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Air toxics source ≠ NSR source.
At facilities with a single primary activity, the entire facility is often designated as the source for both the air toxics and new source review (NSR) programs. At facilities with multiple primary activities, they are often divided quite differently. Why?
When designating an air toxics source, all contiguous sites that are under common control must be included in the source. Thus, a wholly owned sister facility across the road would have to be included in the source. The same holds true when defining NSR sources, but an additional industry grouping factor is added. If all the activities at the combined source are in a single primary industry group (e.g., petroleum refining), then the air toxics and NSR sources will generally be the same. If some of the activities are in a different primary industry group (e.g., chemical manufacturing), then they would generally be split into a separate source for NSR.
And don’t forget—the pollutants and major source thresholds are very different for air toxics versus NSR. For additional compliance morsels, visit our website.
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McCoy and Associates, Inc. makes no representation, warranty, or guarantee in connection with any guidance provided above. McCoy and Associates, Inc. expressly disclaims any liability or responsibility for loss or damage resulting from its use or for the violation of any federal, state, or municipal law or regulation with which such guidance may conflict. Any guidance above is general in nature related to the federal environmental regulations. Persons evaluating specific circumstances dealing with environmental regulations should review state and local laws and regulations, which may be more stringent than federal requirements. In addition, the assistance of a qualified professional should be enlisted to address any site-specific circumstances.
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