This paper describes the evaluation of several actual projects at a recycled box board plant and a vegetable oil processing plant as case studies to illustrate how the New Source Review (NSR) Reform provisions have achieved the desired objectives of reducing paperwork and encouraging investment in process improvements that result in emission reductions and other environmental benefits. It is the authors’ experience that application of the actual-to-projected-future-actual test in place of the actual-to-futurepotential test for determining NSR applicability has reduced the number of applications for “synthetic” minor modifications. The project case studies contrast the differences between the old NSR provisions, the NSR reform package that went into effect in March 2003, and the stayed NSR reform rules. The case studies indicate that the NSR reform provisions have reduced administrative paperwork for both permit applicants and regulatory agencies while encouraging improved energy efficiency and better environmental performance.
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