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
             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 STAPPA/ALPACO to the Secretary we at
             DHEC are concerned that major revisions to the NSR process will be made
             ...