NSR Issues for Reform: Project Aggregation – Properly Defining the Project

Trinity Consultants
Training overview
1 day

Course description

Defining the “project” is crucial to completing any NSR/PSD applicability determination. At a facility with many operations, coincidentally timed projects, and production of intermediates, identifying a specific project, based on EPA guidance, is necessary for making a proper applicability or non-applicability determination. Despite leanings of the current administration, EPA relies most frequently on the criteria established in the 1993 3M Maplewood case to determine if multiple activities at a stationary source should be “aggregated” as a single project to prevent sham minor source permitting or improper PSD/NSR circumvention.

Our presenters will look back to proposals made under the Bush administration to explore possible direction by the Trump EPA on updated and clarifying NSR aggregation guidance.  In addition, we will examine the 1993 3M Maplewood memo to review the implications of maintaining the status quo in applying this guidance going forward.  Elements related to timing, intrinsic operational interdependence, and funding will be reviewed.

About supplier

Trinity Consultants

Trinity Consultants - environmental consulting

Trinity Consultants is an environmental consulting company that specializes in industrial air quality issues. With offices nationwide and in China and the Middle East, they help organizations comply with applicable environmental regulatory requirements and optimize environmental performance for long-term sustainability....

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