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Olmsted County Resource Recovery Facility EM April, 1984 24a. continued The Rochester area is designated attainment for the criteria pollutants total suspended particulates (TSP), lead, oxides of nitrogen and ozone. New Source Review requirements in nonattainment areas apply to new sources which emit 100 tons per year (TPY) or more of the pollutant for which the area is nonattainment. Estimated annual emissions of S02 from the proposed facility will exceed 100 TPY. Estimated CO emissions are less than 100 TPY. Facilities must control their emissions of nonattainment pollutants to the lowest achievable emission rate (LAER). In addition, a requirement to offset the new emissions must be met. Offsets are reductions in emissions Of a pollutant at another source in the area. Offsets are measured in tons per year of the nonattainment pollutant. Since the Rochester area is nonattainment for the S02 ambient air quality standards (AAQS) and the proposed facility is a major source of S02, LAER must be demonstrated and emissions offset for S02. These require- ments do not apply for CO emissions since the proposed facility is not a major source of CO. Nonattainment requirements will apply unless the area is redesignated to attainment prior to permitting of the facility. For a new source to be issued an air emissions facility permit, S02 emissions must be offset by reducing the S02 emissions of an existing source in the area by a 1.1 to 1 amount or more. If sufficient offsets are not available, exemption provisions can be utilized which allow such facilities to be con- structed when offsets are not available. A possible scenario for the proposed Campus facility is to offset its smissiom by the retiremnt of the boilers at the Associated Hilk producers, Inc. (AEI) facility. Negotiations are currently underway to provide the AMPI facility with its required steam from the Campus facility. ,Assuming that these negotiations are successful, and Ampi agrees to limit or eliminate use of its boilers, a part of the needed offset may be available. The !'SPCA 1980 emission inventory data indicates that the W1 facility emitted 58 TPY of S02. Taus, the proposed waste to energy Campus facility's estimated annual emissions could be reduced by 58 TPY. However, the offset rule requires that a net reduction in S02 emissions of equal to or greater than 132 TPY be obtained. In addition, the NPCA'a proposed administrative policy regarding the state- wide ceiling on sulfur dioxide emissions requires that S02 emissions of greater than 100 TPY due to the operation of a new source must be offset by an equivalent reduction in sulfur dioxide emissions in acid rain sensitive areas. 3c