An official website of the United States government.

This is not the current EPA website. To navigate to the current EPA website, please go to www.epa.gov. This website is historical material reflecting the EPA website as it existed on January 19, 2021. This website is no longer updated and links to external websites and some internal pages may not work. More information »

New Source Review (NSR) Permitting

Routine Maintenance, Repair and Replacement

Date Title EPA Office Author Issues Addressed
02/12/2004 Wynnewood Refining Company Wynnewood Refinery in Garvin County, Oklahoma Region 6

Neleigh, David

Whether a proposed replacement of the Fluid Catalytic Cracking Unit (FCCU) reactor cyclone system qualifies as a “routine maintenance, repair and replacement” project.
04/01/1999

Turbine Replacement Issue

Region 2 Riva, Steven Whether turbine repair/replacements under PSE&G’s turbine repair/maintenance program should be considered modifications.
01/29/2003 Assistance on Permit Determination for P.H. Glatfelter Company Regarding Routine Maintenance, Repair and Replacement Region 5 Miller, Robert Whether a project that would replace approximately 1060 steam tubes in one of the facility’s boilers with new steam tubes does not qualify for the “routine maintenance, repair and replacement” exemption.
05/23/2000 Applicability Determination Regarding the Proposed Replacement and Reconfiguration of the High Pressure Section of Two Steam Turbines at Detroit Edison's Monroe Power Plant Region 5 Lyons, Francis Whether a project that would replace and reconfigure the high-pressure section of two steam turbines at Detroit Edison’s Monroe Power Plant is a major modification.
09/14/2001 Opinion on if Packaging Corporation of America Project is Routine Maintenance Region 4 Worley, Gregg Whether a project that would replace all of the tubes in a Recovery Boiler generating bank, and replace 44 tubes of the recovery boiler’s economizer at a pulp and paper mill should be considered routine maintenance, repair or replacement.
09/09/1988 Applicability of PSD Requirements to the Wisconsin Electric Power Company Port Washington Life Extension Project OAR Clay, Don Whether two physical changes made at five combined-cycle gas turbine units (installing a GE operating kit, referred to as a “2055 degrees F Upgrade” kit on each of the turbines and installation of inlet air fogging systems on each turbine) are routine maintenance, repair or replacement.
10/03/1978 PSD - Routine Maintenance, Repair and Replacement SSCD Reich, Edward Addresses the meaning of replacement and whether it includes the replacement of an entire facility (i.e., an old heater at a petrochemical plant which has ended its normal useful life).
01/28/2002 Assistance in Determining Routine Maintenance, Repair or Replacement Region 4 Smith, Winston Whether a project that consisted of “adding additional tubes from the upper steam drum to the lower water drum and changing the baffling in the main steam drum” of a recovery boiler at a pulp and paper mill should be considered routine maintenance, repair or replacement.
11/05/2001 Response to Inquiry Regarding Routine Maintenance, Repair and Replacement Analysis for Recovery Furnace Modifications at Longview Fibre, Longview Mill and Boise Cascade Corporation, Wallula Mill Region 10 Cole, Doug Whether a project that would completely reconstruct the firebox in a recovery furnace is a physical change that is not routine. Also, addresses whether a project that would replace the economizer and generator bank tubes at a recovery furnace constitutes routine maintenance, repair or replacement.
08/28/1998 Turbine Enhancements and PSD Applicability -- Holcomb Station Region 7 Toensing, Don Whether proposed turbine upgrades qualify as routine maintenance or replacement given that the modified unit incorporates redesigned/upgrading blades.
04/17/2001 EPA Region VIII's Opinion on Otter Tail Power Company's Coyote Station Low Pressure Rotor Upgrade Proposal Region 8 Long, Richard Whether a proposed low pressure rotor upgrade at Otter Tail Power Company’s Coyote Station Power Plant constitutes “routine maintenance, repair, and replacement.”
09/13/2000 No. 1 Recovery Furnace Maintenance, Repair and Replacement Project, PCA Pulp and Paper Mill, Valdosta, Georgia Region 4 Neeley, R. Douglas Whether a project that would include several maintenance, repair and replacement actions for a recovery furnace at a pulp and paper mill is routine.
03/19/2002 Applicability of PSD-WEPCO Rule for Existing Five Combined-Cycle Combustion Turbines at Cogen Technologies, Union County Region 2 Riva, Steven Whether two physical changes made at five combined-cycle gas turbine units (installing a GE operating kit, referred to as a “2055 degrees F Upgrade” kit on each of the turbines and installation of inlet air fogging systems on each turbine) are routine maintenance, repair or replacement.
11/18/2002 Opinion on Whether Making a Bypass Stack Functional Constitutes Routine Repair and Maintenance Region 3 Morris, Makeba Whether project that would make “repairs” to the bypass stack of a 52 MW combustion turbine (i.e., making the bypass stack and associated dampers operational) is a physical change and/or a change in the method of operation that does not fall within the routine repair and maintenance exemption.
05/11/1979 PSD Regulations SSCD Reich, Edward Addresses the question of what "repairs" and “replacements" can be classified as routine as it applies to a particular source. Also addresses the meaning of routine replacement.
08/06/2002 Marathon Ashland Petroleum LLC, St. Paul Park Refinery, Request for PSD Applicability Determination for FCCU Air Grid Maintenance and Replacement Project Region 5 Miller, Robert B. Whether a project that would replace the air grid on the FCCU catalyst regenerator qualifies for any of the seven exemptions in 40 C.F.R. § 52.21(2)(iii) (including the RMRR exemption).

Related Topics: Alternative Fuels Exclusion

Return to Policy & Guidance Document Index

The “Relevant Guidance” index includes a collection of documents issued by EPA organized by topic area. These documents include memoranda, letters, orders, and other types of EPA actions that may provide guidance in one or more forms, such as an adjudication, statement of policy, interpretation of statutes or regulations, or technical information. Each collection is intended to be representative of EPA statements on the topic, but it may not be a complete listing of such statements. The collection does not reflect topic-specific statements that have been expressed by EPA though published rule preambles and Title V petition orders, nor does it include EAB decisions. Each document in the collection speaks for itself, and the inclusion or exclusion of a document in the collection is not intended by EPA to communicate anything more than what is expressed within each document. EPA makes no independent representations on this website as to the extent to which any document in the collection reflects EPA’s current views on the topic, is a final action by EPA, or has any legal effect or precedential weight. Readers are advised to review the documents in the collection and conduct their own assessment of such considerations based on the content of each document and other documents in the collection. Some of the information or views included in the documents may be affected by subsequent changes to the referenced statutory or regulatory language or by court decisions. In addition, many of the statements in these documents are based upon the federal regulations which may differ from rules that govern federally-approved programs. Permitting authorities are advised to consult with their EPA Regional Offices if there is a question as to the relevance of a particular statement to their NSR program.