Nevada Mercury Control Program (NMCP) - Designations and Issued Permits
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"Designations" references the De Minimis designations and "Issued Permits" references the Phase-1 and Phase-2 Mercury Operating Permits to Construct. The designations and issued permits are available in PDF format below. Please note that only the designations and permits are included here; the supporting documentation and data are available at the NDEP office or upon formal request.
| DeMinimis Designations | |
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Units which receive a De Minimis designation are not required to add control technology for the reduction of mercury emissions pursuant to NvMACT. The De Minimis mercury emissions level is 5 lbs/yr per facility. A facility may select the units of its choice, whose total combined mercury emissions are less than or equal to 5 lbs/yr. Units may not be considered De Minimis if they utilize a control for the reduction of mercury emissions. In this manner, a facility can not make a large-emitting unit De Minimis by adding a control technology. De Minimis is intended only for the smallest of emitting units. De Minimis potential to emit is calculated based on maximum operation scenarios utilizing stack tests or material assay data to calculate emissions. The majority of De Minimis units are laboratory equipment such as hotplates, drying ovens and spectrometers. It is important to note that De Minimis units are not "out" of the Nevada Mercury Control Program. Facilities must demonstrate annually that their De Minimis units have not changed and that De Minimis emissions have not exceeded the 5lbs/yr threshold. | |
| Phase-1 Permits | |
| The purpose of Phase-1 is to issue permits that require the continued proper operation of existing mercury controls and to implement work practice standards on units without controls to minimize mercury emissions until NvMACT is determined. Phase-1 permits do not have mercury emission limits. Mercury emission limits are established in Phase-2 after the Maximum Achievable Control Technology is determined for every thermal unit (which is not De Minimis). Phase-1 permits also define the stack testing requirements. | |
| Phase-2 Permits | |
| The Phase-2 permit contains the NvMACT control technology and NvMACT mercury emission limit for a thermal unit. NvMACT is a case-by-case analysis. Each NvMACT determination is unique to the individual unit; NvMACT is not universal for the unit type. NvMACT is determined pursuant to the provisions in NAC 445B.3677.3. The Phase-2 permit contains comprehensive work practice standards, monitoring, record keeping, reporting and testing requirements. Issued Phase-2 permits have undergone a 30-day public notice and comment period.
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