Preparing for Clean Air Act Section 114 Requests: Procedures of Internal PSD Auditing
This paper contains a detailed procedure for approaching a historical New Source Review/Prevention of Significant Deterioration (NSR/PSD) audit which was derived from the experiences of PSD auditors in the pulp and paper industry. This procedure uses a two-tiered screening approach to identify those projects which may have required NSR/PSD review and culminates in the preparation of an audit report. The elements of a successful audit, what items of information are key in determining past projects that may have triggered NSR/PSD, and the advantages gained by undertaking an audit are discussed in this paper. It is anticipated that the procedure presented in this paper, based on actual auditing experiences, will help facilities address historical NSR/PSD issues in preparation for Clean Air Act Section 114 requests.