NSR Update 2012 - New Challenges for Refiners

摘要

The NSR Program continues to undergo rapid transformation as a result of the USEPA's now decade long effort to reform the rules. Additionally, clarifications to the rule resulting from implementation guidance issued by the Agency and judicial review of aspects of the rule have resulted in new and, sometimes improved understanding of NSR related issues. In prior papers the authors have addressed efforts to adopt new PM2.5, S02 and N02 NAAQS and the challenges presented by the new NAAQS. This paper addresses the following issues which have emerged in the last year: