EPA's permitting gauntlet

What happens if the US Environmental Protection Agency targets your refinery for an investigation of compliance with the New Source Review (NSR) provisions of the Clean Air Act (CAA)? At least 6 corporations, including more than 30 refinery locations, have received the EPA's CAA Section 114 letter.As survey editor, I find it occasionally necessary to work with historical data, searching for facts and figures from just a few years ago, now filed away in cabinets in various parts of the building. An NSR investigation, by comparison, is more than time-consuming. It's an overwhelming paper chase.NSR regulation developmentIn 1980, the EPA issued a 20-page document that required US ref...

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