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To prevent facilities from excluding emissions up to their allowable or potential to emit, the rule specifies that excluded emissions must be determined using actual operational data that occurred during the two (2)-year baseline period.
There are a number of ways to evaluate and document excludable emissions from an emissions unit that vary in complexity depending upon the nature of the unit.
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Now, there exists a distinct possibility that several pieces of the NSR applicability puzzle could change depending on the outcome of an ongoing NSR enforcement action filed by the U. The NAAQS are the ultimate basis of the NSR programs. EPA enforcement action involves the potential modification of an existing major stationary source, and more specifically involves the detailed math of determining how much of an emission increase will result from the modification.
The NSR programs were established to ensure that the NAAQS are attained and maintained as major new emissions sources are constructed and as existing emission sources are modified in a manner that increases their emissions as a part of facility expansion projects. Determining whether or not a project at an existing major stationary source will result in a “net significant increase” under the NSR rules at face value does not appear to be a difficult task.
For existing emissions units at an existing major stationary that are undergoing a change as part of a project, emissions that the unit could have accommodated during the baseline period can be subtracted from (i.e., excluded) from the PAE for that unit in Step 1 of the applicability analysis.
As previously stated, this provision is sometimes referred to as the “demand growth exclusion” in which projected emissions increases that are unrelated to the project are assumed to result from growth in product demand (and are therefore excludable).
The crafters of the Federal Clean Air Act (CAA) specifically state that increased operation of a source is not an emission increase for NSR purposes as long as the source was capable of that operation prior to the modification.
The intent is to not penalize the company simply because it did not have the demand, or need, to operate the source.
articles addressing issues that facilities face when contemplating plant improvement projects that have the potential to trigger new source review (NSR) permitting requirements.
While we have published multiple articles since that time that relate to the underlying foundation of the NSR regulations (i.e., national ambient air quality standards or NAAQS) and how certain technical elements of NSR permit applications are changing (e.g., modeling revisions), we have not specifically addressed topics related to determining NSR applicability. This enforcement action involves the determination and use of “excludable” emissions in NSR applicability determinations (among other issues) for existing emission sources.
A key piece of the equation and apparently the key issue in U. EPA’s 2010 enforcement action is how “excludable” emissions are determined and used in an NSR applicability evaluation.Tags: Adult Dating, affair dating, sex dating