5900-246 Synthetic Minor Limit Application

OMB Control No. 2060-0003
Approval expires 04/30/2012
United States Environmental Protection Agency
Program
Address
Phone
Fax
Web address

Reviewing Authority
Program
Address
Phone
Fax
Web address

FEDERAL MINOR NEW SOURCE REVIEW PROGRAM IN INDIAN COUNTRY

Application For Synthetic Minor Limit
(Form SYNMIN)

Please submit information to:

[Reviewing Authority
Address
Phone]

A. GENERAL INFORMATION
Company Name

Source Name
Title

Company Contact or Owner Name
Mailing Address
Email Address
Telephone Number

Facsimile Number

B. ATTACHMENTS
For each criteria air pollutant, hazardous air pollutant and for all emission units and air pollutantgenerating activities to be covered by a limitation, include the following:
Item 1 - The proposed limitation and a description of its effect on current actual, allowable and the potential to emit.
Item 2 - The proposed testing, monitoring, recordkeeping, and reporting requirements to be used to demonstrate and
assure compliance with the proposed limitation.

Item 3 - A description of estimated efficiency of air pollution control equipment under present or anticipated
operating conditions, including documentation of the manufacturer specifications and guarantees.

Item 4 - Estimates of the Post-Change Allowable Emissions that would result from compliance with the proposed
limitation, including all calculations for the estimates.
Item 5 – Estimates of the potential emissions of Greenhouse Gas (GHG) pollutants:

EPA Form No. 5900-246

OMB Control No. 2060-0003
Approval expires 04/30/2012
[Disclaimers] The public reporting and recordkeeping burden for this collection of information is estimated
to average 6 hours per response. Send comments on the Agency’s need for this information, the accuracy
of the provided burden estimates, and any suggested methods for minimizing respondent burden, including
through the use of automated collection techniques to the Director, Collection Strategies Division, U.S.
Environmental Protection Agency (2822T), 1200 Pennsylvania Ave., NW, Washington, D.C. 20460.
Include the OMB control number in any correspondence. Do not send the completed form to this address.

Instructions
Use this form to provide general and summary information about the synthetic minor NSR
source (source or plant) on Tribal lands and to indicate the emissions limitations requested.
Submit this form once, in addition to FORM NEW, for each synthetic minor NSR source on
Tribal lands.

1. Who Can Request Federally-Enforceable Limitations Under the Tribal NSR Authority?
The Tribal NSR Rule applies only to sources located within the exterior boundaries of an Indian
reservation in the United States of America or other lands as specified in 40 CFR part 49, collectively
referred to as “Indian country”. So, to use the authority in the Tribal NSR Rule to create federallyenforceable limitations, a source must be located within Indian country. Land ownership status (for
example, whether the land is owned by a Tribal member or whether the land is owned in fee or in trust)
does not affect how the rule applies.
2. Who Might Want to Request Federally-Enforceable Limitations?
The primary reason for requesting federally-enforceable limitations is to avoid an otherwise applicable
federal Clean Air Act program, rule or requirement. Many federal Clean Air Act programs use a
source’s “potential to emit” (PTE) air pollution to determine which rules or requirements apply. A
source’s PTE is based on the maximum annual operational (production, throughput, etc) rate of the
source taking into consideration the capacity and configuration of the equipment and operations.
Emission or operational limits can also be taken into consideration as maximums if they are federally
enforceable. So, using a synthetic minor NSR permit to establish federally enforceable limitations can
lower a source’s PTE and possibly allow the source to avoid certain federal Clean Air Act
requirements.
Three examples of federal Clean Air Act programs that use PTE to determine whether they apply are
(1) the Prevention of Significant Deterioration (PSD) construction permitting program, (2) the Title V
operating permit program, and (3) the Maximum Achievable Control Technology (MACT) program.
For example, existing sources that are considered “major” for Title V (meaning they have the potential
to emit air pollution at levels defined in that rule as “major”) must apply for a Title V operating permit.
If a source accepts a federally-enforceable limitation through a synthetic minor NSR permit that
reduces their PTE to below the “major” threshold, and the source does not meet any of the other
requirements that would trigger applicability to the part 71 program, then the source no longer needs a
Title V operating permit. When planning for the construction of a new source or expansion of an
existing source, a source can also accept limitations on PTE (using a synthetic minor NSR permit) that
allow the source to avoid PSD. Limitations on PTE can similarly help a source to avoid new MACT
standards that would otherwise apply to the source.

EPA Form No. 5900-246

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OMB Control No. 2060-0003
Approval expires 04/30/2012
3. Section B. ATTACHMENTS
This section lists the information that must be attached to the application form for each requested
limitation. The requested limitation(s) must be described for each affected emissions unit (or pollutantgenerating activity) and pollutant and must be accompanied by the supporting information listed on the
form and described below. Note that applicability of many federal Clean Air Act requirements (such as
Title V, PSD and MACT) is often based on source-wide emission levels of specific pollutants. In that
case, all emissions units at a source and all pollutants regulated by that given rule or regulation must be
addressed by this section of the application form.
Item 1 – The requested limitation and its effect on actual emissions or potential to emit must be
presented in enough detail to document how the limitation will limit the source’s actual or potential
emissions as a legal and practical matter and, if applicable, will allow the source to avoid an otherwise
applicable requirement. The information presented must clearly explain how the limitation affects each
emission unit and each air pollutant from that emission unit. Use the information provided in response
to Item 4 below to explain how the limitation affects emissions before and after the limitation is in
effect.
Item 2 – For each requested limitation, the application must include proposed testing, monitoring,
recordkeeping and reporting that will be used to demonstrate and assure compliance with the
limitation. Testing approaches should incorporate and reference appropriate EPA reference methods
where applicable. Monitoring should describe the emission, control or process parameters that will be
relied on and should address frequency, methods, and quality assurance.

Item 3 – The application must include a description and estimated efficiency of air pollution control
equipment under present or anticipated operating conditions. For control equipment that is not
proposed to be modified to meet the requested limit, simply note that fact; however, for equipment that
is proposed to be modified (e.g. improved efficiency) or newly installed to meet the proposed limit,
address both current and future descriptions and efficiencies. Include manufacturer specifications and
guarantees for each control device.
Items 4 – Any emission estimates submitted to the Reviewing Authority must be verifiable
using currently accepted engineering criteria. The following procedures are generally
acceptable for estimating emissions from air pollution sources:
(i) Source-specific emission tests;
(ii) Mass balance calculations;
(iii) Published, verifiable emission factors that are applicable to the source. (i.e., manufacturer
specifications).

(iv) Other engineering calculations; or
(v) Other procedures to estimate emissions specifically approved by the Reviewing Authority.
Post-Change Allowable Emissions: A source’s allowable emissions for a pollutant is expressed in tpy
and generally is calculated by multiplying the allowed hourly emissions rate in pounds per hour
(lbs/hr) times allowed hours (which is the number of hours in a year) and dividing by 2,000 (which is
the number of pounds in a ton).
Item 5 - New construction projects that have the potential to emit GHG emissions of at least 100,000
tpy CO2e and 100 or 250 tpy on a mass basis, modifications at existing PSD facilities that increase
GHG emissions by at least 75,000 tpy CO2e and minor sources that increase GHG emissions by at least
100,000 tpy CO2e and 100 or 250 tpy on a mass basis are subject to PSD permitting requirements, even
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OMB Control No. 2060-0003
Approval expires 04/30/2012
if they do not significantly increase emissions of any other pollutant. As such, any requested limits to
avoid PSD must take into account greenhouse gases.
Therefore, please include in your permit application estimates of the potential emissions of the
following pollutants. More information about GHG permitting and how to calculate CO2 equivalents
(CO2e), the mass emissions of each individual GHG adjusted for its Global Warming Potential (GWP)
can be found at: http://epa.gov/nsr/ghgdocs/ghgpermittingguidance.pdf
1. Carbon dioxide (CO2)
2. Methane (CH4) and its CO2e
3. Nitrous oxide (N2O) and its CO2e
4. Hydrofluorocarbons (HFCs) and its CO2e
5. Perfluorocarbons (PFCs) and its CO2e
6. Sulfur hexafluoride (SF6) and its CO2e

EPA Form No. 5900-246

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