Clean Air Act Update: NSR and PSD Headaches Abound For Facilities

摘要

Complying with New Source Review (NSR) and Prevention of Significant Deterioration (PSD) regulations always has been challenging. Not only are these regulations complex, they also are probably the most ambiguous in the Clean Air Act (CAA). Determining whether a facility action triggers NSR or PSD is highly subjective, and often relies on extensive research into U.S. Environmental Protection Agency (EPA) policy and guidance.