ENV-13-54 2013 Update – No Relaxation in Challenges for Fuel and Petrochemical Manufacturers

Description:

This paper addresses the following issues which have emerged in the last year: • Key court decisions impacting the applicability and enforcement of the NSR rules; • Potential NSR challenges created by USEPA’s plans to overhaul the startup, shutdown and malfunction (SSM) provisions of many SIPs and federal rules; • EPA’s guidance related to the continued use of Significant Impact Levels (SILs) and Significant Monitoring Concentrations (SMCs) which are especially important PSD tools; and • A series of emerging GHG issues that potentially will sweep more industrial operations into the PSD program.