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90-Day NSR Study and NSR Improvements

90-Day NSR Study and NSR Improvements. May 2002. National Energy Policy Recommendation.

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90-Day NSR Study and NSR Improvements

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  1. 90-Day NSR Study and NSR Improvements May 2002

  2. National Energy Policy Recommendation “The NEPD Group recommends that the President direct the Administrator of the Environmental Protection Agency, in consultation with the Secretary of Energy and other relevant agencies, to review New Source Review regulations, including administrative interpretation and implementation, and report to the President within 90 days on the impact of the regulations on investment in new utility and refinery generation capacity, energy efficiency, and environmental protection.”

  3. Meetings/Hearings • 4 Public Meetings • Interagency meetings with over 100 stakeholder groups • 30 day public comment period ending on July 27 • Over 130,000 comments • Separate meetings on routine maintenance, repair and replacement

  4. Stakeholder Issues/Concerns • Industry • Routine maintenance • Aggregation • Debottlenecking • Emissions test • States • No netting • STAPPA Principles • No second guessing • Environmentalists/Local Groups • Need to have much better discussion of public health benefit of NSR • Pursue enforcement cases • Gather more information on how permitting is currently working

  5. 1996 Proposed NSR Changes • Offramps • National Security Exclusion • Clean Unit Exclusion • Pollution Control Project Exclusion • Plantwide Applicability Limits (PAL) • 1990 Act Changes • 1990 Clean Air Act Requirements • Ozone Depleting Substances • Special Netting Requirements • Process Changes • Undemonstrated Control Technology or Application • Applicability Issues • Actual Emissions Baseline • Class I Issues • Use of Prior Shutdowns and Curtailments • Demonstrated in Practice • Cut-off Date for Consideration of New Control Technologies • Revisions to BACT process • PSD Preconstruction Monitoring

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