ENV-11-11 NSR 2011 Update - New Challenges for Refiners

Description:

The NSR Program is undergoing rapid transformation as a result of the USEPA's efforts to adopt new PM2.5, SO2 and NO2 NAAQS along with the new requirement to cover GHGs under the PSD program. The challenges presented by the new NAAQS are formidable. PSD increment compliance and SIL demonstrations are very difficult for the new 1-hour ambient air quality standards and there is little available guidance for the states to rely upon to process permits. Additionally, the Agency has undertaken an effort to develop a GHG NSPS for the refining industry. Those efforts are certain to influence BACT selection long before the NSPS is finalized. This paper addresses the new requirements in the context of the petrochemical and refining industry and provides a crystal ball look into the future.