New Source Review reform as applied to the Portland cement industry

Often, in the haste of making desirable improvements to a cement plant operation, insufficient thought is given to the regulatory requirements of New Source Review (NSR). The enforcement ramifications of a failure to fully consider NSR can be time-consuming and expensive. It is important that decision-makers recognize the need to consider NSR requirements during planning for projects. On December 31, 2002, the United States Environmental Protection Agency (USEPA) promulgated important final changes to NSR procedures for existing plants to simplify the NSR process and to provide more certainty and flexibility to the regulated community. The USEPA also proposed a system to clarify the requirements for certain activities to qualify for the exclusion of routine maintenance, repair and replacement (RMRR) from NSR. This paper presents a brief review of significant points in NSR and discusses, in general terms, the final and proposed changes to the NSR program.