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In the existing requirements for New Source Review NSR the rules on determining routine maintenance repair or replacement are arcane and difficult to follow Currently there is difficulty in determining which document to follow since there are over 4000 pages worth of material that is often contradictory not easily obtainable and written with little oversight As a matter of public policy we believe that all changes must go through the rule-making process This will ensure that all interested parties have the opportunity for input for example the definitions of physical changes or changes in operation that are specifically not modifications including routine repair and replacement White Paper We favor a simplification process which gives industry timeliness and certainty but retains a strong technology requirement for all modified sources Simply put there should be a coherent set of guidelines that clearly spell out what thresholds are used to determine when the routine maintenance repair or replacement exclusion is applicable This would serve two goals it would allow industry to plan better its ongoing engineering capitol work plans to improve emissions and it would remove regulatory uncertainty The costs of pollution control are NOT too burdensome at this time As noted by Tom Gibson an Associate Administrator with the Environmental Protection Agency EPA in the Austin Chronicle To draw the conclusion that environmental requirements are a primary cause of this trend referring to US oil supply constraints at refineries is to our knowledge not supported by any study And pollution operating costs have been and continue to be a small part of the overall operating costs As noted in a letter from STAPPAALPACO to the Secretary we at DHEC are concerned that major revisions to the NSR process will be made without input from us Under current law a number of types of modifications to existing sources are exempt from NSR it is our understanding that the Administration is now considering
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