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Understanding Minor New Source Review Requirements for New Constructions

This document outlines the Minor New Source Review (MNSR) requirements as per Section 4 of Regulation 1125. MNSR applies to new construction and is governed by the "rule of five and five," which pertains to five key pollutants: Volatile Organic Compounds (VOC), Nitrogen Oxides (NOX), Sulfur Oxides (SOX), Particulate Matter (PM2.5), and Hazardous Air Pollutants (HAP). It also explains thresholds for emissions, public notice requirements, and the necessity for emission control technologies that meet Lowest Achievable Emission Rate (LAER) and Best Available Control Technology (BACT) standards.

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Understanding Minor New Source Review Requirements for New Constructions

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  1. Minor New Source Review Alberto Roybal

  2. Minor New Source Review • Section 4 of Regulation 1125, Requirements of Preconstruction Review, New Source Review • MNSR applies to new construction • Section 4, “The rule of five and five”

  3. Affected Sources • Five Pollutants • Volatile Organic Compounds (VOC) • Nitrogen Oxides (NOX ) • Sulfur Oxides (SOX ) • Particulate Matter (PM2.5) • Hazardous Air Pollutants (HAP) • Five Tons per year

  4. Synthetic Minor for < 5 Tons per year • PTE > Major Source Threshold 30 Day Public Notice Federal Enforceable Limits • PTE > 5 Tons per year 15 Day Public Notice State Enforceable Limits • If Synthetic Minor grows > 5 tons per year must add controls to meet Minor New Source Review

  5. Meeting Requirements for MNSR 4.3.1.1 Control that meets LAER, Lowest Achievable Emission Rate, requirements of Section 2 of Regulation 1125 4.3.1.2 Control that meets BACT, Best Available Control Technology, requirements of Section 3 of Regulation 1125

  6. Meeting Requirements for MNSR 4.3.1.3 Control technology approved in advance by the Department 4.3.1.4 Analysis based on technological feasibility and environmental, economic, and energy impacts http://www.epa.gov/ttn/catc/rblc/htm/welcome_eg.html

  7. Examples of Approved in Advance • Emission control technologies approved by the Department will be posted on the AQM internet site as technologies are approved by the Department

  8. Additional Considerations • Application Process • Recordkeeping • Help available from DNREC • Engineering & Compliance 302-739-9402, or 302-323-4542 • Small Business Ombudsman 302-739-9909

  9. Summary • Five Pollutants, Five tons per year • Synthetic Minor • Four ways to meet MNSR requirements • Approved in advance options • Application Form, state how to meet MNSR • Work with Engineering & Compliance or with Business Ombudsman

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