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NSR Reform: What Qualifies for the Routine Maintenance, Repair, & Replacement Exclusion

During this third webinar in a four-part series, Trinity senior NSR experts discuss the issue of activities that qualify under the routine maintenance, repair, and replacement exclusion 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. This webinar will inform 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: 

  • Background on the exclusion based on various court cases and guidance memos from EPA
  • Discussion of why making RMRR determination is complex given the guidance, enforcement, and results of litigation of the past
  • Possible best practices in documenting and utilizing RMRR with or without support of emissions change testing
  • Where EPA could offer assistance to regulated sources in dealing with case-specific nature of RMRR determinations

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