On October 7, 2022, the EPA proposed changes to the New Source Review Regulations (NSR) related to how fugitive emissions are treated in physical or operational changes to an industrial facility. Before a facility can begin construction on a major modification, an NSR permit must be granted by local or state governing body. This permit would ensure that the facility's modification would not harm air quality.

What are Fugitive emissions?

Fugitive emissions originate from leaks and irregular releases of gas from pressurized containment systems. Most common fugitive emissions originate from appliances, storage tanks, pipelines, wells, or other types of equipment. Fugitive emissions most commonly originate from industrial facilities. The term “fugitive” is used because these emissions are not taken into account when the design of the equipment is calculated. These emissions are unanticipated and not detached by monitoring or control devices. Fugitive emissions released in 2020 are almost five times those released 70 years ago. Now that we have more data access to health and safety concerns, increased pressure from the public has led the EPA to become more conscious of these emissions.

What is the NSR Permitting program?

The NSR Permitting program was established in 1977 as part of the Clean Air Act Amendments. The NSR program requires industrial facilities to install up-to-date pollution control equipment. The program aims to protect the environment and public health by ensuring that facility operations do not worsen the air quality in a specific area. The EPA sets National Ambient Air Quality Standards (NAAQS) for six pollutants. They are as follows:

• Ozone
• Carbon Monoxide
• Particulate Matter
• Sulfur Dioxide
• Lead
• Nitrogen Oxide

What will Change?

Besides the EPA requiring an NSR permit for facilities applying for a modification, they will look at the 2008 Fugitive Emissions rule to assess the effectiveness and amended portions of the NSR regulations. The EPA proposes to fully repeal the 2008 rule and create a new NSR program to preserve and improve air quality. Facilities that will be required to account for fugitive emissions going forward, are but are not limited to:

• Petroleum refineries
• Fossil fuel-fired steam electric plants
• Portland cement plants

The proposed rule will require that all fugitive emissions from existing sources be counted towards the total emissions count.

Galli Engineering can help your project get the permits it needs despite the ever-changing environmental laws and regulations. Our team of professionals has worked with a wide variety of clients. If you are looking to start a new project and need the proper environmental permits to operate, give us a call at 631-271-9292 or email jstrashun@gallieng.com with what you want your project to be.