Prevention Of Significant Deterioration (PSD)
Construction of any new source, including a greenfield power plant, is subject to New Source Review (NSR). If the source is located in an attainment area, it will also trigger Prevention of Significant Deterioration (PSD) permitting, as required by the Clean Air Act (CAA) for major stationary sources of air pollution in attainment areas. A major source is any stationary source with the potential to emit more than 100 tons of pollutant per year. An attainment area is defined as an area where the air quality is in compliance with the National Ambient Air Quality Standards (NAAQS). The PSD regulations require that new major stationary sources obtain a PSD permit prior to construction to ensure compliance with the applicable NAAQS. To obtain a PSD permit, an applicant must complete several steps:
- perform a Best Achievable Control Technology (BACT) analysis;conduct an ambient air quality analysis;
- perform an additional impacts analysis;
- demonstrate that the project does not adversely impact a Class I area; and
- undergo adequate public participation.
For projects as significant as a greenfield power plant, a specialty consulting firm is contracted to prepare the PSD permit application package. A PSD permit application for a coal-fired power plant typically takes months to prepare and submit. If satisfied the project meets approval criteria, the state regulatory agency will issue a draft permit within six months to a year. In addition, preconstruction monitoring may be required on a case-by-case basis, though most states have a well-established ambient air quality monitoring network.