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NSR Issues for Reform: Addressing Emissions from Debottlenecking Projects

During this final webinar in a four-part series, Trinity senior NSR experts discuss the issue of NSR applicability for complex projects that impact emissions from both modified and unmodified existing emissions units (i.e., "debottlenecking" projects) including the regulatory and legal background, the difficulties and ambiguities under current rule or policy, possible approaches to reform, and their associated implications for industry. Viewing this webinar will help environmental professionals who are responsible for major source permitting for their companies to develop a useful framework from which to monitor future developments.

Topics include:

  • Since debottlenecking is not specifically addressed in the NSR regulations, why are NSR applicability determinations challenged by this issue?
  • How do the recent EPA NSR memos affect NSR applicability analyses involving debottlenecked sources (modified and unmodified emission units)?
  • Complications in how regulators may view debottlenecked sources versus what regulated sources believe
  • Where EPA could offer assistance to regulated sources in dealing with debottlenecking

 


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