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EPA’s Final New Source Review Rule and “Routine Maintenance” Proposal: An Analysis of Key Provsions

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  • date(s):

    January 30, 2003

related attorney(s):

On Thursday, January 30, 2003, at 3:00 p.m. EST/12:00 p.m. PST, Morgan Lewis will host a teleseminar, "EPA'sFinal New Source Review Rule and Routine Maintenance Proposal: An Analysis of Key Provisions." The teleseminar will cover the following topics:

- EPA's new "actual-to-projected-actual" emissions increase test for determining NSR applicability;

- Authorization for 10-year look back for determining baseline emissions;

- New plantwide applicability limitation, clean unit, and pollution control project exclusion provisions; and

- Proposal to clarify meaning of "routine maintenance, repair, and replacement" exclusion.

This program will be a primer on the NSR rule and "routine maintenance" proposal published in the Federal Register on December 31, 2002. It will provide a good overview of the framework and elements of the revised NSR requirements and "routine maintenance" proposal.