationships between emissions and unit and plant operating costs and use · Life-cycle emission impacts Air quality · Ambient concentrations of relevant emitted primary pollut ants and pollutants formed in the atmosphere over various spatial and temporal scales Health effects · Human exposure and dose · Mortality and disease -- Population incidence -- Incidence for particular subpopulations (regional or socioeconomic) -- Risks to highly exposed individuals
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From page 9... ...
Some computer models of the electricity-generating sector appear to be sufficiently detailed and sensitive to allow a first assessment of how changes in NSR rules might affect technology adoption and emission trends. For industry sectors outside the electricity-generating sector, the models in use do not appear to have the capacity to represent alternative technologies in a long-term simulation, and the time and resources available to the committee are not sufficient to support the reformulation or construction of sector models for this purpose.
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It remains to be determined which modeling approaches considered by the committee will have sufficient sensitivity to the NSR rule changes under investigation to be able to estimate their effects accurately. Nonetheless, insights into a firm's behavior will help in assessing how individual facilities might respond to the incentives created by the NSR rule changes.
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From page 11... ...
The committee will then evaluate pathways by which the NSR changes could affect industry decisions and determine the plausibility of the pathways and the likely direction and magnitude of the emissions changes. On the basis of this assessment, the committee will focus on the NSR program changes, industries, and pathways that appear likely to contribute substantially to changes in emissions of specific pollutants, pollution prevention, pollution control, and energy efficiency.
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From page 12... ...
Data are sparse, the number of possible scenarios is large, and uncertainties are numerous. However, the committee concludes that this enumerative approach will help to uncover aspects of the NSR changes and the pathways that may influence the effects that the committee has been asked to study.
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