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Hidden exclusions.
When determining applicability of the CAA NSPS (Part 60) or NESHAP (Parts 61 and 63) standards, the “source category” and “affected source” (or “affected facility”) are carefully defined terms. In addition, many of the terms used within these definitions are also carefully defined. EPA’s goal was to explicitly identify which sources are subject to each standard.
Because of this, hidden within many of these definitions are exclusions that may exclude your source from applicability of some or all of the requirements. So always check the definitions carefully when determining NSPS and NESHAP applicability. Additional compliance morsels can be found on our website.
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McCoy and Associates, Inc. makes no representation, warranty, or guarantee in connection with any guidance provided above. McCoy and Associates, Inc. expressly disclaims any liability or responsibility for loss or damage resulting from its use or for the violation of any federal, state, or municipal law or regulation with which such guidance may conflict. Any guidance above is general in nature related to the federal environmental regulations. Persons evaluating specific circumstances dealing with environmental regulations should review state and local laws and regulations, which may be more stringent than federal requirements. In addition, the assistance of a qualified professional should be enlisted to address any site-specific circumstances.
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